Loyalty Club

ALIANTHOS ESTATE RESORT CCTV

2nd Level Information Notice of the Company EMMAN VARDAKIS ALIANTHOS S.A. regarding the processing of personal data through a video surveillance system

Last updated: September 22, 2026

The company under the name "EMMAN VARDAKIS ALIANTHOS S.A.", based in Rethymno, Crete, in the area of Plakias (P.C. 74060) of the Municipality of Ag. Vasileiou, with Tax Registration Number (AFM): 094118026, Tax Office (DOY) of RETHYMNO (hereinafter referred to as "the company"), which manages and operates the Hotel "Alianthos Estate Resort" (hereinafter referred to as "Hotel"), recognizing the importance of protecting the personal data of its visitors, partners, suppliers, and staff, and having as one of its primary concerns compliance with Regulation (EU) 2016/679 (GDPR) and relevant national legislation, has drafted this policy to fully inform data subjects about the Operating Policy of all Video Surveillance Systems maintained on the Hotel's premises, the terms of their installation and operation, the security measures taken to protect personal data, as well as the rights of access to the maintained data.

Video surveillance systems are defined as those systems that are permanently installed in a space and have the capability of capturing and/or transmitting images and/or sound to display screens or recording equipment (where cameras can be connected to the screen or recording equipment either directly or via a network/internet). Our policy does not apply to cases where image and/or sound capture is performed using handheld cameras, photo cameras, mobile phone devices, video conferencing systems, audio-visual recordings of events, or video shootings for the production of material for the company's social media.

1. Data Controller

The company under the name "EMMAN VARDAKIS ALIANTHOS S.A.", based in Rethymno, Crete, in the area of Plakias, P.C. 74060, Municipality of Ag. Vasileiou, with Tax Registration Number: 094118026, Tax Office of RETHYMNO, is the data controller for all cameras installed at the hotel "Alianthos Estate Resort" located in Plakias 74060, Rethymno, Crete.

The contact details of the legal entity are:

Alianthos Estate Resort

Telephone: +30 28320 31280

info@alianthosestate.com

Plakias 74060, Rethymno, Crete

https://www.alianthosestate.com

As the data controller, the Company bears all obligations deriving from the GDPR, Law 4624/2019, and the Guidelines of the Data Protection Authority.

2. Data Processed

The personal data collected during the operation of the video surveillance system are image and video data of visitors and staff present on the Hotel premises.

3. Purpose of Processing and Legal Basis

We use a surveillance system for the purpose of protecting persons and goods, monitoring and preventing illegal entry, protecting the Hotel's visitors and staff as well as our company's partners, and protecting our assets from theft, arson, or other illegal acts. We use a surveillance system for the purpose of protecting persons and goods. The processing is necessary for the purposes of the legitimate interests pursued by us as data controller (Article 6 par. 1(f) GDPR).

4. Analysis of Legitimate Interests

The company seeks to offer the maximum possible level of security on the Hotel premises, while always respecting the privacy of those present in the space. For these reasons, we use a video surveillance system equipped with privacy-friendly technology, carefully positioned to ensure that monitoring is restricted, to the extent possible, to the spaces and goods strictly necessary for the intended purposes.

Our legitimate interest consists of the need to protect the Hotel premises and the goods located therein from illegal acts, such as indicative theft, vandalism, fire, as well as the timely detection of malicious actions. The same applies to the safety of life, physical integrity, health, and property of our staff as well as any third party lawfully present in the monitored area.

We collect image data only, through the use of fixed cameras that do not collect sound nor have optical zoom capabilities. Capture is limited to areas where we evaluated a higher probability of illegal acts occurring (e.g., theft), such as at our cash desks, server room, and entry/exit points of the Hotel and its private parking area provided for guests, as well as areas requiring a high level of security, such as the accounting department and our electromechanical installations, using cameras that focus exclusively on the protected asset.

No cameras have been placed in open areas, and no images are taken from external public spaces, roads, sidewalks, or neighboring buildings. Furthermore, no cameras are placed in dining areas, hallways leading to hotel rooms, or areas where guests and/or visitors of the hotel might be monitored (such as individual room entrances, staff break areas, toilets, and areas where recreational activities take place, such as swimming pools, gyms, sports facilities, changing rooms, etc.). We do not focus on areas where the private life of the persons whose image is captured might be excessively restricted, including their right to respect for personal data.

Personal Data collected through the system are under no circumstances used for monitoring work, evaluating the behavior, or measuring the efficiency of employees.

5. Recipients

The maintained material is accessible only by a small, clearly defined number of authorized personnel charged with the security of the area, who are bound by relevant confidentiality and secrecy clauses. This material is not transmitted or disclosed to third parties, with the exception of the following cases:

  1. a) to the competent judicial, prosecutorial, and police authorities when it contains information necessary for investigating a criminal offense concerning persons or goods of the data controller,
  2. b) to the competent judicial, prosecutorial, and police authorities when they lawfully request data in the performance of their duties, and
  3. c) to the victim or perpetrator of a criminal offense, when the data may constitute evidence of the act.

Our Company has taken all appropriate organizational and technical measures to ensure that the processing of your personal data, whether by itself or by third parties on its behalf, is lawful, appropriate, and maintains an adequate level of security to prevent unauthorized or accidental access, processing, erasure, alteration, or other use thereof.

6. Retention Period

We retain the data for thirteen (13) days, after which they are automatically deleted. If an incident is identified during this period, we isolate a section of the video and retain it for up to one (1) additional month for the purpose of investigating the incident and initiating legal proceedings to defend our legal interests. If the incident concerns a third party, we will retain the video for up to three (3) additional months.

7. Informing Data Subjects about Video Surveillance

The company informs data subjects about video surveillance in the following ways:

  • Through the text of the Personal Data Protection Policy posted on the website https://www.alianthosestate.com. This policy applies to customers, partners, suppliers, and any third party visiting the Hotel premises.
  • Through warning signs.

8. Your Rights

Data subjects have the following rights:

  • Right of access: You have the right to know if we are processing your image and, if so, to receive a copy of it.
  • Right to restriction: You have the right to request that we restrict processing, such as asking us not to delete data you consider necessary for establishing, exercising, or defending legal claims.
  • Right to object: You have the right to object to the processing.
  • Right to erasure: You have the right to request that we erase your data.

You can exercise your rights by sending an email to kvardakis@alianthosestate.com, a letter to our postal address, or by submitting the request in person at our address.

To examine a request related to your image, you will need to specify approximately when you were within the range of the cameras and provide an image of yourself to help us locate your data and conceal the data of third parties depicted. Alternatively, we offer you the possibility to visit our premises so that we can show you the images in which you appear. We also note that exercising the right to object or erase does not imply the immediate deletion of data or modification of processing. In any case, we will respond to you in detail as soon as possible, within the time limits set by the GDPR.

If you have questions regarding our practices concerning personal data or the exercise of your rights, you can contact the Company at kvardakis@alianthosestate.com.

9. Right to Lodge a Complaint

In case you consider that the processing of your personal data violates Regulation (EU) 2016/679, you have the right to lodge a complaint with a supervisory authority.

The competent supervisory authority for Greece is the Hellenic Data Protection Authority, Kifissias 1-3, 115 23, Athens, https://www.dpa.gr/, tel. +30 2106475600.

10. Amendment of this 2nd Level Notice

This Statement may be amended periodically to reflect any changes in our company's policy and practices. When we make changes to this Statement, we will publish a link to the revised version on the homepage of our website.