We are committed to safeguarding the privacy of our customers and website visitors; this policy sets out how we will treat your personal information.
This policy refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.
ICON uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which we believe may be of interest to you and your business. In you making initial consent to marketing contact from ICON we shall maintain a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. We may from time to time use such information to collect statistics about the behaviour of visitors to our website.
What information we process?
Personal information is any information about you as an identifiable individual. The personal information that we process includes:
- Basic information – such as name, surname, date of birth, gender, passport and/or ID information and publicly available photograph;
- Contact information – such as your home address, zip/postal code, email address and phone number;
- Financial information – itemised spending and transaction history; We DO NOT STORE any credit card details;
- Health information where disclosed and relevant to the provision of services;
- Preferences – such as special requests, service issues and other preferences for your stay;
- Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information, in the case of our website); and
- Correspondence – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.
How/When do we collect the Personal data
We gather information when you provide it to us, or interact with us directly, for example:
- when you create a profile or sign in to access an existing profile on our website;
- when you make a purchase through our website;
- when you make a reservation online, by calling our Reservation Office or reception directly; and
- during your stay at the Icon, including information provided during check-in.
We also receive information about you from other sources, such as our business partners, tour operators, travel agents and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us.
Any information ICON holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.
We will only collect the information needed so that it can provide you with marketing and consulting services, we do not sell or broker your data, although coincidentally there may be times when your information could be contained in data that ICON has purchased from a third-party list broker, on behalf of a client.
Legal basis for processing any personal data
- To meet contractual obligations to our clients and to also respond to marketing enquiries.
- to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors.
- Legitimate interests pursued ICON. using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalized to you, and to make your experience of our services more efficient and effective
- To promote the marketing and services offered by ICON
- because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes through agreeing to this privacy notice you are consenting ICON processing your personal data for the purposes outlined. You can withdraw consent at any time by e mailing us at email@example.com
- for the establishment, exercise or defence of legal claims or proceedings.
ICON may on occasions pass your Personal Information to third parties (as shown below) exclusively to process work on its behalf. ICON requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.
We do not broker or pass on information gained from your engagement with us without your consent. However, we may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. We may also enforce our Terms and Conditions, including investigating potential violations of our Terms and Conditions () to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of ICON, our clients and/or the wider community.
We may share certain of your personal information with:
- agents, contractors or third party service providers of The Icon who provide services to us for better serve your needs as a Guest;
- Analytics and search engine providers that assist The Icon in the improvement and optimization of our website;
- our professional advisors and auditors; and
- local or foreign regulators, governments, courts, law enforcement and national security authorities.
We will process your Personal Data during the duration of any contract and will continue to store your personal data until you exercise your right to be forgotten. In such case your Personal Data will be destructed within 30 calendar days from the date you have exercised your right to be forgotten, unless ICON has a valid and legitimate reason to the extent required or otherwise permitted by law, to continue to process and/or hold your personal data and you will be informed accordingly.
Data is held in Cyprus, Italy, and Germany. ICON does not store personal data outside these areas.
Your rights as a data subject
We understand that you may like to know what personal information we hold about you. We are happy to assist you with your request. To protect your personal information, however, we require that you prove your identity to us at the time your request is made.
When you make a request in person, we will require you to produce some form of photo identification such as a passport or your ID card and you will be asked to sign a request form.
Where you make a request by other means, we request you contact us in writing via email, fax or letter including a copy of a government issued identification and signature. We require home and business addresses and phone numbers so we can check them with our files and verify your identity.
The above information is required to create an audit trail of how the request has been handled.
ICON reserves the right to decline access to your personal information under certain circumstances as permitted by law. If your personal information is not disclosed to you, you will be provided with the reasons for this non-disclosure.
You are entitled at any time to exercise the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
All requests should be made to firstname.lastname@example.org.
If you do not wish to receive marketing information from ICON, you may indicate your wishes on your registration from when you stay with us or send an e-mail to: email@example.com
You will always have the ability to accept or decline any form of communication from ICON.
You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
After you have chosen to withdraw your consent ICON may be able to continue to process your personal information to the extent required or otherwise permitted by law.
We, us, our or ICON - refers to Y.A.M. Imperio Enterprises LTD, a company incorporated and validly existing in the Republic of Cyprus, with Registration no. HE141929 and any of its Subsidiaries and/or Affiliated Companies.