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Privacy Policy

This privacy policy (“Policy”) has been drafted by and applies to ΑΔΕΛΦΟΙ ΑΝΤΩΝΙΟΥ ΕΣΤΙΑΤΟΡΙΑ ΛΙΜΙΤΕΔ, a company registered in Cyprus with registered number ΗΕ 117151 and all their subsidiaries (collectively, “ANTONIOU BROTHERS" "we," or "us").

At ANTONIOU BROTHERS, we value and respect your privacy and would like to prove this through this Privacy Policy which demonstrates our compliance with the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the “Regulation”) which is directly applicable in the European Economic Area from 25 May 2018, and has introduced new measures aiming to protect your Personal Information and thus your privacy.

ANTONIOU BROTHERS, as a legal person determine the purposes and means of processing of Personal Information we receive. This means that ANTONIOU BROTHERS is the “controller” of Personal Information we receive and process and thus we have and take responsibility in our capacity as a controller, up to the extent that the information is not processed by another controller.

In this Policy, we explain our practices regarding the collection, use, processing and disclosure of your Personal Information, what kind of Personal Information we collect from you and when we collect them.

A. Collection of Personal Information

I. Clients (online and offline)
Except as provided otherwise, in relation to this category of data subjects, the provision of the below data is necessary for the performance of the contract and / or transaction and/or the conclusion of a contract between us. The collection of the below Personal Information is also necessary to comply with our legal obligations to keep our accounting books in order and our legal obligations under the VAT and income tax laws and regulations. Failure to provide them may make our service impossible or illegal to provide.
a) Name in the event of a reservation and/or a delivery and/or take away order;
b) home and/or work and/or another address in the event of catering and/or delivery services;
c) landline and/or mobile telephone numbers and/or email address, fax number. In the event that you make a reservation and/or use our delivery services;
d) credit and/or debit card number, other payment card information and generally payment, pricing and bill information;
e) your order history;
f) your reviews and opinions about our services. The collection of this is based on our legitimate interest to improve our services and/or to deal and/or to handle complaints.

II. Loyalty card holders
This category includes people that have subscribed to our loyalty card. The collection of their information is based on a contract formed between us through the terms and conditions of the application form that has been completed and/or their consent provided through the application form and/or our legitimate interest which are connected to the purposes mentioned under the “Purposes of processing section below, including to improve the goods and services we offer to our guests and/or to potentially offer some form of compensation in accordance to the management’s discretion and/or to send you our newsletters and/or marketing material. If they do not provide the below information they cannot become members. The below Personal Information are over and above what is provided in the event that an individual is also our client.
a) Name of card holder;
b) home and/or another address;
c) landline and/or mobile telephone number and/or email address;
d) all the above information included under the “Clients” sub-section but without a limitation as to what is necessary for the completion or preparation for a contract for the provision of the goods and services referred to under the above sub-section.

III. People who complete our guest comment card
This category includes people who visit our restaurant and complete the guest comment card. The collection of the Personal Information is not based on any contract between the guest and the restaurant or based on a legal requirement and/or obligation of ours. It is based on the guest’s consent provided through the completion of the guest comment card and/or our legitimate interest to improve the goods and services we offer to our guests and/or to potentially offer some form of compensation in accordance to the management’s discretion and/or to send you our newsletters and/or marketing material. The collection of the below Personal Information is necessary so as to investigate and/or resolve any issue and/or complaints a guest may have and to improve the quality of our goods and services and/or to send you our newsletter and/or marketing material.

a) Name of the visitor;
b) address
c) landline and/or mobile telephone number;
d) e-mail.

IV. Personnel
The below data is obtained under the social security regulations and laws, and/or based on your consent and/or our legitimate interest in identifying our staff and communicating with them in the intervals of the execution of our employment contract and/or relationship. Failure to provide the following data results in the employment being illegal and / or in an inability to perform the employment contract.
a) CVs, studies, academic titles, past working experience and evidence of the information included on the CV;
b) Name, title, gender and date of birth, visas, identity number and / or passport number and all the information mentioned therein;
c) Contact details: home address, landline and mobile telephone numbers and email address;
d) health status, examinations and history required by social insurance authorities;
e) tax identification number;
f) social security number;
g) IBAN;
h) Employment contracts and any data recorded on them.

V. Candidate Personnel
These data are necessary for the process of entering into an employment contract and/or relationship with an individual. Failure to do so makes the process impossible and / or undesirable. However, upon closure of the job vacancy we store and maintain the data of individuals whose employment was considered as “Highly Recommended” based on their consent.
a) CVs, studies, academic titles, past working experience and evidence of the information included on the CV; and
b) Name, title, gender and date of birth, visas, identity number and / or passport number and all the information mentioned therein;
c) Contact details: landline and/or mobile number and/or e-mail address.

VI. Suppliers and/or Service Providers and/or their personnel and/or agents
To the extent that we receive Personal Information of suppliers and/or their personnel such information is either necessary for the performance of the service and/or products agreement and/or transactions with us and/or it is based on your consent and/or our legal obligation under and/or rights the VAT, income tax and other taxes laws and/ regulations and/or to keep our accounting books in order and/or our legitimate interests in facilitating the better communication in the intervals of our business relationship and/or cooperation. Failure to provide this information has a negative impact on the flexibility and ease of our communication and might also make our transactions illegal to the extent that our bookkeeping activities are affected.
a) Names of the suppliers and/or our service providers and their employees;
b) VAT numbers;
d) Contact details: address, telephone and/or fax and / or mobile phone number, e-mail address;
e) IBAN and/or bank account number;
c) Profession, professional activities, position and title.

VII. Website and social media page visitors
The reception of the below Personal Information is not done in the process of a contract and/or based on a legal requirement and/or obligation of ours. It is done based on our legitimate interest to improve the goods and services we offer to clients and the public, to understand towards where the demand trends tend to move and to customize the content of our website and/or our social media pages, and/or your consent to the cookies and/or the provision to you of a notice to the use of cookies which appears in our website and/or our social media page and the provision of information on our part as to how to disable them and/or the consent which you have provided to the social media services providers.
a) The IP address of your device;
b) In the event that you use a social media account to access our social media page, your profile username and any Personal Information that are available on your profile;
c) Your movements and/or behavior in our website and our social media page;
d) Cookies information.

VIII. Premises and/or restaurant visitors
The reception of the below Personal Information is not done in the process of any contract and/or a legal requirement but it is based on our legitimate interest to protect our property, the safety of our visitors and/or our personnel and the prevention of criminal activity.
a) your image on CCTV in the event that you pass in front of one of its cameras.
IX. People who communicate with us
These data are not needed in the process of a contract or a statutory requirement but they serve as a means to respond to any inquiry or issue in relation to which you contact us through either post, e-mails or our website or who leave a message through the telephone:
a) your correspondence and communications with us;
b) name;
c) your contact information e.g. e-mail address and / or telephone number.

X. Generally
We may also collect the following which are not based on any contractual or legal obligation:
a) any other publicly available Personal Information, including information that is published on websites and any which you have shared via a publicly available platform such as your or Linked In pages, WhatsApp, Viber, WeChat, Facebook, Twitter or other online social media services when you sign up; and/or
b) any other type of information which you may choose to provide to us or we may obtain about you through third parties with whom we do business during the execution of the below purposes.
If you submit any Personal Information relating to other people, (including your employees, contractors, clients and other individuals) to us, especially Personal Information of minors, in connection with the services, you represent that you have the authority to do so and to permit us to use the Personal Information in accordance with this Privacy Policy which is provided at our restaurant and/or our administration offices and/or in our website.

B. Methods of Personal Information Collection

We always take care for the methods used to be proportionate to and not go beyond from what is needed to serve the legitimate purposes of processing.

We and our service providers and/or agents and/or affiliates may collect Personal Information from either of the following sources and/or routes:
a) directly from you (i.e. during face-to-face contact with a member of our staff or through an e-mail or telephone conversation between you and a member of our staff e.g. when you call yourself to make a reservation); and/or
b) indirectly from you (i.e. through a legal guardian and/or an agent and/or another person/body acting on your behalf e.g. a friend booking a reservation on your behalf); and/or
c) through and/or with the assistance of a third party who has first obtained your permission to share this information with us (e.g. your employer who might be one of our suppliers, or a introducer who refers you to us and generally a person/body providing information about you based on your consent); and/or
d) through another source which comes to our attention during the provision of our services, whether such source is made available in writing and/or by electronic means and/or provides Personal Information in writing or verbally.

The methods used for the collection of Personal Information are the following:
a) requesting the information that is necessary for national insurance purposes when you are employed with us;
b) requests and/or messages sent through the “contact us” section of our website; and/or
c) registrations for loyalty cards when submitting hard copy applications or which are done through our website; and/or
d) when you visit our restaurant and complete our guest comment card;
e) when you communicate with us and/or any member of our staff at our office and/or the restaurant in person and/or over the phone and/or via e-mail; and/or
f) when you visit our offices; and/or
g) when you provide us with your business card; and/or
h) When making an order through the food delivery platform which we use for the provision of our online services; and/or
i) when you have a meeting with any person of our staff and/or representative whether in our offices and/or restaurant and/or in another location and/or through the phone and/or through the internet; and/or
j) from publicly available databases, directories and websites where Personal Information is displayed; and/or
k) cookies used on our website. Our website uses cookies to store small bits of customer information, such as his/her username and shopping cart contents. A cookie is a small file on the user’s computer and makes things such as login sessions and shopping carts possible. In order to ensure privacy, customers logging into our website from publicly accessible computers should delete their cookies and/or browser history before walking away. ANTONIOU BROTHERS never uses cookies to store sensitive information, such as passwords or credit card numbers.

In the event that we receive information from third parties, as opposed to directly from you, provided that they are lawfully entitled to share your Personal Information with us, we will use and share this information for the purposes described in this Statement. Also in the event that your Personal Information is collected in this way, then we will bring to your attention the information included in this Statement along with the source from which the Personal Information originated, and if applicable, whether it came from publicly accessible sources. This information shall be provided to you within a reasonable period after obtaining the Personal Information, but the latest within 1 month, except where the Personal Information are to be used for communication with you, in which case we will provide you with the above information at the latest at the time of the first communication with you. However, if the above information is envisaged to be disclosed to another recipient then the above information shall be disclosed the latest when the Personal Information are first disclosed to the new recipient, despite the fact that none of the previous deadlines has passed. Of course, no such information would need to be provided:
a) where you already have this information;
b) where the provision of this information, for some reason, proves impossible or would involve disproportionate effort to obtain;
c) obtaining or disclosure is expressly laid down by Union or Member State to which we are subject, and which provide measures to protect your legitimate interest; or
d) in the event where the Personal Information must remain confidential subject to an obligation of professional secrecy.

C. Purpose of Processing

We may use Personal Information in the following ways depending on the category of the data subject (it is possible for a person to enter into more than one categories of data subjects):

I. Generally in relation to all
a) for our business purposes, such as data analysis, audits, security and fraud monitoring and prevention (including through the use of closed circuit television), enhancing, improving or modifying our services to ensure that you get high quality services, and expanding our business activities;
b) to identify all the below data subjects and to verify their identity and/or to perform security checks and/or to ensure that we speak to the correct individuals in the intervals of providing our services, especially when providing and/or communicating confidential and/or Personal Information or upon a request for the exercise of your rights in relation to your personal data;
c) to respond to an emergency which sets the physical integrity and health of a person at risk;
d) to permit us to pursue available remedies or limit the damages that we may sustain and/or defend our case in the course of court proceedings against any of the below;
e) to act upon any legitimate interest permitted under the Regulation΄
f) to delete any Personal Information that are no longer necessary for the purposes for which Personal Information are processed.

II. Clients (online and offline)
a) for the provision of services including provision of food and drink, holding of events, catering, delivery of food, online ordering of food and take away services and any other services included in any service agreement and/or contract and/or engagement letter signed and/or entered into by you;
b) to receive payment;
c) to verify the applicability of reservations and to remind you about your reservation in the event of a delay;
d) to respond to you following an enquiry and/or requests and/or complaint in relation to the subject matter of your enquiries and/or requests and/or complaint; and/or
e) to verify your identity upon any request in relation to any reservation at the restaurant or for the delivery of an order; and/or
f) for the purpose of verification of your identity in the event that you wish to access our premises; and/or
g) to permit us to pursue available remedies or limit the damages that we may sustain or defend a case our case in the course of a court case; and/or
h) to respond to an emergency which sets the physical integrity and health of a person at risk; and/or
i) to comply with our legal and regulatory obligations, which may involve VAT, income tax and other tax laws and regulations and the legal requirements to keep accounting books and carry out independent audits, to justify our income, and to respond to governmental inquiries or requests from public authorities when we are obliged to do so.

III. Loyalty card holders
a) to administer the loyalty program;
b) to provide the card holders with the appropriate discounts;
c) to send to the card holders offers and promotion alerts, news and/or other promotional and/or marketing and/or informative and/or material and/or special and/or promotional offers and/or newsletters; and/or
d) for our business purposes, such as data analysis, audits, developing new products and services, enhancing, improving or modifying our services, to ensure that our products and services are of interest to you, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities; and/or
e) to monitor your purchasing behaviour;
f) to contact the card holders to perform data security checks; and/or
g) to combine with information collected from other sources to assist with targeting advertisements;
h) to customise our products and/or services and/or advertising to your preferences and behaviour;
i) to generate statistics in relation to the types and volumes of clients to whom we provide services during the year; and/or

IV. People who complete our guest comment card
a) to investigate and/or resolve any issue and/or complaint a client may have;
b) to provide a form of compensation in accordance to the management’s discretion;
c) to correspond with you in case you have any issue and/or complaint;
d) to improve the quality of the goods and services we offer to our clients;
e) to customise our products and/or services and/or advertising to your preferences and behaviour;
f) for marketing purposes and in particular to send you newsletters, and marketing material with special offers and/or events.

V. Personnel
a) to fulfil our responsibilities under the employment contracts;
b) to administer and organise the personnel;
c) to identify our personnel;
d) to make payments;
e) to permit us to pursue available remedies or limit the damages that we may sustain; and/or
f) to respond to an emergency which sets the physical integrity and health of a person at risk; and/or
g) to monitor compliance with our internal policies; and/or
h) to comply with our legal and regulatory obligations, which may involve the legal requirements to keep accounting books, and social insurance reporting duties and carry out independent audits, and to respond to governmental inquiries or requests from public authorities when we are obliged to do so.
i) To monitor the activity of employees in relation to personal data in accordance with the Regulation.

VI. Personnel Candidates
a) to communicate with the candidate personnel for purposes of setting meeting for interviews
b) to administer the process of interviewing and/or selection of members of the personnel;
c) to gather information about potential employees and candidates for members of staff, if applicable;
d) to make preparations for the entering into an employment contract; and/or

VII. Suppliers and/or service providers and/or their personnel and/or agents
a) for the provision of your services and/or products to us. In particular, the data are used to facilitate our communication with you in the intervals of the execution of a contract and to receive or to request products and/or services which are needed for the operation of the restaurant and the provision of our products and/or services;
b) to permit us to pursue available remedies and/or limit the damages that we may sustain and/or to defend our case; and/or
c) to respond to an emergency which sets the physical integrity and health of a person at risk; and/or
d) to comply with our legal and regulatory obligations, which may involve VAT and other taxes laws and regulations and the legal requirements to keep accounting books and carry our independent audits, and to respond to governmental inquiries or requests from public authorities when we are obliged to do so and/or
e) administration and/or organization of professional meetings in the intervals of the performance of contract and/or entering into contract and/or transaction and/or cooperation with them.

VIII. Website users and social media page visitors
a) to generate usage statistics of our website and our social media pages;
b) to improve our website and make it more user-friendly;
c) to improve and customise our services and/or products;
d) to carry out marketing promotions;
e) to apply and enforce the terms and conditions of our website;
f) to better target advertising and/or
g) monitoring of the traffic of visitors of our website and the products and/or services that are in demand.

IX. Premises and/or restaurant visitors
a) to protect the safety and security of our restaurant’s our premises’ visitors, our personnel, our property, the Personal Information we store and prevent criminal activity;
b) to assist public authorities in the event of a criminal investigation;
c) to return lost items.

X. People who communicate with us
a) to correspond with you in the event that you have contacted us about our products and/or services and/or in the event that you have any other enquiry and/or you want to establish a business relationship.
In the event that we decide to further process your Personal Information for a purpose other than the purposes for which the above Personal Information was obtained, we shall only do so to the extent that the processing is compatible with the purposes in relation to which the data was collected.

D. Disclosure, Sharing and Transfer of Personal Information

Your Personal Information may be shared with the below entities and/or people:
a) authorised personnel at our office, who are appropriately and regularly trained for the processing of Personal Information and are subject to confidentiality obligations in relation to the work they execute;
b) affiliate and subsidiary companies of ANTONIOU BROTHERS;
c) our auditors and/or accountants;
d) our bank in the event that we would like to make a payment and/or they seek justification for any transactions;
e) our legal consultants and/or advocates and/or solicitors and/or barristers and/or lawyers;
f) the Commissioner of Taxation in Cyprus, and any other regulators or supervisory authorities;
g) service providers and/or suppliers who assist us in the provision of our services in our restaurant and/or online and/or who assist us in the storage of the Personal Data and/or the functioning of our offices, such as our software and IT engineer and external social media administrator and/or consultant;
h) non-financial companies (including retailers, online and offline advertisers, membership list vendors, direct marketers and publishers);
i) companies that perform marketing services on our behalf;
j) any physical and/or legal person and/or body to whom you instruct us to transfer your Personal Information;
k) with professional and regulatory organisations such as the income and VAT tax departments, social insurance services and the board of health;
l) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may share your Personal Information to a third party for the purposes of the aforementioned event;
m) We may also disclose information to a third-party who provides substantially similar services as the original service signed up for, if we decide to stop providing such services ourselves;
n) if you visit any of our premises for the purpose of an event and/or meeting, then the Personal Information collected for the meeting and/or event may be shared with (1) the organisers of that event and/or meeting, and (2) where appropriate, the guests who participate in the event and/or meeting.
Where there is no confirmation from the European Commission that a particular country, which is outside the EEA, keeps satisfactory level of protection (e.g. by virtue of an adequacy decision), either standard contractual clauses that have been approved by the European Commission and/or the Office of the Commissioner for the Protection of Personal Information in Cyprus (which is competent data protection authority in Cyprus), shall be used or an authorisation shall be sought.

ANTONIOU BROTHERS shall not, in any way and in any event, directly or indirectly, sell any of your Personal Information to any third party. Any information supplied will be confidential and will be handled in accordance with the applicable laws and regulations.

E. Confidentiality and Personal Information

ANTONIOU BROTHERS must employ suitable personnel and take appropriate organizational and technical measures for the processing of Personal Information, their security and protection from accidental or unlawful destruction, accidental loss, alteration, unauthorised dissemination or access or any other form of unlawful processing.
ANTONIOU BROTHERS carries out checks and/or uses contractual terms to ensure that any party to whom my Personal Information are transferred and/or who has access to Personal Information and who processes Personal Information on behalf of ANTONIOU BROTHERS complies with the principles of confidentiality, the instructions and security procedures specified by ANTONIOU BROTHERS, the Regulation and the law in general. Where any recipient determines the way in which the Personal Information will be processed and the purposes for which they will be processed, due diligence procedure will take place in relation to that recipient to ensure that they carry out checks and/or have contractual terms and/or binding agreements in place to ensure that Personal Information is processed in accordance to the Regulation.
Any information related to you shall not be disclosed to third parties except in the cases allowed and/or mandated under the provisions of the Regulation and the law in general.

F. Legal grounds for collection and processing of Personal Information

We would like to inform you that the legal grounds for receiving and handling your Personal Information, depending on the purpose of processing, may be:
a) that processing is necessary for the provision of the services from and/or any other contractual agreement (e.g. retainer for representation before the court, Engagement Letter, employment contract) you have with ANTONIOU BROTHERS (Regulation, Art. 1(b));
b) to the extent that the collection and processing is not covered by a) then the legal ground will be your explicit consent to the processing of your Personal Information for the above specific purposes (Regulation, Art. 1(a)). You may withdraw your consent at any time by sending us written notice of your wish to withdraw. This may be done in any written format including e-mail and fax; and
c) that processing is necessary for compliance with our legal obligations (Regulation, Art. 1(c));
d) that processing is necessary in order to protect your vital interests or those of another individual (Regulation, Art. 1(d));
e) that processing is necessary for the legitimate interests pursued by us except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where the data subject is a child (Regulation, Art. 1(d)). Direct marketing to existing clients of ANTONIOU BROTHERS is part of the legitimate interests but they may at any point unsubscribe.

G. Your rights

Under the Regulation, you have the following rights:
a. to check whether and what kind of Personal Information we hold about you and to access or to request copies of such data;
b. to be explained clearly and simply the information contained in this Statement;
c. to request correction, supplementation or deletion of Personal Information about you that is inaccurate or processed in non-compliance with applicable legal requirements;
d. to instruct the erasure of your Personal Information from our archives and/or servers and/or back-ups where:
  i. it is no longer necessary for the purposes mentioned in this Statement;
  ii. where you withdraw your consent on which the processing is based and where there is no other legal ground for the processing;
  iii. where you object at any time to the processing of your Personal Information in accordance to point (f) and (g) below;
  iv. your Personal Information has been unlawfully processed;
  v. your Personal Information has to be erased in order for us to comply with our legal and/or regulatory obligations.
e. to obtain a restriction to the collection, processing or use of Personal Information about you where:
  i. the accuracy of your Personal Information is contested by you to allow us to allow us to verify the accuracy of your Personal Information;
  ii. the processing is unlawful but you do not wish us to erase your Personal Information from our archives;
  iii. we no longer need your Personal Information for the purposes of processing, but they are required by you for the establishment, exercise or defence of legal claims; or
  iv. you object to the processing of your information which is based on your consent, subject to limited exceptions such as the establishment, exercise or defence of legal claims;
f. to object to processing of your Personal Information on grounds, relating to your personal situation, which have been obtained based on the necessity for the legitimate interests pursued by us, and to have us no longer process your personal data unless either we demonstrate to you compelling legitimate grounds for the processing which override your interest, right and freedoms, or the Personal Information is needed for the establishment, exercise or defence of legal claims;
g. to object at any time to processing or your data for direct marketing;
h. to the extent that your data is processed on the legal ground of your consent or the processing is carried out by automated means, to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from our part;
i. to know the identities of third parties to which your personal data is transferred;
j. to provide instructions on how your data must be handled after your death when relevant;
k. to lodge a complaint with the competent data protection authority, in Cyprus i.e. the Office of the Commissioner for the Protection of Personal Data;
l. to withdraw your consent at any time. If, following the provision of the consent, you then no longer wish to receive from us on a going-forward basis tax and deadline alerts, tax news and/or other informative material about the state of the law and the economy, important business and legal events and developments at both Cyprus and international levels, you may opt-out by emailing us at neonphaliron@cytanet.com.cy or info@neonphaliron.com or following the instructions in any such email you receive from us or by sending us a fax at 25-341742;
m. to request us to transmit your Personal Information to another controller without hindrance from our part.

How you can exercise your right?:

If you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, you may contact us at neonphaliron@cytanet.com.cy or info@neonphaliron.com or:
135 Gladstonos Steet,
Limassol,
Cyprus
Telephone number: 25-365768
Fax number: 25-341742
We only accept requests for the exercise of your rights that are in a written form (even if it is in an electronic form) and we also request proof of your identity.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

H. Security

Reasonable organisational, technical and administrative measures are in place to protect your Personal Information from unauthorised access, disclosure, alteration or destruction, while the Personal Information is stored in our archives and/or servers. Among the things used to ensure the protection of your data are the following:
a. firewalls
b. use of access passwords in relation to computers;
c. different access passwords for our office which are available only to the administration;
d. use of safe box in relation to sensitive Personal Information;
e. the minimisation of people who have access to the staff’s personal data, and the payment data for clients and associates;
f. prohibition of access to places where Personal Information is stored and use of signs to clearly indicating the prohibition to unauthorized access;
g. use of shredders in relation to Personal Information that is being disposed;
h. CCTV in relation to entrances and areas of hazard. CCTV cameras that look at the area of the tables of the restaurant are turned off during the working hours of the restaurant. Attention has been made so that cameras in the kitchen focus on the hazardous areas;
i. use confidentiality clauses and other Regulation related clauses in order to legally protect your Personal Information.

We also carry out checks to ensure that our affiliates and service providers with whom we share Personal Information, have reasonable measures in place to provide an adequate level of data protection and to maintain the confidentiality and protection of your Personal Information.
We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. If you receive this type of request, you should not respond to it. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. We also ask that you please notify us at neonphaliron@cytanet.com.cy or info@neonphaliron.com.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us at neonphaliron@cytanet.com.cy or info@neonphaliron.com.

I. Special category of Personal Information

“Special Category of Personal information” amounts to such information the processing of which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

We do not generally collect Special Category information and we ask that, unless there is a regulatory (e.g. due diligence procedures requiring a copy of your passport and health information for social insurance purposes) or other serious need for you and/or another client and/or a third party, you do not to send us, and you do not disclose, any Special Category Personal Information to us.

J. Minors

We do not knowingly collect personal information from individuals who are under 18 years of age. As a parent or legal guardian, please do not allow your children to submit personal information without your permission. By providing us with the personal information of your children, you represent that authority has been given by both parents for the provision of this information.

K. Retention Period:

Personal Data is retained in accordance to the following retention policy, unless you communicate an objection to us. In the event that personal data fall under more than one category of Personal Data, the longer period shall apply in relation to the Personal data referred to below:
1. Personal Data in relation to Candidate personnel: 1 year following the receipt of the Personal Data;
2. Personal Data in relation to Personnel, Suppliers and/or Service Providers and/or their personnel, Clients, people who communicate with us and in relation to any other Personal Data not falling under any of the pre-determined categories: 3 years following the end of our contractual and/or service relationship and/or our last transaction and/or communication; 3. Personal Data in relation to Loyalty card holders: until the card holder decides to unsubscribe;
4. Personal Data in relation to People who complete our guest comment card: until the guest decides to unsubscribe;
5. CCTV records: for 2 weeks;
6. Personal Data of website and social media page visitors: 1 year following the last collection of the Personal Data;
7. Personal Data in relation to which a longer retention period is required or permitted by the applicable law. This depends on the applicable legislation. Personal data used for the maintenance of our accounting books (including payroll information) shall be kept for a period of 7 years in accordance to our legislative obligations;
8. Personal Data which are needed for the establishment, exercise or defence of potential legal claims shall be kept for a period of up to 10 years. In the event that a court cases starts within that period then the Personal Data shall be kept for the duration of the court case.

In the event that you communicate an objection to us we will only keep Personal Data in accordance to the above retention policy to the extent that the processing is necessary for exercising our right of freedom of expression and information and/or for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest and/or for the establishment, exercise or defence of legal claims

The above retention periods are in our opinion necessary to fulfil the purposes outlined in this Statement.

Your Personal Information shall be destroyed as early as practicable, from both our short-term system and our back-ups so that restoration and/or reconstruction of the data are no longer possible. This also involves the secure destruction of any printed paper through methods such as cross-shredding the paper documents.

L. Updates to this Privacy Statement

Where the need arises for the further protection of your Personal Information and for the purposes of your information, we may change and/or modify this Privacy Statement from time to time. Where we make material changes to this Statement we will post a link to the revised Statement on the homepage of the website of ANTONIOU BROTHERS at www.neonphaliron.com.

It is possible to recognise when this Statement has been last updated by looking at the date at the top of the Statement. Any changes become effective from the date on which they were posted on the website of ANTONIOU BROTHERS. Use of the website, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.

M. Contact Us

In the event that you have any questions about this Privacy Statement or you want to exercise any of your rights regarding your Personal Information please contact us at neonphaliron@cytanet.com.cy info@neonphaliron.com
135 Gladstonos Steet,
Limassol,
Cyprus
Telephone number: 25-365768
Fax number: 25-341742

Because email communication are not always secure, please do not include credit card or other sensitive information in your emails to us.