Α. BASIC DEFINITIONS
This Chapter sets out the key definitions and abbreviations used in this Policy for the purpose of its proper interpretation and implementation. The terms defined herein, together with their corresponding abbreviations, are capitalized throughout the following Chapters.
1. HDPA: means the Hellenic Data Protection Authority (1–3 Kifisias Avenue, 115 23 Athens, Greece, Tel.: +30 210 647 5600, website:https://www.dpa.gr.).
2. Recipient: means any natural or legal person, as well as any public authority, agency, or other body, to whom the personal data collected under and for the purposes of this Policy are disclosed.
3. GDPR: means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
4. Personal Data: means any information relating to an identified or identifiable natural person. An identifiable natural person is one whose identity can be established, directly or indirectly, in particular by reference to identifiers such as a name, identification number, location data, or an online identifier (e.g., an IP address).
5. Processor: means a natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Controller.
6. Processing: means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction.
7. Company: means the public limited company (société anonyme) under the corporate name “DKG DEVELOPMENT S.A.”, with its registered office at 602A Vouliagmenis Avenue, Imeras Office Center, Argyroupoli, 16452, Greece, Tax Identification Number (TIN/VAT No.) 801259253, and General Commercial Registry (G.E.MI.) Registration No. 152902909000.
8. EEA: means the European Economic Area, comprising the Member States of the European Union, as well as Iceland, Norway, and Liechtenstein.
9. Subsidiary Company: means any company over which DKG DEVELOPMENT S.A. exercises, directly or indirectly, a controlling influence (e.g., through ownership of more than 50% of the share capital or control over its management), as provided under Greek Law 4308/2014 on the Greek Accounting Standards.
10. Website: means the online platform consisting of all web pages, applications, and content accessible through the domain name www.wyndhamresidencespiraeusmarinazeas.com, which is managed by the DKG Development Group as an Information Society service provider.
11. Law: means Greek Law 4624/2019, as amended and in force from time to time, which was enacted in the context of the GDPR.
12. DKG Development Group: means the group of companies listed in Annex A (parent company, subsidiaries, and affiliated companies). For the avoidance of doubt, each company within the Group constitutes a separate legal entity and acts as an independent Controller with respect to the Processing of your Personal Data under and for the purposes of this Policy.
13. Personal Data Breach: means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data collected under and for the purposes of this Policy.
14. Policy: means this Cookie Policy, including its Annexes, governing the use of cookies on the DKG Development Group’s Website.
15. Affiliated Company: means any company that is under common management or control with DKG DEVELOPMENT S.A., or over which DKG DEVELOPMENT S.A. exercises significant influence, in accordance with the provisions of Greek Law 4308/2014 on the Greek Accounting Standards.
16. Controller: means any natural or legal person that determines the purposes and means of the Processing of Personal Data. For the purposes of this Policy, the Controller is the relevant company within the DKG Development Group that Processes the Personal Data of its employees, contractors, and business partners for the purposes set out in this Policy, as identified in Annex A.
17. Data Subject: means any identified or identifiable natural person whose Personal Data is subject to Processing. For the purposes of this Policy, Data Subjects include current and former employees, contractors, directors, and business partners of the DKG Development Group.
Β. INTRODUCTION
1. Use of Cookies: The DKG Development Group uses cookies on the Website to enhance visitors’ browsing experience, analyze Website traffic, and provide personalized content. This Policy is fully compliant with the GDPR, the Law, and the guidelines and recommendations issued by the HDPA, including its recommendations of 25 February 2025 regarding the compliance of Controllers with the special legal framework governing electronic communications.
2. Corporate Structure and Responsibility: This Policy applies uniformly to all companies within the DKG Development Group (see Annex A). For the avoidance of doubt, each company within the DKG Development Group constitutes a separate legal entity and acts as an independent Controller with respect to the Personal Data it Processes under and for the purposes of this Policy.
3. Legal Compliance Framework: This Policy is intended to ensure the full compliance of the DKG Development Group with the applicable legal and regulatory framework, in particular the GDPR, the Law, and any decisions, guidelines, recommendations, or other regulatory acts issued from time to time by the HDPA.
4. Data Subjects: The provisions of this Policy apply to every natural person who interacts with any company within the DKG Development Group in the capacity of a visitor to the Website.
5. Status of the Annexes: The Annexes attached to this Policy form an integral and inseparable part thereof and shall have the same binding force and effect as the main body of the Policy.
6. Amendments to the Policy: The DKG Development Group reserves the right to amend or update this Policy unilaterally at any time in order to reflect changes in applicable legislation, improvements to technical security measures, or changes to its corporate structure. The version of the Policy in force from time to time will be made available through the Website.
7. Relationship with Applicable Law: The provisions of this Policy are intended to supplement, and not replace or limit, the obligations arising under the applicable legal and regulatory framework governing the protection of Personal Data. In the event of any inconsistency or conflict between the provisions of this Policy and the applicable legislation, the provisions of the applicable laws and regulatory acts shall prevail.
B. WHAT ARE COOKIES?
Cookies (also referred to as trackers) are small text files that are stored on your device (such as a computer, tablet, or mobile phone) when you visit a website. Cookies enable the Website to remember your preferences and certain information about your visit for a period of time, thereby improving your browsing experience and facilitating the functionality of the Website.
Γ. CONTROLLERS
- The Company and each of its Subsidiary Companies and Affiliated Companies act, for the purposes of this Policy and with respect to the Processing of Personal Data carried out under and for the purposes of this Policy, as separate and independent Controllers within the meaning of Article 4(7) of the GDPR.
- Each Controller independently determines the purposes and means of the Processing and bears separate, independent, and exclusive responsibility for ensuring the lawfulness, transparency, and overall compliance of the Processing of Personal Data carried out under and for the purposes of this Policy.
- It is expressly acknowledged and clarified that the above-mentioned companies are not Joint Controllers within the meaning of Article 26 of the GDPR, as they do not jointly determine the purposes and means of the relevant Processing activities.
- In the event of an audit, investigation, complaint, or the imposition of administrative measures or sanctions by the competent supervisory authority, including the HDPA, each Controller shall bear sole and exclusive responsibility for any acts or omissions relating to the Processing carried out under this Policy, as well as for any violations of the applicable data protection legislation arising from such Processing. No company within the DKG Development Group shall be liable for the Processing activities carried out by another company within the DKG Development Group, unless otherwise expressly provided in a specific written agreement.
- The full details of each Controller, including its corporate name, registered office/address, Tax Identification Number (TIN/VAT No.), General Commercial Registry (G.E.MI.) registration number, telephone number, and email address, are set out in Annex A.
4. INFORMATION AND MANAGEMENT OF COOKIES – CONSENT
4.1. Consent Procedure
Upon your first visit to the Website, a Cookie Banner is displayed, providing you with the following options:
- “Accept All”: Accept all categories of cookies.
- “Reject All”: Reject all cookies, except those that are Strictly Necessary Cookies required for the operation of the Website.
- “Customize”: Access the Cookie Preference Center, where you can selectively enable or disable individual categories of cookies according to your preferences.
4.2. Cookie Preference Center
We use cookies to ensure the proper functioning of the Website, enhance your browsing experience, and provide personalized content. Below, you can find detailed information about each category of cookies and customize your preferences accordingly.
Strictly Necessary Cookies are technically essential for the basic operation of the Website and remain enabled without requiring your consent. The use of all other categories of cookies (including Analytics Cookies, Advertising Cookies, and any other non-essential cookies) depends entirely on your preferences and will only be activated if you provide your consent.
Please note that disabling certain categories of cookies may affect the functionality and performance of the Website.
4.3. Detailed Table of Cookie Categories
Following the above information regarding the customization of your cookie preferences, a detailed table is provided setting out each category of cookies used on the Website, together with the purpose and function of each category, the applicable retention period, the recipients of the data collected through such cookies, their activation status, and the available consent management options.
| Κατηγορίες Cookies | Σκοπός και Λειτουργία | Πάροχος / Ταυτότητα Υπευθύνου | Διάρκεια Λειτουργίας | Αποδέκτες Δεδομένων | Κατάσταση (Default) | Συγκατάθεση |
| Necessary | They are required for the basic functionality of the Website, including secure access and the management of your cookie consent preferences. These cookies do not store Personal Data. | Each company within the DKG Development Group | Session to 1 year | Hosting service providers | Always active | NO |
| Functional | These cookies enable features such as sharing content on social media, collecting user feedback, and supporting other third-party functionalities. | Google Ireland Ltd (Google Analytics) | From 1 minute to 2 years | Google, Google advertising networks | Inactive | YES |
| Analytics | These cookies collect information about Website traffic (such as the number of visitors, traffic sources, and related metrics) to help us understand how users interact with the Website. | Meta Platforms Inc. (Facebook Pixel) | 90 Days | Meta, third-party advertising platforms | Inactive | YES |
| Performance | These cookies are used to analyze the performance of the Website, helping us evaluate its effectiveness and improve the user experience. | Website owner and affiliated analytics service providers | From the duration of the session up to 1 year | Technical consultants, cloud service providers, and hosting service providers | Inactive | YES |
| Advertisement | These cookies are used to deliver personalized advertisements based on your browsing activity and to measure the effectiveness of advertising campaigns. | Google Ireland Ltd (Google Ads) & Meta Platforms Inc. (Facebook Pixel). | From 90 days up to 2 years, depending on the cookie. | Google, Meta, third-party advertising platforms | Inactive | YES |
4.4. Consent Management Mechanism
Your cookie consent preferences are managed through a dedicated consent management mechanism, which enables you to activate or deactivate individual categories of cookies at any time. You may withdraw your consent or modify your cookie preferences at any time by accessing the “Cookie Settings” link available in the footer of the Website.
5. PROCESSING OF IP ADDRESSES AND TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA
5.1. IP Addresses: Certain cookies collect your IP address for security and statistical purposes. The DKG Development Group implements IP anonymization measures wherever this is technically feasible.
5.2. Transfers Outside the EEA
5.1. In the case of third-party cookies, such as those provided by Google and Meta, Personal Data may be transferred to servers located outside the EEA (for example, in the United States), subject to the safeguards provided under the EU–U.S. Data Privacy Framework.
The identity of the relevant Controller for each individual cookie is specified in the table above, while the recipients of the Personal Data include the respective advertising and analytics service providers engaged by the above-mentioned third-party providers.
5.3. Data Protection Safeguards: Any transfer of Personal Data outside the EEA is carried out only where appropriate safeguards are in place, such as the European Commission’s Standard Contractual Clauses (SCCs) or the EU–U.S. Data Privacy Framework, thereby ensuring that your Personal Data benefits from a level of protection essentially equivalent to that guaranteed within the European Union.
6. COMPLIANCE WITH THE HDPA GUIDELINES
The DKG Development Group does not regard silence, continued browsing of the Website, or closing the Cookie Banner as constituting valid consent.
Default Setting (“OFF”): All non-essential cookies are disabled by default.
Right to Withdraw Consent: You may change your cookie preferences or withdraw your consent at any time through the Website’s cookie management mechanism, as easily as you provided it.
7. CONTACT INFORMATION
If you have any questions or require further information regarding this Policy, you may contact the Privacy Contact designated by the relevant company within the DKG Development Group.
The full contact details of the designated Privacy Contact for each company, including their name, telephone number, and email address, are set out in Annex A to this Policy.
| DATE | VERSION |
| 07/07 / 2026 | 1.0 |
ANNEXES
ANNEX A
CONTROLLER DETAILS – PURPOSE OF PROCESSING – CONTACT DETAILS OF AUTHORIZED PRIVACY CONTACTS
| CONTROLLER | LEGAL REPRESENTATIVE | REGISTERED OFFICE / ADDRESS – TELEPHONE – E-MAIL – TAX IDENTIFICATION NUMBER (TIN/VAT No.) – G.E.MI. REGISTRATION NUMBER | PURPOSES OF PROCESSING | AUTHORIZED PRIVACY CONTACT (Name, Telephone, E-mail) |
| DKG DEVELOPMENT ΑΝΩΝΥΜΗ ΕΤΑΙΡΕΙΑ | 602A Vouliagmenis Avenue, Imeras Office Center, Argyroupoli, 16452, Greece TIN/VAT No.: 801259253 G.E.MI. Registration No.: 152902909000 | As set out in Section D above. | Emmanuel Gkialas e.gialas@lavish-hospitality.com +30 210 9227299 |
DECLARATION OF ACCEPTANCE AND COMMITMENT
The undersigned companies of the DKG Development Group, each duly represented by its authorized legal representative, hereby acknowledge that they have read, understood, and unconditionally accepted the contents of this Policy, and agree to be bound by its provisions.
Each company assumes responsibility for implementing the measures set out herein within its own organization, acting in its capacity as an independent Controller.