What is personal data?
Personal data is any information that makes it possible to identify a living individual, directly or indirectly (including, but not limited to, your name, date of birth, address, phone number, email address as well as your IP address).
Who is the Controller?
If you have questions on how data is processed in our company, please contact firstname.lastname@example.org
Which personal data we process and for what purpose
Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of our website, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that, if you decide not to make such data available to us, you may be unable to complete your user registration or to enjoy those services or functionalities. Depending on how you interact with us, we will process your personal data for the following purposes:
We collect and process the following data when you visit our website:
- The name of your internet service provider
- Information about the website from which you reach our site
- The web browser and operating system you are using
- The IP address allocated by your internet service provider
- The files requested, data volume transferred, and downloads/file export
We inform you that, when accessing our website, we might treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our website and thus be capable of introducing improvements in it.
We collect and process the following data when you submit a contact enquiry:
Name, Email, Telephone (optional)
The principle of data economy and data reduction is taken into account here, in that you only need to provide the data that we need in order to make contact with you. This comprises your email address, first name, surname, subject, and the message field itself. In addition, your IP address is processed for reasons of technical necessity and legal safeguarding.
If you contact us by email, we will process the personal data you provide in the email purely for the purpose of processing your enquiry.
You can subscribe to a free-of-charge newsletter on our website. When doing so, we collect and process the following data:
The email address provided during newsletter registration will be used for sending the personalized newsletter, promotional offers etc. in order to improve your customer experience. To that end, we guarantee to not bombard your inbox with irrelevant emails and to offer as much of a customized content as possible.
The principle of data economy and data reduction is taken into account here, as only the email address is identified as a mandatory field. When you subscribe to the newsletter, your IP address will also be processed for reasons of technical necessity and legal safeguarding.
You may of course end your subscription at any time without stating any reason for doing so, using the unsubscribe option provided in the newsletter, or sending an email to email@example.com, thereby revoking your consent.
We will respond to this request within 5 working days.
To manage your registration as user of our website, we collect and process the following data:
Name, Surname, Display Name, Email Address
For the performance and execution of the purchase or services contract that you executed with us on our e-shop platform, either as a guest or as a registered user, we collect and process the following data:
Name, Surname, Address, Email Address, Telephone
This purpose includes processing your data, mainly: a) To contact you for updates or informative notices related to the contracted functionalities, products or services, including potential quality surveys and to be able to establish the degree of customer satisfaction with the provided service; b) To manage payment of the products that you purchase, regardless of the payment procedure used; c) To manage potential returns after you have purchased and manage requests of availability information for articles, reservations of products through our website, depending on the availability of such options from time to time ; d) For invoicing purposes.
For marketing purposes
This purpose includes the processing of your data, mainly, for: a) If and when you subscribe to our Newsletter, we will process your personal data to manage your subscription, including to send customized information on our products or services through various means (such as email or SMS). Accordingly, please take into account that this data processing implies analysis of your user or customer profile to establish your preferences and therefore which products and services are most fit to your style when sending you information. For example, based on your purchases and browsing history (i.e., depending on the articles that you clicked), we will make you suggestions on products that we believe may interest you and, if you are a registered user, we will provide you with the “recover cart ” functionality; b) To perform promotional actions (for example, for the organization of competitions or to send the list of items stored to the email you designate). On participating in any promotional action, you authorize us to process the personal data that you have shared with us depending on the promotional action and disclose them through different media such as social networks. In each promotional action in which you participate you will have available the terms and conditions where we will be providing more detailed information about the processing of your personal data ; c) To disseminate through our channels in the social networks photographs or pictures that you shared publicly, provided that you expressly give us your consent for the purpose.
Legal grounds for data processing
We use your data for initiating business; fulfilling contractual and legal obligations; implementing the contractual relationship; offering products and services; and strengthening the customer relationship, which may also include analysis for the purpose of marketing or direct advertising.
The legal terms on which we are permitted to process your personal data also depend on the purpose for which we process them, as explained below:
To manage your user registration we process your data because this is necessary on the terms regulating the use of the website. In other words, for you to be able to register as a user, we need to process your personal data, since we would otherwise be unable to manage your registration.
For the performance and making of the purchase or services contract we process your data because their processing is necessary for us to make the purchase or services contract with you. Certain processing of data related to the purchase process is activated only because you request or authorize it, as is the case of the storage of payment (card) data for future purchases or to provide you with the Coming Soon / Back Soon functionalities. In these cases, our processing of your data is supported by your own consent. We have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of these data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties.
In order to provide customer support we have legitimate interest in answering the requests or queries raised by you through the existing contact form. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised. When you get in touch with us, in particular, for the management of incidents related to your order or the product/service acquired through our e-shop platform, the processing of your data is necessary to perform the purchase contract. When your request is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.
For marketing purposes we are legally permitted to process your data due to the consent that you give us, for example when you accept receiving customized information through multiple channels, subscribing to our newsletter, or when accepting the legal terms and conditions to participate in a promotional action or to publish your pictures on our social networks’ channels. In order to show you customized information. we consider that we have a legitimate interest to conduct a profiling with the information that we have about you (such as your browsing, preferences or purchase history) and the personal data that you have provided us, such as the age range or language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.
Your rights as a data subject
We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Your rights under data protection law are set out below:
- The right to access
- The right to erasure
- The right to rectification
- The right to data portability
- The right to restriction of processing
- The right to object to processing
More in detail:
The right to access
You shall have the right to be informed and verify the legitimacy of the processing. So, you shall have the right to access the data collected and get additional information concerning its processing. We remind you that when you are a registered user you may also consult this information in the relevant section of your online account.
The right to erasure
You shall have the right to request the deletion of your personal data while we process them with your consent or in order to protect our legitimate interests. In all other cases (e.g. where there is a contract, an obligation required by law to process personal data, public interest), this right is subject to specific restrictions or ceases to exist as the case may be.
The right to rectification
You have the right to have any incorrect personal data corrected, updated, completed if it’s incomplete or amended, by contacting firstname.lastname@example.org. Please bear in mind that if you are a registered user, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the website, to our company or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms.
The right to data portability
You shall have the right to receive your personal data free of charge in a format that allows you to access, use, and edit them with commonly used editing methods. You shall also have the right to ask us, if technically feasible, to transfer the data directly to another controller. This right applies for the data you have provided to us and its processing is carried out by automated means based on your consent or the enforcement of a relevant contract.
The right to restriction of processing
You shall have the right to obtain from the controller restriction of processing where one of the following applies: (a) when you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data; (b) when you oppose the erasure of the personal data and request the restriction of their use instead; (c) when your personal data are no longer required for the purposes of processing, but they are required for the establishment, exercise or defense of legal claims; (d) when you object to processing pending the verification whether the legitimate grounds concerning the controller override those of you.
The right to object to processing:
You shall have the right to object at any time to the processing of your personal data where, as described above, it is necessary for the purposes of legitimate interests we seek as controllers, as well as for processing for direct marketing and consumer profiling.
In the context of rights to object, please note the following:
We will then no longer process your personal data unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if processing is necessary for the establishment, exercise or defense of legal claims.
When we process your personal data for the purpose of direct advertising, you have the right to object to this data processing at any time without stating any reasons. The same also applies for any profiling insofar as it is associated with direct advertising.
If you object to processing for the purposes of direct advertising, we will no longer process your personal data for these purposes. Submitting an objection is free of charge and can be done via submission to email@example.com and we will process your request within 14 working days.
In order to assert these rights, please contact firstname.lastname@example.org The same applies if you have questions on how data is processed in our company.
You are also entitled to lodge complaints with a supervisory authority for data protection.
The right to revoke consent
When processing is based on consent, you have the right to withdraw your consent freely. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
In order to assert these rights, please contact email@example.com
The same applies if you have questions on how data is processed in our company.
You are also entitled to lodge complaints with a supervisory authority for data protection.
Disclosure to third parties / data recipients
We will only disclose your data to third parties in the framework of legal provisions or in the event of corresponding consent. Otherwise we will not disclose your data to third parties unless we are required to do so due to compulsory legal stipulations (disclosure to external bodies such as supervisory authorities or law enforcement authorities).
In our company, we ensure that only individuals who require your data to fulfill contractual and legal obligations receive access to that data.
In many cases, service providers support our departments in performing their tasks. In these cases our company remains the data controller instructing the purpose and ends to which the service providers can process the data. The necessary data protection contracts have been concluded with all service providers, in order to ensure that data processing is conducted within the legal framework and that every natural person can freely exercise the rights he/she is entitled to.
How long will we keep your data
The time for which we will keep your data will depend on the purposes for which we process them, as explained below:
To manage your user registration we will process your data for the time during which you remain a registered user (meaning, until you decide to unsubscribe).
For the performance and execution of the purchase or services contract we will process your data for the time necessary to manage the purchase of the products or services that you buy, including potential returns, complaints or claims related to the purchase of the product or service in question. Sometimes, we will only process the data until the time when you decide, as is the case of payment (card) data that you requested us to store for future purchases.
For Customer Support we will process your data for the time necessary to meet your request or application.
For marketing purposes we will process your data until you unsubscribe or cancel your subscription to our newsletter. You can do this at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.
If you participate in promotional actions, we will keep the data during a six (6) months period from the end of the action.
Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.
Secure processing of your data
We implement appropriate technical and organizational measures for the best possible protection of the data we store against accidental or deliberate manipulation, loss, destruction, or unauthorized access. Data exchange from and to our web server is encrypted in every case.
In any event, the way the internet functions and the fact that it is accessible to anyone, cannot assure that unauthorized third parties will never be able to violate the applicable technical and organizational measures by gaining access to personal data and possibly using these for unauthorized and/or unlawful purposes.
The term “profiling” implies an automated form of processing carried out on personal data in order to evaluate certain personal aspects of a natural person, in particular to analyze or predict aspects concerning that natural person’s behavior, personal preferences, location or movements.
We would like to inform you that profiling may occur for marketing purposes on the basis of your consent to receiving our newsletters concerning our services and offers, in order for us to create personalized content adapted to your preferences and interests.
Links to other providers
Our website might also – clearly and identifiably – include links to websites operated by other companies. Where links to other providers’ websites are provided, we have no influence over their content. For this reason, no guarantee can be provided and no liability can be accepted for this content. The respective provider or operator of the relevant pages is responsible for the content of these pages.
At the time that the link is placed, the linked pages are checked for possible legal violations and identifiable infringements of the law. No illegal content was identifiable at the time that the link was placed. However, constant monitoring of the content of the linked pages is unreasonable without specific indication of an infringement of the law. In the event of infringements of the law becoming known, links of this type will be removed without delay.