Last Updated: 24.05.2018
On May 25th 2018 a new General Data Protection Regulation (GDPR) comes into effect in the European Union, replacing the Data Protection Directive 95/46/EC. The new GDPR was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy.
Introduction
This Privacy Statement (hereinafter referred as “Privacy Statement”, or simply “Statement”) describes how your personal data (“Personal Data”) are managed and your privacy is respected by our company (hereinafter referred as “we”, “us”, or “Company”), as well as our employees, our subcontractors and our service providers.
The ultimate goal is to process Personal Data in accord with the applicable legislation, while taking into account and balancing the interests of our Company, our customers and other stakeholders of our Company.
Statement Scope
This Statement regards the following aspects of your Personal Data collection and processing by our Company:
- What Personal Data we collect.
- How Personal Data are used and for what purposes.
- When and why your Personal Data can be disclosed to third parties.
- How the accuracy, integrity and security of your Personal Data is maintained.
- Collection and process of Personal Data of minors or of legally incapable persons.
- How your Personal Data are retained and destroyed.
- What are your individual rights pertinent to your Personal Data.
- Contact details should you have any questions regarding the use of your Personal Data.
Collection of Personal Data
When you visit and use our site, products and services, we may collect data or ask you to provide certain data, including Personal Data, for the purpose of helping us manage our relationship with you. “Personal Data” is any data relating to an identified or identifiable individual, and may include name, address, email address, phone number, login (account number, password), marketing preferences social media account, ID numbers (or any other identification document), or payment card number. If we link other data with your Personal Data, we will treat that linked data as Personal Data. This data may include:
- Contact details, such as name, mailing address, email address and phone number.
- Shipping and billing data, including credit card and payment data.
- Your transaction history.
- Data you provide to us to receive technical assistance or during customer service interactions.
- Data about your computer or device, including browser type and settings, IP address and traffic data relating to your Internet connection.
Process of Personal Data
We collects and process your Personal Data in order to provide services to you, to comply with our legal obligations, and to improve our products and services, as follows:
- Process your financial transactions.
- Send you order / renewal confirmations.
- Register your rights, if any, to technical support or other benefits that may be made available to registered users.
- Respond to customer service requests, questions, etc.
- Administer your account.
- Send you requested product or service information.
- Keep you informed about special offers and offered services.
- Administer promotions and contest you enter and notify you of the results.
- Investigate, prevent or take action regarding illegal activities and/or violations of our Terms of Service.
- Meet our research and product/service development needs and to improve our site, services and offerings.
- Customize your interaction experience with us, including improved targeting our services and offerings to you.
Communication & Marketing Campaigns
We have the legitimate interest in promoting our offerings and to try to optimize the message delivery in terms of matching each message content with recipients’ interests.
Complying with GDPR we will send to you such promotional message only as long as with have obtained your consent.
If you do not want to continue receiving any promotional message from us, you can click on the unsubscribe function in the communication or e-mail, or by unselecting the consent option in your account page. Note that if there isn’t any consent option in your account page, then we considered that you haven’t granted any consent.
We are entitled to contact you whenever we change the Terms of Service or the Privacy Statement. Moreover, we are entitled to send to you messages related to services offered to you including, but not limited to, registration emails, account update emails, benefit notification emails, emails automatically triggered by your actions, billing related emails, etc. In general, you may not opt-out of those non-promotional communications. If you do not wish to receive them, then you may deactivate your account.
Cookies & Tracking Technologies
Cookies are small, unique text files that are placed on your browsing device (e.g. computer, mobile phone, etc.) whenever you visit a website, or whenever you open a HTML-formatted email.
We may use session cookies, which terminate when a user closes the browser, and/or persistent cookies, which remain on the browsing device until manually deleted. Most Web browsers can either alert you before cookies usage or refuse to accept cookies entirely. If you do not want cookies to be placed on your browsing device, you can set your browser either to reject cookies or to notify you whenever a cookie is to be placed on your browsing device. Rejecting cookies may affect the access and smooth usage of our site.
Both we and our partners may use cookies, web beacons, pixel tags, scripts or other similar technologies on our websites or emails so as to:
- Ensure the proper operation of our sites and the proper delivery of any legitimate electronic communication.
- Tailor information offered to you based on your browsing preferences, such as language and geographical region.
- Collect statistics regarding the usage of our site.
- Collect information of business and marketing nature.
We use different kinds of cookies:
- Essential cookies, which are necessary to provide you with services and features available through our site. Without these cookies most of the services you may need, such as shopping carts or e-billing, cannot be provided.
- Analytics or customization cookies, which collect data that is either used in aggregate form to help us understand how the site is being used or how effective our marketing campaigns are, or to help us customize the site for you.
If you do not wish to receive cookies you are advised to refuse them by not agreeing to the use of them upon entering the website. If you do so, we may be unable to offer you some of our functionalities, services or support. If you have previously visited our site, you may also have to delete any existing cookies from your browser.
We gather certain data automatically and store it in log files. This data may include IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this log data with other data we collect about you so as to enhance the offered services and to improve marketing, analytics, or site functionality.
Personal Data Disclosure
We do not sell, lease, rent or give away your Personal Data. We only disclose your Personal Data within our Company, with our partners, with service providers that process data on our behalf and with any Public Authorities required by applicable law, or entities required by Courts of Law (e.g., to comply with subpoenas, warrants, court orders, or legal processes). Processing is only undertaken for the purposes described in this Statement and the relevant product and service privacy notices.
If we disclose your Personal Data, we require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.
Personal Data Protection
Safeguards
The Personal Data that you provide in connection with the use of the site is protected in several ways.
- Access by you to your account profile is available through a password and unique customer ID selected by you. This password is encrypted. You should use a strong, alpha-numeric password which you should not divulge to anyone.
- Your Personal Data reside on secure servers that only selected Company’s personnel and subcontractors have access to via password.
- Your Personal Data are encrypted whenever it is transmitted to us.
- When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using Transport Layer Security (TLS) technology
Although we take into account the sensitivity of the Personal Data we collect, process and store, and the current state of technology we so as to protect your Personal Data, you need to bear in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure.
Links to Third-Party Sites
Our site may include links to other Web sites whose privacy policies may be different from ours. If you submit Personal Data to any of those sites, your information is governed by the privacy policies of these third-party sites. As a result, we advise you to carefully read the privacy policy of any web site you visit.
Social Media Widgets
Our site may include social media features, such as the Facebook “Like” button and widgets, such as the “Share this” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the above feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
Single Sign-On Option
You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.
Minors’ Privacy
We do not intend to collect or solicit Personal Information from persons lacking legal capacity (e.g. underage persons), as determined by your jurisdiction applicable laws, or knowingly allow such persons to register. If you are not legally capable, do not enter any information on this site, nor use any of our services. If you believe that an underage person, or a person lacking legal capacity in general, has entered Personal Information please contact [email protected] to have the data erased and terminate the associated account.
Data Retention
We will retain your information for as long as your account is active, your information is needed to provide our services to you or the information you’ve consented to receive by our side, or as required to fulfill our legal obligations. We reserve the right to extend the data retention period and use your information so as to comply with our legal obligations, resolve disputes, and enforce our agreements.
Privacy Rights
At any time you have the right to access and correct, or delete your Personal Information and privacy preferences. You can view and make immediate changes to most of your Personal Information via your account page. On the other hand, due to security reasons certain Personal Information can only be changed by contacting us.
For any request of yours we are abide by our legal obligation to take reasonable measures to ascertain your identity and the legitimacy of your request, and may ask you to disclose to us any information necessary for that purpose.
Any legitimate request will be responded within 1 (one) calendar month or 31 (thirty-one) calendar days (whichever is longer). In certain circumstances, we may need to extend our response period as permitted by applicable law.
Regarding such requests, we reserve the right to retain any data necessary to prevent fraud or future abuse or as required or permitted by law, including to comply with legal obligations we are subject to, as well as to establish, exercise and defend our legal claims.
Statement Revision
We reserve the right to revise this Privacy Statement. Upon any material change we will notify you by email (based on the email address that is associated with your account), or by web site notice before this change becomes effective. We encourage both visitors and authorized users to regularly review this page, so as to get the latest information regarding our privacy policy.
Contact Details
Regarding our use of your personal data and its privacy, should you wish to exercise any of your rights, to ask questions, or to file a complaint you can contact us as follows:
Via post:
Spirit Innovations SA
GR-17778 Tavros-Athens
GREECE
Attn: GDPR
Via email:
[email protected]