1. General information
- Applicable law for the protection of personal data is the General Regulation (EU) 2016/679 (hereinafter GDPR) of the European Parliament and of the Council (adopted on 27 April 2016 and implemented since 25 May 2018) and Law 4624/2019 "on the protection of individuals with regard to the processing of personal data", as in force, as well as the instructions of the Personal Data Protection Authority.
- Personal data is defined by the GDPR as any information by which a natural person can be directly or indirectly identified ("data subject"). Such data include, but are not limited to, name, surname, home address, e-mail address, tax identification number, equipment or terminal device identifiers, internet search history, etc. Information relating to legal persons and groups of persons or statistical information, from which it is not possible to refer to an identified or identifiable natural person, does not fall within this category and is excluded from the scope of the relevant legislation.
- The following information on the protection of user/customer personal data concerns the way in which our company processes his/her personal information when he/she contacts us or uses any of the services of our website and e-shop. This policy is fully compatible with the General Regulation on the protection of natural persons with regard to the processing of personal data (EU/2016/679) and the Greek legislation (Law 4624/2019).
- It is clarified that our company may modify this policy at any time and without notice. To this end, it is considered necessary to study this policy before navigating the user / customer and any registration of his personal data.
- By navigating and using the services of the website and the online store, the user / customer accepts the content of this policy.
2. Controller
The company with the name "Avgeros G. Christos" located in the Municipality of Piraeus at 68 Napoleon Labelet Street – 18541, as legally represented in its current or current legal form, as controller, attaches particular importance to the protection of the personal data of users/customers. For any question, question or request, the user / customer can contact our company by the following means: Tel: 210 220 9684, e-mail: hi@dot360.io.
3. Purpose of data collection
- When visiting our website, the user / customer is not obliged to provide us with personal information, unless he wishes to:
• Communicate with us
• Express interest in purchasing products
• Commit to transactions and payments
• Create an account in our online store
• Subscribe to the newsletter service - We also collect data to analyse the usability, quality and marketing of our services in order to improve our products and individual benefits.
- We collect data for purposes related to the detection of online fraud and the security of electronic communications.
- Some of the collected data is necessary for the purpose of pricing the products sold in accordance with the applicable tax legislation.
- As a business we process only those necessary personal data that are necessary for the fulfillment of the purposes of our transactions. Our company guarantees that the personal data it processes remain highly confidential and cannot be used for any other purpose than the one for which they were provided.
4. What kind of data we collect and on what legal basis
- In the "shopping cart" section we collect the following: (a) in the "personal information" form: first name, last name, e-mail address, telephone number, (b) in the "charging address" form: name, address, city, zip code, country, region. The above data are necessary for the preparation and processing of the sales contract in accordance with Article 6 (1) (b) GDPR. Also, the above information is necessary for the issuance of a retail receipt in accordance with Article 6 (1) (c) GDPR. In addition to the above information, the TIN and Tax Office fields must be filled in to issue an invoice.
- In the section / contact form we collect the following: first name and / or last name, phone number and e-mail address. The contact information is collected in order to be able to respond either to your requests, in accordance with Article 6 (1) (c) GDPR or to provide you with information on our products or transactions, in accordance with Article 6 (1) (b) GDPR.
- In the pop-up newsletter form as well as in the corresponding footer form we collect the e-mail address (e-mail). The collection of the user's / customer's e-mail is only done if he/she enters it in the relevant field, thus giving us his/her consent, in accordance with Article 6 paragraph 1 (a) GDPR. It is clarified that at any time the user / customer can unsubscribe at no cost and no longer receive such messages, informing our company by any appropriate means of communication or by clicking on the option “unsubscribe” in the promoted message.
- In the "Create an account" form we collect the following: first name, last name, e-mail address, phone number. The legal basis for the processing is firstly the consent of the user / customer to register and create an account, in accordance with Article 6 (1) (a) GDPR, as well as the legitimate interest of our company, in accordance with Article 6 (1) (f) GDPR, for the security of the account and the identification of the user, where and when this is required.
- We may also automatically receive certain information contained in log files, such as IP address, geographical location data, date and time of visit to the website, etc. for which we consider that we have a legitimate interest, in accordance with Article 6 (1) (f) GDPR, to protect the security of networks, information and services from accidental events or illegal or malicious actions (e.g. online fraud) related to the availability, authenticity, integrity and confidentiality of data and at the same time to provide on our part, in accordance with Article 6 (1) (c) GDPR, a more secure environment for the processing of the personal data of the user / customer.
- We also use cookies either to measure the statistics of our online store or to improve the navigation and user experience or to further market our products. In detail about Cookies, by type, type, duration, purpose and provider, the user / customer can be informed by the relevant policy or cookie banner. The placing of a tracker on a terminal device requires, in principle, the consent of the user, regardless of whether personal data are ultimately processed through it. The trackers exempted from the obligation to obtain consent are those considered technically necessary to make the connection to the website or to provide the internet service requested by the user himself. According to the Hellenic Data Protection Authority, consent is not required (a) for the identification and/or retention of content entered by the subscriber or user during a session on a website for the duration of the specific connection, such as the "shopping basket", (b) for the connection of the subscriber or user to services that require authentication, (c) for the security of the user, (d) for the implementation of the load balancing technique on a connection to an internet website, (e) for the maintenance of the user's choices regarding the presentation of the website, e.g. language selection, storage of search history. By contrast, trackers installed for the purpose of online advertising or third-party trackers, such as Google Analytics for the purpose of web analytics, are allowed only if the user's prior consent has been obtained after appropriate information.
- It is clarified that our company does not have in any way access to credit or debit card data of the user / customer. Online transactions take place in a secure contracted bank environment.
5. Recipients of the data – Transfers
In order for us to be able to provide our services, we inform the user / customer that access to certain elements of the site may have, under strict conditions, such as e.g. encryption, contractual confidentiality clauses, etc., contracted partners with us:
- Commercial or logistical companies and software/cloud computing services
- Financial providers
- Advertising service providers
- Companies or accounting support offices
We require all the above recipients to implement increased organisational and technical measures that ensure the optimal level of security.
Our company does not transfer the personal data of the user / customer to third countries, ie outside the EU. For Cookies, see the relevant policy.
6. Time of data retention
In case the user/customer entered into a contract with our company, his/her personal data will be kept for the duration of this contract. After the completion of the contract, i.e. after the full payment of the price of the products, our company keeps his personal data provided for the purchase of the products for at least two years, with the exception of any certain information that should be kept for tax reasons for longer than the above period.
If, until the expiry of the two years, legal actions are ongoing with our company or any other affiliated company, concerning the user/customer directly or indirectly, or any administrative control is pending, this time of retention of his personal data will be extended until the issuance of an irrevocable court decision or an administrative act.
If the user/customer has subscribed to the Newsletter service or has created an account, the data he/she has provided for receiving the newsletters or creating an account respectively, are kept for the duration of his/her registration. By unsubscribing from the above service, which can be done in any appropriate way (e.g. by sending an e-mail), the data provided to us are immediately deleted.
To configure Cookies, the user/customer can consult the relevant policy or cookie banner.
In the event that a shorter or longer retention period is provided for by law, the above data retention period will be reduced or increased accordingly. For this reason, the company undertakes to periodically review the relevant legislation and revise this policy accordingly.
7. The rights of the user/customer
Under the General Data Protection Regulation, the user/customer has the following rights:
Right of access: To know if and to what extent his personal data are processed in any form, and in particular the purposes of the processing, the categories of data we process, the recipients of his data, the period for which we keep his data as well as the existence of automated decision-making (Article 15 GDPR).
Right to rectification: Request the correction and/or completion of his/her data so that it is complete and accurate (Article 16 GDPR).
Right of restriction: Request the restriction of the processing of his data under the conditions of Article 18 GDPR. It is noted, however, that our company has in any case the right to refuse its request to restrict the processing of its personal data if the processing or keeping of the data is necessary for the establishment, exercise or support of our legal rights or the fulfillment of our obligations.
Right to object: Object to any further processing of his or her personal data that we hold (Article 21 GDPR), unless we demonstrate that there are compelling and legitimate grounds for processing his or her data or their retention is necessary for the exercise of our legal claims.
Right to erasure (‘right to be forgotten’): To request the deletion of his personal data from the records we keep under the conditions of Article 17 GDPR. Please note that our company has in any case the right to refuse its request for the deletion of its personal data, if the processing or keeping of the data is necessary for the establishment, exercise or support of our legal rights or the fulfillment of our obligations.
Right to portability: To request the transfer of his/her data from our company to any other controller (Article 20 GDPR). It is noted that the right to portability does not imply the deletion of his personal data.
Right of termination: To submit a complaint to the Personal Data Protection Authority (www.dpa.gr), if he considers that his rights are violated in any way.
In order to exercise his/her rights, the user/customer may address himself/herself in writing or by electronic means to the "controller". The company, fully respecting his rights, will make every effort to respond to his request within thirty (30) days of submission. That period may be extended by sixty (60) additional days, if necessary taking into account the complexity of the request and the number of requests. Our company, in any case, will inform the user / customer of any extension of the deadline for reply within thirty (30) days from the submission of his request. The exercise of his rights does not require any costs. If, however, his requests are manifestly unfounded, excessive or repetitive, we have the right either to charge him a reasonable fee, informing him accordingly, or to refuse to respond to his request(s).
8. Data security
Our company applies strict security procedures in order to protect the personal information of the user / customer from damage, destruction or disclosure and to avoid unauthorized access to them.
When data is to be transmitted to our recipients, we require that similar measures be taken to fully protect the user/customer information.
9. Links
The website contains links to third-party pages (Links). The provision of links does not imply the approval of their content. The company bears no responsibility regarding the availability or content of these websites or any liability for any damage as a result of the use of their content. These links mainly concern the navigation of our corporate pages on social media (Facebook, Instagram, etc.). The links are provided solely for the convenience of the user. In any case, the user browses these websites at his own risk. Before entering any personal data, it is always recommended to study the terms of use and privacy policy of each individual platform.
