PRIVACY POLICY

1) We respect your privacy and choices.

2) We ensure that personal privacy and security are incorporated into everything we do.

3) We do not send you ads unless you have asked us to. You can change your mind at any time.

4) We never offer or sell your data.

5) We are committed to keeping your data safe and secure. This includes our cooperation only with trusted partners.

6) We are committed to full transparency in the way we use your data.

7) We do not use your data in ways we have not already disclosed to you.

8) We respect your rights and always try to satisfy your requests to the best of our ability, in compliance with our legal and operational obligations.

Part C

DATA PROTECTION POLICY 

The present Privacy Policy has been established by us in order to inform you about the Company's policy regarding  your personal data, about the processing purposes, the category of recipients, the procedures you can follow in order to enforce your legal rights and to provide your consent for processing them .

Therefore, the control and protection of your personal data is governed by the terms of this announcement and the relevant provisions of Greek, European and  International law regarding the protection of personal data of the individual, as well as the Decisions of the Hellenic Data Protection Authority  or other competent authorities . Any future change in the aforementioned regulatory framework will be object of this announcement. It is possible that we will occasionally modify the DPP , either in whole or in part, in our sole discretion. Any amendment to this will be effective immediately as soon as the amended DPP is posted on our website. In any case, if you continue to trade with us,  use our Website and its services and the services of our Online Store , after modifications have been made in accordance with the above, you will be deemed to accept these modifications unreservedly .

The security and protection of your personal data is a priority for us. That is why we undertake to handle your personal data responsibly.

This website contains also links to other websites that are under the responsibility of third parties (individuals or corporations). In no case is our company responsible for the terms of protection and management of the personal data that these websites follow.

1. DEFINITION OF PERSONAL DATA    

Personal data’ is any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as but not limited to, the name, the address, the mobile telephone number, the email address (e mail ) , residential address, and one time user data, such as, the password and the IP address , or the MAC address , as well as cookies .

2. PERSONAL DATA WE COLLECT

It is likely to be prompted to register  your information (for instance name, surname, age, occupation, address, shipping address, phone number, credit card details etc.) , in order: to browse our Online Store, to trade with us, register as a member at  www.surfmarket.gr and sign up for an Account in order to buy products, to register in the Newsletter Service , to participate in competitions or giveaways  or surveys through social media , to ensure a communication channel with you so that we can inform you about both your orders and our new products, to comply with our legal obligations such as invoicing etc. , to apply for career opportunities , to exercise your rights under the law . Particularly:

ØFor each purchase of products from our Online Store, through our website, or store pickup,  the information you must provide us is: your name, phone number, address (street, city, postal code), billing address and order shipping address, document type (receipt, invoice), transaction information such as product purchases and store location, payments and related information or purchase history.  At the same time, we optionally request some information such as mobile phone number (in case we need to contact you directly), e-mail, fax number and your profession.      

ØIn case we will issue an invoice to a natural person, we need : the name of the entrepreneur , VAT number, DOY(Tax Office) , address of his / her registered office, occupation .      

ØAdditionally, for subscribing to our company’s Newsletter services in order to send you information regarding company news , promotions, sales etc. about our company, products / services, etc., we ask you to provide us with: Your email address (email), name and surname.      

ØTo ensure your participation in contests, giveaways, promotional offers or surveys ,we may use data / profile information that are publicly available  in social media and they may be used (when the connection is established using social media accounts or you provide the aforementioned personal data), or other information concerning you and you have provided to us (e.g. through the page "My account").       

Ø Data collected through cookies or similar technologies  used during your use of our website / our application or websites / third party applications.      

ØIn order to contact us through our contact page , you must fill in the following fields:      

- Name, Surname, City, email (required).         

- Address, Age, Postal Code, Profession, Telephone, Comments, checkbox "I want to receive newsletter emails " (optional).      

3. WAYS WE COLLECT OR OBTAIN YOUR DATA

It is possible we collect or receive data from you through our websites and through forms, applications and devices, product websites or trademark of our Company on social media or otherwise.

Sometimes, we collect them e.g. using cookies to understand how you use our websites / applications or, sometimes, we receive your data from third parties.

Sometimes, you provide them to us directly (i.e. when you create an account, when you contact us, when you make purchases through our websites / applications or from stores, etc.).

When we collect data, the required fields are marked with an asterisk. Failure to provide data marked with an asterisk may affect our ability to provide our products and services.

4. PURPOSE OF PROCESSING OF PERSONAL DATA

The personal data that you provide anywhere on the pages and services of our website www.surfmarket.gr, are intended exclusively for reasons related to your transactions with us, such as:

- fulfil our mutual agreement (e.g. to deliver the products you have purchased from their websites / applications us),

- provide you with the requested service (for example, send you a weekly newsletter) ,

- Manage contests, giveaways, promotions or surveys in which you choose to participate,

- respond to your questions and to trade with you in other ways,

- to offer a loyalty program, or comply with legal requirements (e.g. issuing invoices or receipts),

- to contact you,

- to keep your details on a deletion list if you have asked us not to send you any further commercial promotions.

- for statistical purposes and to improve the services provided.

Your personal data may not be used by any third party (except for the competent authorities, where provided for, by law without your consent regarding the protection against the processing of personal data, as applicable at any time) , with the exceptions described herein. in Article 7.

The processing of your personal data is also intended to ensure that our websites / applications remain secure, protect them from fraud, and to better understand your needs and expectations and, consequently, to improve services, products and marketing. or our commercial reputation.  

In summary, we only ask exactly as much information as we need, in order for you to enjoy, improved purchasing experiences, for as long as you wish to trade with us, while  we, are in compliance with our legal and contractual obligations.

5. PROCESSING METHOD

Your personal data will be processed by appropriate means through the use of computers and automations and telematics tools, or manually, or in print, exclusively for the purposes for which it has been collected, with our appropriate security guarantees and confidentiality for the data being processed.

Your Personal Data will be processed by trained, competent staff of the company  (employees and partners) , duly authorized as " relevant persons " in the fulfilment of their duties and , possibly , by third parties which are bound , wherever it is deemed necessary to carry out the above purposes (e.g. service providers, couriers , technicians responsible for the maintenance of information systems, companies used by our Company to organize and / or manage promotional campaigns for products and services of, etc.). Your credit card data is not used for purposes other than verifying the existence of means of payment, accrual and payment management as well as for managing any or all the claims or disputes. To this end, this data will be further processed by the bank that provides services related to online payment management and by the issuer of the credit card you are using, in order to confirm your payment.

In the event that you provide your consent to the processing of your Personal Data, your data will automatically be visible and accessible at all stores of the Company (within Greece), for the purposes regarding the account creation, or for the purposes of marketing ,for  which you will receive appropriate safeguards and measures for the protection and confidentiality of your Personal Data .

6 . PERSONAL DATA RETENTION DURATION

We retain your personal data for as long as we need it and for the purpose for which we retain it in accordance with Article 4 of this DPP, in order to meet your needs or to comply with our contractual and legal obligations.

To determine the retention duration of your personal data, we use the following criteria:

· When you buy products and services, we retain your personal data throughout our contractual relationship and five years after its fulfilment.           

· When you participate in an advertising offer, we keep your personal data throughout the offer and five years after the offer.           

· When you contact us to ask us a question, we retain your personal information for as long as it takes to process your inquiry and five years after processing it.           

· When you create an account, we retain your personal data until you request to delete them or after an inactivity period of five years (as inactivity period is the period that elapses without making any transactions with the Company).           

· When you have provided your consent for direct marketing communications, we keep your personal data until you unsubscribe or  request deletion or after a period of five years of inactivity ( as inactivity period is the period that elapses without making any transactions with Company ) .           

· When cookies are installed on your computer, we keep your personal data for as long as it is necessary to fulfil their objectives (e.g. cookies used throughout the duration of a session  shopping cart cookies or session identification cookies ) and five years after they fulfil their objective.           

· When you contact us to apply for a job, we retain your personal data for three years.           

We may retain some personal information in order to comply with legal or regulatory obligations us and also to be able to manage our rights (for example, for us to promote our claims before the courts of Law) or for statistical or historical purposes , but no more than ten years .

 When we no longer need to use your personal data, we delete it from our systems and archives or anonymize them, so that you can no longer be identified by them, unless you ask us in writing to retain them. (see section 14).

The websites of our company operate in accordance with the applicable  Greek and European legislation and maintain securely your personal data for as long as you are registered / or subscribed to any of the services of  « www.surfmarket.gr » and according to what is mentioned in this section.

7. RECIPIENTS OF YOUR PERSONAL DATA

AND PURPOSE OF TRANSMISSION

We may transmit your personal information to our representatives and / or subcontractors for the purpose of supporting, promoting and executing your transaction with us, but always under conditions that fully ensure that your personal data does not undergo any illegal processing, meaning any processing other than the purpose of the transmission in accordance with the above. For example , we reserve the right to , for the above purposes , transmit your personal data to the shipping companies mentioned on our Website for the shipment of the products you purchased  from our Online Store to credit card processors in order to process a payment by you, as a result of your purchase from our Online Store, to third parties – individuals or corporations - who may provide on our behalf promotion and marketing services for both our company and products or services, or to our third party partners who provide us with technical services, such as hosting and technical support services. We hereby inform you that the above categories of recipients of your personal data are the ones performing the processing on our behalf and therefore as such they do not process any of your data beyond the above transmission purposes.

In any case, the employees of our Company who, due to their competence, have access to your personal data, are specific and the access of persons without authorization to your personal data is prohibited.

Every possible step to secure your data, has been taken.

Your personal data in extremely rare and special cases may be disclosed to companies cooperating with our Company.

We may also disclose your personal data to third parties, restrictively in the following cases:

 · In case of sale of a business activity or some assets, in which case we may disclose your personal data to the prospective buyer of that business activity or assets. In case of acquisition of our company or part of its assets by a third party, the personal data it holds about its consumers and which are linked to these assets is one of the assets that are transferred. Where appropriate, in this case, the buyer acting as new data controller, processes your data and that processing is governed by the data protection policy.

· If we are obliged to disclose or disclose your personal data in order to comply with any legal obligation or the imposition or application of our terms of use / sale or other terms and conditions you have accepted for the protection of the rights, assets or the safety of our Company, our customers or employees.       

· If we have your consent to this, or       

· If the law allows us to do so.       

Our company will not offer for sale or otherwise transmit or disclose personal information of visitors / users of its website to third parties other than those mentioned, without the consent of the customer / visitor / user, with the exception of the application of relevant legal obligations and to the competent authorities only.

The data kept in our archives may be disclosed to the competent judicial, police and other administrative authorities upon their legal request and in accordance with the legislation in force at the time. In addition, in the event of a legal order, official order or official preliminary investigation, the Company has the right without further ado to make the relevant information available to the competent authority.

8. SAFE RETENTION - SAFEKEEPING

OF PERSONAL DATA

We are committed to keeping your personal data safe and take all reasonable technical etc. precautions towards that goal. We also require, under a contract, that every trusted third party who handles your personal data on our behalf do exactly the same. We always make every effort to protect your personal data and once we receive it, we use strict procedures and security features to prevent any unauthorized access to it. Our Company is not responsible for the malicious actions of third parties that may violate the security of your personal data.

9. TRANSMISSION AND ARCHIVING

OF PERSONAL DATA

Your data is transmitted using encryption.

Your data stored in cloud hosting provided by the company Lighthouse SA, which has taken the necessary measures to comply with the European General Regulations Privacy Policy.

Our Company does not store or control credit card data.

10. LINKS TO WEBSITES OF THIRD PARTIES

& CONNECTION VIA SOCIAL MEDIA

From time to time, our websites and applications may contain links to and from the websites of our affiliates and advertisers. If you follow a link to any of these  websites, please note that these websites have their own data protection policy and our company shall not be held liable for these policies. We recommend that you check these policies before submitting any personal data to such sites.

We may also offer you the opportunity to use the login credentials of your social media accounts. If you use this feature, you should know that you are sharing your profile information with us, depending on your settings on the relevant social networking platform. Please visit the relevant social media platform and check their privacy policy in order to understand how your personal data is shared and used in this context.

Some of our sites and applications allow users to submit their own content. Remember that any content you submit to any of our social networking platforms may be displayed to the public, so you need to be careful when providing certain personal information, e.g. financial information or address information.

Our Company does not bear any responsibility for any actions taken by other persons if you post personal data on any of our social networking platforms and we recommend that you do not disclose such information.

11. USER CONSENT

By carrying out any of your transactions with us and using any of the Services of our  website www.surfmarket.gr , you consent to this DPP and in particular:

Account Entries: If you enter in your Member Account the information of your savings account and / or bank account, then you agree that our Company will use this information for all possible refunds to you, in case you exercise your right of withdrawal under provisions of the Terms of Use and the Law.

Use for advertising purposes: You agree that our Company will process and use your personal data for marketing purposes, such as e.g. sending email with general information or advertising nature (newsletters) with respect to the products and services our company offers. If you wish, our Company will waive the use of personal data for advertising purposes, provided, however, that you follow the procedures for your deletion from the list of registered members who receive our newsletters. The member can at any time send a relevant email to [email protected]  or notify us for his/her communication preferences through his/her member's account or unsubscribe following the procedures specified in each informative email he/she receives from us.

Data Processing regarding fraudulent acts: You agree that in the event of reasonable evidence and in the event that it is required by the specific occasion, our Company will have the right to collect, process and use those data which are necessary for disclosure as well as termination of offers generated for fraudulent purposes as well as the data of any other illegal or unconventional use of our website and / or your data by any malicious third party.

We declare that we reserve the right and duty transmission of your personal data to law enforcement and supervisory authorities for the necessary protection against risks for public safety and for the prosecution of crimes within the framework of existing laws.

User Data/Account Deletion

You may request the deletion of your account and all the data linked to it.

1. Log in to your account.

2. Choose cookie Privacy Policy & Settings https://www.surfmarket.gr/el/page/account-pages/private-data-settings/

3. Click REQUEST DELETION on the DELETE ACCOUNT area.

4. Please Click YES on the delete account confirmation message.

12. YOUR RIGHTS AND YOUR CHOICES

Our Company respects your right to your personal privacy: it is important that you are able to control your personal data. Your rights are as follows:

To handle your requests, we may request confirmation of your identity.

In any case, you have the right to address any request in the context of your above rights (e.g. for information, access, correction or deletion, or restriction of the processing of your personal data, etc.) in writing to our Company (see . section 14 – CONTACT INFORMATION).