Respect for your privacy and the management, protection and security of your personal data are a priority for "VASILEIOS KOSTETSOS" (or "Company", "KOSTETSOS", "we", "us"). The Company has established this Data Protection Policy (hereinafter the "Data Policy" or "Protection Policy" or "Policy"), in order to inform you who visit or buy from www.kostetsos.com (hereinafter "e-shop" , "Online Store" or "Website" or "KOSTETSOS" or "VASILEIOS KOSTETSOS"), or become a member or subscribe to the list of recipients of our Newsletters, or in any other capacity you use our services or participate in promotions or other actions of it, or you use the social media (Social Media) of the "Company", or otherwise, (hereinafter "you", "you").

KOSTETSOS is committed to the protection of the confidentiality and privacy of the information provided to it and complies with the applicable legislation for the Protection of Personal Data. Please review this Data Protection Policy in order to learn more about the type of information we collect about you through this website and how we use this information. KOSTETSOS also collects personal data in the context of the provision of its services (see below for more information). The "Data Policy" regulates the data of both the visitor of our website and our online store and concerns the process of your personal data. If someone does not agree with our policy, they are free to leave either our website or our online store.

1.PROJECT MANAGER AND PERSONAL DATA PROTECTION COORDINATOR

Responsible for the processing of your personal data is the company with the name "VASILEIOS KOSTETSOS LTD", based at ALEXANDROU SOUTSOU 11 - KOLONAKI (Tax Identification Number: 095702241 / Tax Office D 'ATHENS 84 no. 2103607354 (hereinafter the "Company").

You can contact the Company Data Protection Coordinator (DPC) by email ……………… .. and by phone …………… ..

2. COLLECTION AND PROCESSING OF PERSONAL DATA

Personal data or information of a personal nature means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one whose identity can be ascertained, directly or indirectly. This data does not contain data that is anonymous.

During your navigation in our Online Store or in the Social Media of "KOSTETSOS", the submission of an order, the opening of your Account, your registration in the list of recipients of our Newsletter newsletters or as a member of "KOSTETSOS", your participation in actions KOSTETSOS promotions, such as contests, social media interactions (eg comments, Likes, etc.) or otherwise, we collect various types of personal data about you, either directly from you, or from third parties or which we collect or we create by our own means (including automated means).

Indicatively, we collect the following personal data for you:

- Identity Data: (name, username, member code or other similar ID) that you provide to us during the submission of your order or during your registration as a Member of "KOSTETSOS" by opening an Account, your participation in competitions, etc ..
- Contact Data: (landline or mobile phone, e-mail address and other contact information) that you provide us when submitting the order, opening an Account or in the context of receiving commercial communication from "KOSTETSOS", or in the context of of your participation in various activities of "KOSTETSOS" (eg participation in competitions, etc.).
- Delivery Data: Postal Address (street, number, postal code, city, country).
- Financial data: (bank account, transaction value, credit, refunds, debit or credit card details, billing address, etc.) that you provide to us when paying by electronic means, in case of refund, which we infer from your purchases, etc. The registration of the card details, their confirmation, the commitment of the amount and the final charge, are done in a secure environment (SSL) of ALPHA Bank FAITH The website www.kostetsos.com in no case knows, does not handle and does not store your card details.
- Transaction / Purchase Data: (type of market products, transaction value, place of delivery, time of purchase, purchase history, complaints, payment method, information required in case of account change or re-credit such as bank account, beneficiary name, IBAN, banking institution etc. a.) that we collect about your purchase and / or from your account.
- Consumer Behavior Data: Consumer preferences when browsing the Online Store, ie the items you see, your shopping cart, Wishlist, your interaction on Social Media (eg which products do you Like), gift redemption, frequency purchase, method, time of purchase, type of purchase, etc., based on your shopping products, comments or any answers to our surveys.
- Technical data: such as source channel, Internet Protocol (IP) address, time zone and location, input, browser type and version, operating system and platform, and other technology on the devices you use to access our Website etc. For more details about the information we collect through cookies please refer to our policy.
- Login Data: to your Account or member of the loyalty program, which is the username (username - which corresponds to your email or mobile phone number) and password.
- Profile Data: in the context of your participation in the loyalty program of "KOSTETSOS" we collect data on your interests and consumer preferences, the collection and redemption of your reward points, your participation in competitions or events and your general interaction as a member with "KOSTETSOS".
- Demographic Data: age, gender, place of residence, which are collected directly from the subject on a case by case basis or inferred from the transactions of the subjects in our Online Store, etc.
- Data via Cookies: Browser, IP address, products that you have placed in the cart and have not completed the purchase, the country of origin of your order, the products that you look in the Online Store, the Wishlist with your favorites, your origin from other websites.
- Marketing data: which includes your preferences regarding the receipt of promotional material from us and third parties and your preferences for your communication with us, if we have your relevant consent, your opinion about products you bought from us.

It is important that the personal data we hold about you is up to date and accurate. Please let us know as soon as possible of changes to your personal data for the duration of your transaction with us.

We collect the following personal data directly from you:

When submitting your order, you must provide us with your name, shipping address, email, contact phone (mobile) and payment details (credit / debit card, etc.). The registration of the card details, their confirmation, the commitment of the amount and the final charge, are done in a secure environment (SSL) of ALPHA Bank FAITHFUL. The website www.kostetsos.com in no case knows, does not handle and does not store your card details.
- When registering as a Member in the loyalty program of "KOSTETSOS" either through our website or through our stores, through the relevant form that you fill in, you must provide us with your mobile phone number, your Name, your date of birth, as well as a password. Optionally and if you wish, you also provide us with your email, the date of your name day and your home address.
- When you register in the list of recipients of the Company's newsletters (Newsletter) you provide us with your email.
- During your registration in competitions that from time to time are conducted by our Company, you provide us with your personal data that are identified on a case by case basis.
- During your communication with us on the social media of "KOSTETSOS" (Facebook, Instagram, etc.) and with the Customer Service Department (apart from the cases of telephone ordering), you provide us with your personal information, such as identity, contact data, or transactions, which we use on a case-by-case basis only to serve your request.

We collect the following data and information about you by automated means.

By using cookies and other similar technologies we collect and / or create data about your preferences, such as the products you visit, the duration and frequency with which you observe certain products, the types of newsletters you open or not, their content and your interaction with us after each newsletter submission, your Wishlist, the type of products you purchase, the search terms you entered or the links you clicked into the Online Store, the products you place in the cart and do not complete the purchase their country of origin, language, etc.
- From your Account we create the history of your orders and your purchases, and from them we deduce your preferences, the frequency of your purchases by type, the value of the products you buy or are interested in, the season at which you buy, the your area of ​​residence etc.
- Data about the devices through which you visit our Website, such as the Internet Protocol (IP) address, login information, browser type and version, operating system and platform, and other technology on the devices used to access our Website etc.
- Data about the page you logged in from and the page you went to when you left.
We collect the following data and information about you from third parties:
- We may receive your personal information such as name and email address from a third party friend who told you to receive a gift voucher from us or to send you a gift of their choice.
- In case you register in our service through a social networking platform, we may collect the above personal data directly from the information you have provided on the platform (as long as the social networking platform has the relevant right to share your personal data with us).
- Your personal data may be shared with us by independent third parties when there is a legal basis for processing and they have the relevant right to do so. In these cases you must be informed about the processing of your personal data by the relevant Data Protection Statement of these third organizations. These organizations may include social media such as Facebook, Instagram, Viber, Twitter.

3. THE LEGAL BASIS FOR THE USE OF YOUR PERSONAL DATA

"VASILEIOS KOSTETSOS" believes that consent is one of the most important principles of privacy. You have the option not to provide us with any information that could lead to the verification of your identity (although in such circumstances you will not be able to access our entire website and especially our online store). The registration page where you sign up for email or other services provides a selection mechanism, which means that you will not receive any communication or services from us unless you click on the box that expresses your explicit consent. For specific communications and services, we will confirm your explicit consent prior to the commencement of the service you requested.

By choosing "subscription" you declare that you have read and agree with this Protection Policy and that you provide to our Company your consent for the processing of your personal data, including their transfer to associates with "KOSTETSOS" natural or legal persons (including affiliated companies) established in the European Union or in a third country, subject to compliance with applicable law and guarantees of a satisfactory level of protection of your personal data. If you later decide to discontinue the communication or services we provide to you, you may do so by changing the previous appropriate option on the relevant website, or, in the case of email distribution, each email we send you either providing clear disconnection instructions or provides a link to unsubscribe from the mailing list for that service or distribution.

4. HOW AND WHY WE USE YOUR PERSONAL DATA

All the above personal data which, as mentioned, you either provide to us compulsorily or voluntarily, or we collect from third parties or are produced by automated means, we use for the following legal purposes. Please note that in the event that European or national law restricts or prohibits certain actions of the Company for which we use your data, we will cease to use the information that concerns you for these purposes.

In particular, your personal data is used by us for the following purposes:

- To receive your orders, process them, and send the products to you.
- The communication with you for issues related to the sale of our products to you.
- For the management, processing and processing of your payments, including the security of our financial transaction.
- For your service as a Member in "VASILEIOS KOSTETSOS" by opening your Account with us. For the creation, storage and maintenance of a database with our clientele and its analysis.
- To send you commercial communication via Newsletter, SMS, or other multimedia (VIBER) that concerns news of our Company, products, offers and promotions.
- To analyze your behavior and understand your preferences.
- To understand and analyze the results of our ads and promotions.
- For the processing of your requests, such as for example the withdrawal, product replacement, etc ..
- For the satisfaction of your rights, regarding your personal data.
- For the security of transactions.
- For business analysis and improvements, such as for the marketing of our products and their optimization, for the optimization of your experience and your service by us in our Online Store, for the management of customer loyalty programs (Loyalty), as well as to adapt your experiences to our Online Store.
- For market research, statistical analysis, for the development of marketing strategies and the management of marketing campaigns and to inform you or our partners about possible opportunities to participate in the marketing initiatives or product promotion of "VASILEIOS KOSTETSOS".
- For other purposes for which we will notify you, or as the case may be, at the point where the information about you is first collected

5. RIGHT TO INFORMATION, ACCESS, INFORMATION AND DELETE

With respect to your Personal Data, you retain, among other things, the rights to update, access, opt-out and delete. In this context, you may at any time access your Personal Data we hold in databases to modify, correct or update this data, and even to oppose - at any time and for any reason - the processing Personal Data concerning you, as well as to revoke your consent regarding their processing or to request their final deletion from the Company's files. To do this, follow the steps that will be mentioned each time in the message you receive through the relevant means of communication (such as e-mail or SMS messages).

If you wish to withdraw your consent from all our newsletters and your consent to the use of your Personal Data for marketing, promotional products and / or services, then you may use the unsubscribe link as indicated in the messages you have received. Alternatively, you can contact our Customer Service Department via e-mail at [email protected] or by phone at 210.3607354. Please note that we may need to ask you to verify your identity before proceeding with your request.

You can also request at any time to delete your Personal Data kept in our files, by contacting the Customer Service Department via e-mail [email protected] or by phone at 210.3607354. We will respond within thirty (30) working days of receiving your request. If we do not respond or our response is not considered satisfactory by you, you have the right to appeal to the Data Protection Authority and request a review of our response or omission of our action.

In case of a request for deletion from you:

i. We will stop using and making available your Personal Data (unless or otherwise required by law).

ii. We will delete all of your Personal Data from our databases, except those contained in emails, correspondence or other documents that we may retain, in order to prove the terms of our contractual relationship with you or as otherwise provided by current legislation.

iii. Given the technology available and the cost of implementation, we will take reasonable technical and organizational steps to inform other data controllers who process your Personal Data on our behalf, as specifically stated above, that you have requested their deletion (the executors processing) any links to such data or copies or reproductions of such Personal Data.

Please note that we may need to ask you to verify your identity before proceeding with your request.

6. SECURITY OF YOUR PERSONAL DATA

We are committed to taking the appropriate technical and organizational measures to protect your personal data from unauthorized or illegal processing and from the accidental loss, destruction or damage of personal data. Your personal data, after completing the purchase of any goods, is transmitted via the internet securely using high quality encryption.

The information you provide to us will be stored on our systems, which are located on our premises or those of a certain third party. We may also grant access to your information to other third parties acting on our behalf for the purposes described in this Privacy Policy or for other purposes approved by you.

We will retain your personal information for as long as we need it in order to fulfill our purposes set out in this Privacy Policy or to comply with the law.

Our company has taken all the necessary technical measures and precautions to ensure the security and proper use of your data. However, no technical measure of electronic storage is 100% secure.

Our company will process the above data in accordance with the GDPR and the relevant national and European legislation.

Our company reserves the right to modify this policy if necessary in order to comply with the relevant legislation.

CONTACT

If you have any questions about this privacy policy, please contact us using the information set out in this policy.