- Who is the Data Controller of your personal data – Where you can adress the exercise of your rights?
- Company’s general principals related to transparent information
2.1. Any information we are giving to you with this document and any information you may request in the future is provided free of charge under the condition your request should not be repeated, exaggerated, or obviously unjustified (see more 2.3.)
2.2. For each of the above rights you exercise, the Company will respond within one (1) month of the receipt of the request or in case of objective difficulty, complexity of the request or the number of requests, the Company will correspond the maximum in a total period of three (3) months in relation to the completion of your application or justified refusal to perform what you have requested for lawful reasons which are expressly specified in General Data Protection Regulation 2016/679.
2.3. In case the Company determines that any of your above mentioned rights is manifestly unfounded or the claim is excessive or the request has a recurrent nature, it is entitled, on one hand, to impose your charge with a reasonable fee for providing further information (which is free of charge) and, on the other hand, refuse to respond to the request.
2.4. In case the Company has reasonable doubt as to your identity when you are applying for the exercise of one of your above rights, the Company may request the provision of additional information which is necessary to confirm your identity before the procession of the request.
- Which are your Rights related to your Personal Data?
3.1. Right to Information
You reserve the right to request information about the personal data we have received from you and we maintain it for some or some of the purposes as they are being outlined below (under 4). This document is a complete manual of basic information and understanding of the philosophy of the regulatory framework that rule the protection of your personal data. Updating, deepening and clarification in this text can be given to you upon request for the exercise of your right to information. (See 1.2)
3.2. Right to Access
You reserve the right to request from our Company access to your data which we maintain and confirmation as to whether they are processed and more specifically information about the processing purposes, categories of personal data, recipients or categories of recipients, their retention and processing time, the existence of the right of compliant to the Personal Data Protection Authority, any available information about the origin of the data when it is not being provided from you, the existence or not of automated individual decision making including profiling and the relevant methodology, safeguards about the policy we follow when we make transfers to third countries, a copy of the personal data that is being maintained and processed. (See how in 1.2.)
3.3. Right to Rectification
You reserve the right to request from our Company to correct your data in case of any of your data for which we have the right to proceed has changed or is incorrectly registered. (See how in 1.2.)
3.4. Right to Erasure
You reserve the right to request from our Company the full or partial erasure of your data to which we have the right to keep and process either because they are no longer necessary in relation to the purposes for which they were collected or otherwise processed or because you withdraw your consent or because data was collected for a purpose that you deem illegal. Our Company, within a reasonable time (no more than one month and under conditions if there is a difficulty for no more than three months in total) will respond to you by confirming the total or partial erasure of your data or the inability to erasure specific data if a law or fulfilling a duty in the public interest, either the right to freedom of expression and information or the exercise or support of a legal claim requires them to be retained. In this case, you have the possibility of complaining to the supervisory authority and, on the other hand, by bringing legal action. (See how in 1.2.)
3.5. Right to Restriction
You reserve the right to request from our Company to restrict the processing of your data, quantitatively, in time or in relation to the purpose of processing, and more specifically (a) either because you are contesting the accuracy of your data, (b) or because you consider the processing unlawful but do not wish to be deleted as it will serve you for a legal claim, (c) or because the accuracy of the data is contested by you and for as long as it is possible for the Company to verify its accuracy, (d) or in case if you have objections to the processing of the data and until it is verified that your rights as a Subjective are overriding to the Company’s lawful reasons of procession (see how in 1.2.)
3.6. Right to Data Portability
You reserve the right to receive the personal data you have provided us in a structured, commonly used and machine readable format, as well as the right to transmit further without objection, since your data is processed on a consensus basis. As part of the exercise of this right, you may also request direct transmission from the Company to the third party without your own mediation.
This right is exercised under the same conditions under which you have the right to exercise the right of erasure (See 3.4 above) and this exercise can not adversely affect the rights and freedoms of others. (See how in 1.2.)
3.7. Right to Objection
You reserve the right to object to the use of your personal data for the purpose of direct marketing and in particular to create a profile related to this direct marketing. (see how in 1.2.).
There is no relevant right in the case of Candidate Employees and visitors of the company's facilities as this data is not transmitted to the Marketing department and is not treated in this way.
- Can your data be promoted and somewhere else?
Your data is not intended to be transmitted to any organization outside the Company and its affiliated companies with the exception of (a) our Company's electronic systems and network support service providers - and for the sole purpose of their performance of the contract for support of our Company and (b) the competent tax authorities in the context of our mandatory compliance with tax legislation and to the extent (and under the condition) is required.
We assure you that the Company will exhaust any technical and organizational data protection measure and will make the optimal, minimal and absolutely necessary only use and processing of the Data as the law defines and strictly and exclusively for the purpose for which you have provided it to us.
Special provisions for the individual categories of Personal Data Subjects that cumulatively meet the above general provisions of the Policy
(A) RECEIPIENTS OF INFORMATION
A.1. Purpose: The receipt, processing and retention of your data provided in the context of registration of each user/customer in the online ordering platform is your information on the performance/fulfillment of your order and the products and services we provide in the field of health and wellness.
A.2. Legitimate basis for processing: The legal basis for the processing of your data is your consent to it for the fulfillment of the respective above purpose, according to article 6 par. 1(a) of the General Data Protection Regulation (GDPR).
A.3. Data Retention Period: For the fulfillment of the above processing purpose, your information about the shipment of your order, our products and services, we consider a reasonable and necessary retention time of your relevant data for a period of ten (10) years. After the lapse of ten (10) years from the time of receipt of your consent, the relevant data will be erased unless your consent is provided again under the above conditions.
(B) CUSTOMERS - SUPPLIERS and POTENTIALLY CUSTOMERS - SUPPLIERS
B.1. Purpose - Legitimate basis:
(a) during the pre-contractual stage, indicatively in case of completion of an electronic communication form on our website or direct sending of an email or telephone communication or filling in a printed form, (in which case, you provide us with name/email address and/or telephone and/or Address and/or capacity and/or our products that interest you), the purpose is to investigate the possibility of transaction with the Company and the legal basis is to serve the legitimate interest of the Company to pursue its commercial purposes in response to the requested communication to investigate the possibility of transaction with you.
(b) In the event of a transaction with the Company, your data that you have provided to us pre-contractually (as well as what you will provide to us in the context of our transaction) will be processed for the purpose of implementing the contract between us and our compliance with tax legislation. In this case, the legal basis of the processing is the performance of the contract between us as well as our compliance with the legislation (art. 6 par. 1(b) and 1(c) of the General Data Protection Regulation (GDPR).
B 2. Data Retention Period:
We will keep the above data under B.1. (A) for five (5) years and then we will erase them. With regard to the above under B.1. (B) the data will be maintained for as long as necessary by the tax legislation.
(C) VISITORS AT THE COMPANY FACILITIES
C.1. Purpose: Upon entering the company's premises we receive data regarding your identification, while, at the same time, the entire facility is covered by closed circuit television (CCTV), which records (image) on a continuous basis the movement in these places. The purpose of the above receipt, processing and maintenance of specific data is to protect the safety of people, located at the company's facilities (indicatively customers, visitors, employees, etc.) but also to safeguard the property (building, electronic equipment, etc.) and the interests of the Company.
C.2. Legal basis for processing: The legal basis for receiving, keeping and generally processing your data is the safeguarding of the Company's legal interests, which are identified with ensuring the safety of individuals (e.g. employees, visitors) and the material objects are located at the Company's premises, according to article 6 par. 1 (f) of Regulation (EU) 2016/679.
C.3 Data Retention Period: For the fulfillment of the above processing purpose we consider a reasonable and necessary retention time of your relevant data the period of ten (10) days. After the lapse of ten (10) days from the time of your entry into the company's premises, the relevant file with all your details will be erased.
(D) CANDIDATE EMPLOYEES:
D.1. Purpose: The evaluation of the possibility of your recruitment by the Company.
D.2. Legal basis for processing: For the data you have provided to us in the context of the assessment of the possibility of your recruitment by the Company, the legitimate basis is your consent according to art. 6 par.1 (a) of the Regulation (EU) 2016/679.
D.3. Data Retention Period: For the fulfillment of the processing purpose that concerns the investigation of the occupation of a job in our company, we consider a reasonable and necessary retention time of your relevant data the period of twelve (12) months. After the lapse of twelve (12) months from the time of receipt of your CV, the relevant file with all your details will be erased.