PRIVACY POLICY

INTRODUCTION

Welcome to HomeisAthens’s privacy policy.

COSTANA SINGLE MEMBER PRIVATE COMPANY (the company which operates the website wwwhomeisathens.gr, hereinafter the “HomeisAthens” or the “website”) respects your privacy and is committed to protecting your personal data. This privacy notice will tell you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

• PURPOSE OF THIS PRIVACY POLICY
  This privacy policy aims to give you information on how HomeisAthens collects and processes your personal data through your use of this website, including any data you may provide through this website when you register on our website. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them. Please read the Policy carefully before you use the website. You should not use our website if you are not comfortable with what is stated below, and your continued use of Services constitutes consent to the Policy.
• CONTROLLER
  COSTANA SINGLE MEMBER PRIVATE COMPANY is the controller and responsible for your personal data. The company may be called “Costana S.M.P.C.”, “we”, “us” or “our” in this privacy policy. Costana S.M.P.C.is a company incorporated in Greece with General Commercial Registry (GEMI) No. 133304501000. Our registered office is at 15 Karneadou Street, Athens, 10675, Attica, Greece. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
• CONTACT DETAILS
  Our full details are:
  Full name of legal entity: COSTANA SINGLE MEMBER PRIVATE COMPANY
  Email address: info@homeisathens.com
  Postal address: 15 Karneadou Street, Athens, 10675, Attica, Greece Telephone number: +30 211 4057163, +30 693 6593578
  You have the right to make a complaint at any time to the Hellenic Competition Commission (HCC), the Greek supervisory authority for data protection issues (https://www.epant.gr). We would, however, appreciate the chance to deal with your concerns before you approach the HCC, so please contact us in the first instance.
• CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
  It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
• THIRD-PARTY LINKS
  This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data ab that you provide to us through the forms you fill in on our Site or automatically which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services and browsing behavior.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Sites you have visited before or after visiting our Site.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but the law does not consider it personal data because this data does not reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

If we need to collect personal data to be able to fulfill a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract. In that case, we may have to cancel a service you have ordered but we will notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • subscribe to our service or newsletters;
  • request marketing to be sent to you; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. (for more information on this, please read our Cookie Policy)
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
  a. analytics providers (such as Google);
  b. advertising networks (such as Google, Facebook); and
  c. search information providers (such as Google, Facebook).
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators (such as Kissmetrics outside the EU).
• Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use the collected information:

• To perform a contract between you and us (such as fulfilling your booking).
• To provide you with our Services as an unregistered or registered visitor/user of the Site
• To manage and improve the performance of our products and Services
• To target our promotional communication according to your use of our Site or Services
• For audits and reporting purposes
• For security, and to protect legal requirements of our own, as well as that of our employees, our agents or others, and to comply with applicable law and government requests.
• Your personal data won’t be stored for longer time than it is required by legal obligations, or our legitimate business interests.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Legitimate Interest means we use your personal data to conduct and manage our business in a way that enables us to give you the best service/product and the best and most secure experience. In doing that, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights. We do not use your personal data for activities where our interests are overridden by the impact using your data might have on you (unless we have your consent or are otherwise required or permitted to by law).

• Performance of Contract means we are processing your data because it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means we need to process your personal data to comply with a legal or regulatory duty that applies to us.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what products, services and offers may be of interest to you. This is part of our marketing strategy. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. If you do not want to receive promotional offers from us, you can opt out at any time. See Opting Out below.

THIRD-PARTY MARKETING

We will not share your personal data with any other company or business for marketing purposes unless you have given express permission to do so.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a service purchase, service experience or other transactions].

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to disclose personal information in the following circumstances and to the following parties:

• service providers (acting as processors) who provide IT and system administration services on our behalf, such as web hosting, email service providers, payment processing, analytics, etc. To do so, we sometimes need to share your personal information with them for the purposes described above. These service providers are located around the world. Therefore, the personal data that we collect may be transferred to and stored in countries outside of your jurisdiction. Any international transfer of your personal information is made by following the appropriate safeguards;
• professional advisers (who may be acting as processors or joint controllers) including lawyers, accountants and insurers based in Greece who provide legal, accounting, insurance or other consultancy services;
• Regulators and other authorities (who may be acting as processors or joint controllers) based in Greece;
• Certain third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Aggregated information that does not identify specific individuals.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

7. DATA SECURITY AND PRIVACY INCIDENT REPORTING

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who need to access that data for business purposes. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Although, we have put in place procedures to deal with any suspected personal data breach, no security program is 100% foolproof and thus we cannot guarantee the absolute security of your personal or other information. Upon the occurrence of a data privacy incident (breach) you will be informed as soon as the incident is taken into consideration. Additionally, the relevant Data Protection Authority will be informed within 72 hours after incident has been noticed.

8. DATA RETENTION

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances we may anonymise your personal data (so that you cannot be identified) in which case we may use this information indefinitely without further policy to you for research or statistical purposes.

9. YOUR LEGAL RIGHTS

Under certain circumstances, if you are an EU resident you have the following rights in respect to your personal information that we maintain:

• Right of access: you have the right to obtain confirmation that your personal data is processed, and in the case of processing, information regarding the purposes of your data processing, the retention period (and the criteria used to determine this period) of the data, the recipients to whom your personal data has been or will be disclosed, and a copy of your personal data that we maintain
• Right to data portability: you have the right to receive your personal data that you have provided to us, in a structured, commonly used and machine-readable format
• Right to rectification: you have the right to obtain rectification of any inaccurate or incomplete personal data that we maintain about you
• Right to erasure (right to be forgotten): you have the right, in some circumstances, to obtain erasure of the personal data that we maintain about you
• Right to restriction of processing: you have the right, in some circumstances, to obtain restriction of processing to the personal data that we maintain about you
• Right to object: you have the right to object to any processing of your personal data that we maintain, but there may be compelling reasons for continuing this processing from our side. In any case we will assess your request and respond to you accordingly. Marketing activities are not included in the afore mentioned compelling reasons.
  Non-EU residents may have similar rights to the above, as described in the applicable legislation. In case you wish to exercise one of these rights, please contact us at +30 211 4057163, +30 693 6593578, info@homeisathens.com. Lastly, you have also the right to raise a complaint to your local data protection authority.

10. NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

11. WHAT WE MAY NEED FROM YOU

We may need to ask for specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anybody who does not have a right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

12. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. UPDATES TO THIS POLICY

This website Privacy Policy may be changed or updated occasionally to meet legal, technological or operational requirements and standards. You are encouraged to frequently visit this policy to stay updated about changes. In case of critical changes, these will be circulated to you prior to their implementation. Modifications will be effective on the day they are published.

14. CONTACT

If you would like to reach us for any reason, you may contact us by phone on +30 211 4057163, +30 693 6593578, by email at info@homeisathens.com or by mail at 15 Karneadou Street, Athens, 10675, Attica, Greece.

Last updated on: 29/01/2019