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PRIVACY POLICY

Our Business takes the protection of its customers' privacy seriously. For this reason, we strictly adhere to the following privacy policy, which ensures the high level of services offered and strictly complies with the applicable legal framework.

With this Data Protection Policy statement, we wish to inform you about how our Business protects the confidentiality of your communications and collects, processes, uses and stores your personal data through our Website, as well as about the options and rights you have regarding the aforementioned collection and processing of your personal data. By visiting our Website, you acknowledge and accept the data protection policy that follows.

This data protection policy is valid only for the winekiosk.gr Website. Users should be aware that our Website may contain links to other websites, however, our Business bears no responsibility for the practices and terms of data protection or the content of these websites.

DEFINITIONS

For the purposes of this document, the following definitions apply:
1. "Cookie" - a short piece of software code sent for storage by the Company's web server to the user's PC each time the latter enters the Website, for the purpose of selectively recording the user's browsing history within winekiosk.gr. It is necessary as a mechanism for the technical execution of the "shopping cart" service.

1.2. "Recipient" - any natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether a third party or not.

1.3. "GDPR" - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

1.4. "Processing" - Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.5. "Business" - Our Business with the trade name Wine Kiosk and distinctive title "Wine Kiosk" based at Psalti 4, Kalamata P.C. 24100

1.6. "Business User" - the business that uses the services of the winekiosk.gr Website.

1.7. "Website" - the website accessible via the domain name winekiosk.gr, including all its web pages.

1.8. "Profiling" - any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

1.9. "Personal data" - any information relating to online user(s) of the winekiosk.gr Website

1.10. "Consent" - any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

1.11. "User" - the online user of the winekiosk.gr Website to whom the data refers and whose identity is known or can be verified, i.e. can be identified directly or indirectly.

SUBJECT MATTER

1. This policy sets out the terms and conditions observed by our Business for the protection of the privacy of winekiosk.gr users. This policy includes the rules based on which we proceed with any collection and processing of your personal data and ensure the confidentiality of this information.

2.2. Our Business reserves the right to modify and adjust this policy whenever it deems necessary, and any changes will take effect from their public appearance on the winekiosk.gr Website.

2.3. If any of these terms are deemed invalid, illegal, or abusive for any reason, the remaining terms shall remain valid and in force as they are, to the extent that they do not conflict with the intention expressed through this policy.

PROCESSING PRINCIPLES

We fully respect your fundamental rights and make the protection of your privacy a priority for our Business. In this context, when processing your personal data, we adhere to the following basic principles:

1. We process your personal data lawfully and fairly, and maintain full transparency with you regarding how we handle your personal data.

3.2. We collect and process your data only for specified, explicit and legitimate purposes, as set out in this policy, and do not further process it in a manner incompatible with those purposes.

3.3. We process your personal data only to the extent that it is appropriate and relevant to the above purposes, while also limiting the relevant processing to what is necessary for those purposes.

3.4. We make reasonable efforts and with your assistance to ensure that your data under processing is accurate and, when necessary, updated in relation to the purposes of the processing, taking all reasonable steps to promptly delete or correct it in case of inaccuracy.

3.5. We keep your personal data in a form which permits identification of you for no longer than is necessary for the above processing purposes.

3.6. We process your personal data in a manner that ensures its security using appropriate technical or organisational measures.

3.7. We do not intend to further process your personal data for a purpose other than that for which it was collected.

3.8. We inform you that there is no obligation for you to provide your personal data and there are no potential consequences from not providing it. Furthermore, we inform you that your personal data will not be used for automated decision-making, including profiling.

3.9. Without prejudice to what is stated in this policy, we do not disclose or transfer your personal data to third parties without your consent, unless this is permitted by law or by our mutual agreement.

3.10. We inform you that we do not transfer your personal data to a third country or international organisation for which there is no adequacy decision by the European Commission in accordance with the GDPR.

3.11. In general, we fully comply with the current legislation and fulfil all our obligations arising from it, as the legally responsible controller of your personal data.

TYPES OF DATA

1. The types of personal data that we collect and process from you depend on the services you choose for us to provide you. Thus, during (a) entry and use of the Website, (b) registration for the newsletter service, (c) creation of a personal account, and (d) provision of services, you provide our Business with the following types of personal data.

4.2. While browsing our Website, you provide the following data:
Internet Protocol (IP Address).
Browsing data within the Website.
Service preference information.
Data on executed transactions.
User-generated content.

4.3. When registering for the newsletter service, you provide us with the following data:
Email address.

4.4. When creating a personal account, you provide us with the following data:
Username.
Password.
Email address.
Full name.
Residence.
Tax identification number (AFM) and Tax Office (DOY).
Contact details.

4.5. Furthermore, if any user communicates with us via email or other means, we proceed with the collection and processing of personal data related to such communications, under the terms and conditions of this policy, in order to respond to relevant requirements and requests and to improve our offered services.

4.6. The Business does not collect or access personal data of its users - customers related to the online payment of services provided through the Website, such as credit card numbers and codes. Such data is collected and processed exclusively by and under the responsibility of the collaborating bank during the process of executing and completing each sale using the redirect method, i.e., by transferring the user from the winekiosk.gr website to a website under the responsibility of the said banking institution.

4.7. Our Business does not collect or access in any way special categories ("sensitive") of personal data or data concerning criminal convictions and offences of its users - customers. You are obliged to refrain from posting such data concerning yourself or third data subjects. In case you post such data on our Website, it will be removed as soon as it comes to our attention. We bear no responsibility to you or to third parties for any posting and/or processing of sensitive data due to your acts or omissions in violation of the above obligation.

PURPOSES AND LEGAL BASIS OF PROCESSING

1. Your personal data, which are necessary for browsing and using our Website in accordance with Article 6 § 1 (b) of the GDPR, are collected and processed by our Business for the following purposes:
Technical capability for the uninterrupted operation of our Website.
User-friendly and easy operation of our Website.
Improvement of your online experience when browsing and using our Website.
Recording of consumer habits through the use of anonymous statistical data.
Sending informational emails to subscribers of the newsletter service.

5.2. Your personal data, which are necessary for the provision of our services within the framework of our contractual relationship in accordance with Article 6 § 1 (b) of the GDPR, are collected and processed by our Business for the following purposes:
Execution of our Business's contractual obligations towards the ordinary and Business Users of our Website.
Direct, adequate, and effective provision of our services.
Tax use and use for invoicing and proof of provision of ordered services.
Communication with our customers within the framework of good execution of our services, as well as for the resolution of any complaints.
Improvement and renewal of our products and services to meet the needs of our customers as much as possible.
Administrative organisation and operation of our Business.
Customer management.
[…].
Support of legal claims.

5.3. Our Business collects and processes personal data of its users – customers exclusively for the aforementioned purposes and only to the absolutely necessary extent for the effective service of these purposes. This data is always relevant, appropriate and not more than what is required in view of the above purposes, and is accurate and, if necessary, updated. Furthermore, this data is retained only for the period required to achieve the purposes of its collection and processing and is deleted thereafter.

CONSENT

1. Our Business may process personal data only after the lawful consent of the Website users for the following purposes:
For purposes of commercial communication, commercial promotion and advertising of our services or third-party services via SMS, telephone, email, internet, fax, mail, social media, and/or any other appropriate communication channels.
For research and/or analysis purposes to better understand your needs, preferences, interests, experiences and/or habits as a consumer.
For the operation and management of any loyalty programs.

6.2. You give us your consent for the processing of your personal data for the above purposes by electronic declaration in a manner clearly distinguishable from other matters, in an understandable and easily accessible form. Your consent is given freely and your personal data is provided without such provision constituting a legal or contractual obligation or a requirement of our company for the conclusion of a contract between us.

6.3. In this context, by completing the relevant field online, you explicitly declare that you wish and that you give your consent for the above purposes in accordance with the terms and conditions of this policy. You provide the above consent in the following ways:
When subscribing to the newsletter service.
When creating your personal or business account.
When ordering services as well as when entering into contracts through our Website.

6.4. You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The withdrawal of your consent is done in the same way as its provision.

THIRD PARTY RECIPIENTS OF DATA

1. Our Business does not transfer your personal data or link its archive for financial or other consideration with any third private companies, natural or legal persons, public authorities or services, or other organizations.

2. For the purposes of processing mentioned in this policy, our Business may provide access to or transfer the following types of your personal data to the following processors on its behalf and instruction:

Your financial data to the credit institution with which we collaborate for the processing of payments to and from your bank accounts and credit card accounts, for the purpose of settling your financial obligations to our Business. Your personal data to the internet hosting service provider with whom we maintain a contractual relationship, for the purpose of hosting them on the winekiosk.gr Website.

Your personal data to the company that provides us with software and database maintenance and support services, for the purpose of supporting the winekiosk.gr Website.
Preference data and contact information to third-party marketing and advertising companies for commercial communication, promotion, and advertising of our services or third-party services.
Your personal data to third-party consulting companies for the provision of data analysis services.
Your financial data and contact details to debt collection companies, in case of overdue debts to our Business after prior notification to you.
Your personal data to auditors, accountants, financial or professional advisors, as well as investors in the context of a transfer of part or all, merger, spin-off, or other universal succession, liquidation, bankruptcy, or submission to another procedure of the bankruptcy code of our business.

3. The processing of your personal data by the aforementioned collaborating entities is conducted under our control and only under our instruction, and is subject to the same data protection policy or a policy of at least the same level of protection.

4. In the event that our Company is compelled by a court or other administrative authority, as well as in any other case where it has a legal obligation to do so, our Company may disclose your personal data to the extent provided by law, but only after informing you.

5. You acknowledge and authorize our Company to provide, upon your request and on your behalf, your contact details, specifically your full name, your address, your email, and your mobile and/or landline phone number (or some of these), as well as any other requested personal data, to any professional or business that you have requested/accepted to provide you with the service you have chosen. Our Company expects and requests professionals to respect your Personal Data, to use it only within the scope of our Website's operation purposes, and not to disclose it to third parties. Nevertheless, you unreservedly acknowledge and accept that our Company cannot oversee these professionals or businesses regarding their adherence to the above commitments, that you assume the relevant risk, and that our Company bears absolutely no responsibility, nor owes any kind of compensation, if a professional who has gained access to your Personal Data uses it for reasons other than providing their services to you or if they disclose it to third parties without your permission.

DATA PRIVACY AND SECURITY

1. Our Company, in order to ensure the proper use and integrity of your personal data and to prevent unauthorized or accidental access, processing, deletion, alteration, or other use thereof, implements appropriate internal policies, while taking all appropriate organizational, technical, physical, electronic, and procedural security measures, as well as technological standards, in accordance with applicable laws and regulations.

2. The data processing procedure by our Company is conducted in a manner that ensures the confidentiality and physical and logical security of the data, taking into account the latest developments, the cost of implementation, and the nature, scope, context, and purposes of processing, as well as the risks of varying likelihood and severity for your rights and freedoms.

3. The processing of your personal data is carried out exclusively by personnel of the Company authorized for this purpose, who are bound by strict obligations to maintain their confidentiality.

DATA RETENTION PERIOD

1. We retain your personal data for as long as the purposes for which they were collected, as described above, remain valid.

9. mentioned cases:
When we have a legal obligation under a relevant law.
For use before tax and social security authorities, as well as any other auditing authority, within the legal statute of limitations.
When required for the operation and organization of our Company, provided that your data is pseudonymized.
For the defense of our rights and legitimate interests before any competent Court and any other public authority.

9.3. After the retention period, your personal data will be destroyed from our archives and system in compliance with our company's policy and provided that their retention is no longer required for the fulfillment of the purposes we have described to you above.

RIGHTS

1. As data subjects, you have the right to request and receive access, information, and a copy of your personal data that we collect and process. If you wish to receive a copy of part or all of your personal data, please contact us using the contact details of our Company provided in the relevant section of this document.

2. We further inform you that you have the ability, at any time, to exercise your rights under the terms and conditions of the law, as they stem from the GDPR, regarding the rectification, erasure, and portability of your personal data, as well as the restriction and objection to their processing.

3. The above requests are submitted in writing by postal letter to the registered office of our Company. Our Company will respond to each of your requests within one month of its receipt. After informing you, this deadline may be extended by two more months, if necessary, taking into account the complexity of the request and the number of requests. Any rejection of your request will be duly reasoned.

4. If your requests do not meet the conditions of the law, our Company reserves the right to either: (a) impose the payment of a reasonable fee, taking into account the administrative costs for providing the information or communication or performing the requested action, or (b) refuse to act on your request.

5. If there are doubts about the identity of the natural person submitting the request, we reserve the right to request additional information necessary to confirm their identity.
10.6. If your rights are violated, we inform you that you have the right to lodge a complaint with the Hellenic Data Protection Authority or another competent supervisory authority.

USER OBLIGATIONS

1. By using the Website and by providing your personal data with your consent, you acknowledge that you have the obligation to declare the true, accurate, and complete information requested by our Company. Furthermore, you are obliged to inform our Company of any changes to this information, in order to keep it updated and accurate.

2. If it is found that you do not comply with the above obligations or if our Company has reasonable suspicions that the information you provide is false or incomplete or in any way contravenes the law or the Terms of Use or this Data Protection Policy, we reserve the right to reject your application for registration or to suspend or immediately terminate your account without notice. In this case, you have no right to any compensation due to the rejection of your application, or the suspension or termination of your account.

3. You acknowledge that our Company may delete, cross-reference, supplement, or modify the information you provide based on information lawfully provided by third parties. In this case, our Company will inform you accordingly, observing the legal procedure.

4. By using the Website, you confirm that you are over sixteen (16) years of age. If you are under sixteen (16) years of age, you are obliged to refrain from any use of the Website and from any provision of your personal data without the approval of the person exercising your parental care. If you do not comply with the above obligations, you must immediately notify our company accordingly. In any case, by using the Website, you acknowledge that our Company is not responsible for your violation of the above obligations to the extent that it does not have the ability, even if it makes reasonable efforts, to verify your age or the consent of the person exercising your parental care.

COOKIES

Our Website uses cookies. For more information, please visit our relevant website regarding our use of cookies [hyperlink].

INTERNATIONAL JURISDICTION AND APPLICABLE LAW

For the resolution of any dispute arising between our Company and users of the Website regarding this data protection policy and its subject matter, the courts of Athens shall have jurisdiction and Greek law shall apply, without regard to its conflict of laws rules.
In the event that a provision of this policy is annulled by a decision of a competent court as unlawful, valid, or enforceable, this fact shall not affect the remainder of its provisions, which shall remain in force and shall apply normally.