INTRODUCTION

The website www.route67.gr (hereafter Website) belongs to the Company named “AFOI SARAKINIOTI UNLIMITED COMPANY”, with registered offices in the Municipality of Athens Attica Greece, 67, Adrianou Str., P.C. 10556, taxpayer identification number (TIN) 800887481 (hereinafter referred to as “the Company” or route67.gr), Tel: +302103241672, e-mail: route67.privacy@gmail.com.

The Company has taken the appropriate measures which ensure that processing of your personal data complies with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the applicable Greek Laws. Especially, route67.gr adopts internal policies and implement measures which meet the principles of data protection by design and data protection by default.

We collect your personal data either directly from you, or through affiliated companies. We collect your data through this site and / or in other ways (social media, contests, cookies, analytics tools, etc.).

Route67.gr is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.

Shopify’s Privacy Policy: https://www.shopify.com/legal/privacy.

Shopify’s Privacy Shield Certification: https://www.privacyshield.gov/participant?id=a2zt0000000TNSNAA4.

By using this Website, you agree to be bound by the Privacy Policy.

This Privacy Policy applies to visitors / users / customers of route67.gr. Therefore, the words "you", "your" and generally the use of the second plural form refers to visitors / users / customers. Throughout the Privacy Policy, the terms “we”, “us” and “our” refer to route67.gr.

SCOPE AND AIM

While you are browsing through different webpages of the Website, we may ask you to disclose some personal data in order to provide you our services. The present Privacy Policy (hereafter Privacy Policy) describes the type of your personal data which are subject to the processing, the way and the context in which your personal data are collected, the purposes and means of the processing of your personal data, the entities to which your personal data may be disclosed, the purpose limitations, the storage period and measures we take to ensure lawful and fair processing and the principles relating to processing of personal data. It also includes information about your rights and data protection. The Privacy Policy applies only to processing of personal data for purposes of the Website’s services and operation. We also collect personal data through our pages on social media, cookies, analytics tools etc. In this case data processing may be subject also to another privacy policy (e.g. facebook / google privacy policy).

DEFINITIONS

For the purposes of the Privacy Policy:

(1) ‘personal data’ or ‘data’ means 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 a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

(2) ‘processing’ means 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;

(3) ‘data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

(4) ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

(5) ‘consent’ of the data subject means 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;

(6) ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

(7) ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

(8) ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51 G.D.P.R.

(9) ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

(10) ‘profiling’ means 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, behavior, location or movements;

For any other term please read the Terms of use.

OUR PRINCIPLES RELATING TO PROCESSING OF YOUR PERSONAL DATA

At this Website we process your personal data lawfully, fairly and in a transparent manner (‘lawfulness, fairness and transparency’). We collect your personal data for specified, explicit and legitimate purposes. Your data are not further processed in a manner that is incompatible with those purposes (‘purpose limitation’). Furthermore, your personal data that we process are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’). Your personal data are also accurate and, where necessary, kept up to date. We take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’). Your personal data are kept in a form which permits identification of you for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’). Your personal data are processed in a manner that ensures appropriate security of them, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

DATA CONTROLLER

For any processing of personal data carried out by www.route67.gr, solely for the following purposes, the Company named “AFOI SARAKINIOTI UNLIMITED COMPANY” is considered to be the Data Controller (e-mail:route67.privacy@gmail.com). The Data Controller determines the purposes and means of the processing of your personal data.

PERSONAL DATA WE COLLECT AND PROCESS - LAWFULNESS OF PROCESSING - PURPOSES - RETENTION PERIOD

We will process your first name, your last name, your e-mail address and your password, to create a new account for you. We will store these data for as long as you retain your account.

In order to purchase our products, we will ask you to provide us with personal information such as: your first name and last name, company name, your address (street, No, city, district, country, zip code), phone number and e-mail address. These data are collected electronically through the relevant data entry form (Checkout). We will also collect/process your order payment information and disclose it to the company EveryPay S.A. In this case processing is necessary for the performance of our contract to which you are party. We will disclose your data to courier companies. We will store your personal data for six years from the end of your last purchase from route67.gr. In the same context, we may also process your personal data in order to take steps at your request, prior to entering into a contract. We may as well use your e-mail address to send you improvements and / or updates of our products / services and information about the delivery of your products.

When you contact us, by filling the available form of the Website, you provide personal information such as your name, your e-mail, your telephone number (optional) and your Message. We also process your personal data when you contact us by any other way. We process your personal data collected this way, for contacting you. When you seek for information about our products / services, we process your Personal Data in order to take steps at your request, prior to entering into a contract. Unless you are already a customer of route67.gr, we will store your personal data for six months from the last time you have contacted us.

We also, collect your Personal Data (profile name, comments, reviews, contact details, messages) you share with us when visiting our pages / profiles / channels on social media platforms (Facebook / Twitter / Instagram / Google Maps etc.). This information is processed when you contact us, make a request or interact in another way with us, through our social media pages, so as to respond or communicate with you in any way. Your personal data will be retained for as long as you remain a fan / follower / subscriber of our pages / profiles / channels. By using the above-mentioned services (social media) you acknowledge that your interaction (like, comment, message) with our pages / profiles / channels etc. gives us the right to process your personal data on the basis of your consent. We may also use process this information for marketing purposes (e.g. send you information about a contest or a product).

We collect your personal data and your contact details, when you participate in contests. We may collect this information from your social media profile, if you participate in the contest through a social media platform, or from another source if the contest is not hosted on a social media platform. We will process this information in order to run the contest and communicate with the winner. Then we will erase your data.

Where route67.gr obtains from its customers their e-mail address, in the context of the sale of a product or a service, we may use these e-mail address for direct marketing of our similar products or services. We give you the opportunity to object, free of charge and in an easy way, to such use of your e-mail address, on each message, in case you have not initially refused such use.

Furthermore, route67.gr may process your e-mail to send you Newsletters on the basis of your consent. In this case, we will store your personal data for as long as you wish to receive Newsletters from us. Newsletters are free of charge e-mails with advertising content, promotions, events, discounts, special offers, contests etc. We will also send you Newsletters, after you have  purchased a product from our e-shop (soft-opt in). You may unsubscribe from our mail list at any time.

We may also process your personal data, if processing is necessary for the purposes of the legitimate interests pursued by the controller (statistical analysis, market research, security reasons), or for direct marketing. Any processing of your Personal Data in this context will be carried out in accordance with the GDPR and the applicable Greek Law.

We store your previous orders for your convenience. You can find them by logging in your account. We will store these data for as long as you retain your account.

We will collect and process your declaration of withdrawal. The withdrawal forms will be retained without any time limitation in order to check whether you are abusively exercising your right to our Company.

The Company cooperates with advertising / promotional companies, statistical analysis companies, suppliers and service providers who process personal data on our behalf. We disclose to our partners your personal data, solely for the processing purposes referred to in this Policy.

Our site and third parties (e.g. Shopify) may store cookies on your device. In particular, we use cookies and other similar technologies (analytics) for statistical analysis, marketing and other purposes. We also use functionality Cookies. For more information (e.g. retention period) read the Cookie Policy.

We collect and process your personal data only for legal purposes, as the above mentioned. We may process your personal data for purposes other than those for which your personal data were initially collected, only where the processing is compatible with the purposes for which your personal data were initially collected. E.g. we may contact you via e-mail to inform you about the Website’ s function. We may also process your personal data, if processing is necessary for compliance with a legal obligation to which route67.gr is subject.

The time that your Personal Data may be retained by route67.gr is also determined by our legal obligations in the applicable Legislation (tax etc.). If you have not fulfilled any payment obligations, or if there is a dispute, pursuant to our contract, we may keep your personal data for as long as it is allowed under the provisions of Greek laws.

PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA – CHILDREN’ S DATA

We do not collect or process special categories of Data. You shall refrain from sending to the Company special categories of Data. The Company shall not be liable for any damage incurred to you or a third party due to an illegal act or omission performed by you, regarding special categories of Data.

Only adults can use the Website’ s services. Therefore, we do not collect or process children’s Data. The Company will erase any children’s Data that you disclose to us through the Website. The Company shall not be liable for any and all damages arising from any use of the Website by a child.

CONSENT

We may ask you to give your consent to the processing of personal data relating to you. This may include ticking a box while browsing through different webpages of the Website. Ticking that box, is a clear affirmative action, which is considered as a freely given, specific, informed and unambiguous indication of your agreement to the processing of your personal data for the above-mentioned purposes. You may withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before your withdrawal.

We will provide you all the information you need to express your prior agreement (consent) to the processing of personal data relating to you, if processing is based on your consent.

We will keep your e-mail address to a separate “unsubscribe list” in case you withdraw your consent for receiving Newsletters from our Company.

If you refuse to disclose your Personal Data to our Company, we will not be able to provide you with our products / services.

RECIPIENTS & PROCESSORS

We may need to disclose your Personal Data to authorized recipients for (i) the maintenance / repair of our equipment (PCs, servers, hardware) that support the operation of the Website, and (ii) the development of the Website.

Where processing is to be carried out on behalf of the Company, we use only processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the GDPR and ensure the protection of your rights.

TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY

A transfer of personal data to a third country may take place where the Commission has decided that the third country ensures an adequate level of protection. We may transfer your data to companies that are certified in the US under the Privacy Shield. In the absence of a decision we may transfer personal data to a third country only if the processor has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Otherwise we will transfer your data to a third country only under GDPR conditions (data subject’ s consent, contract, vital interests etc.).

YOUR RIGHTS

At route67.gr we protect your personal data and we always respect your rights and freedoms.

As Data Subject you have the right to be informed on the processing of your personal data, the right of access to your personal data and to information relevant to processing, the right of rectification of your personal data , the right to erasure of your personal data, the right to restriction of processing, the right to data portability, the right to object to the processing of your personal data, the right not to be subject to a decision based solely on automated processing, including profiling and the right to withdraw your consent at any time.

To be informed about or exercise the above rights, you need to apply by writing to the Company named “AFOI SARAKINIOTI UNLIMITED COMPANY”, with registered offices in the Municipality of Athens Attica Greece, 67, Adrianou Str., P.C. 10556, or via e-mail: route67.privacy@gmail.com). We are ready to handle your request with respect to your rights. Otherwise, you could lodge a complaint to a supervisory authority (www.dpa.gr), if the Data Controller does not take action on your request.

We take all efforts to facilitate the exercise of Data Subjects’ rights. We will not refuse to act on any request of yours for exercising your rights, which are described above, unless we are not in a position to identify the Data Subject.

We will respond in writing to such requests from you, without undue delay and in any event within one month of receipt of your request. In this case we will provide you with information on action taken on behalf of your request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

We will communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

Otherwise, if we do not intend to act on your request, we will inform you without delay and at the latest within one month of receipt of the request, of the reasons for not taking action.

Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the Company may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or (b) refuse to act on the request.

STORAGE & SECURITY OF PERSONAL DATA

Some personal data collected through www.route67.gr, are stored at Google Data Center (google analytics) & to the Company’s data center in Greece, to which only the Company has access. Access is also monitored with firewall technology. Your personal data are mainly stored at Shopify’s data center.

Google’ s Privacy Policy: https://www.google.com/intl/en/policies/privacy/.

Your Personal data are generally kept in electronic form. We may also keep in a physical record documents containing personal data when necessary (tax information, contracts, original forms of withdrawal, etc.). We keep backup of your information.

Our Company shall not be liable for any damage caused by risks appearing in online systems of Banks, entities advertised in this website or collaborating courier companies etc., even if users are referred to said websites by hyperlinks, banners etc. placed on route67.gr. Liability for the content, information, visitors’ safety and protection of their personal data, and the quality of services provided is born solely by owners, managers and administrators of said websites, which users visit at their own risk.

DISPUTE RESOLUTION

In case of controversy or claim of any nature regarding the process of your personal data and the context of this Privacy Policy, applicable law is the law of the Greek state. For all actions or legal procedures, the Courts of Athens will be in charge.

UPDATES TO OUR PRIVACY POLICY

Route67.gr reserves the right to amend this Privacy policy. Any changes will be post in this link. You should periodically check whether changes have been made. In case you disagree with the Privacy Policy, you must refrain from any action, interaction, access and use of this Website.