In ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. we aim to protect and safeguard the privacy of the information provided to us, always respecting the trust of our customers and users of the site.

We have always complied with current National and European legislation on Privacy and we have implemented a series of actions to be fully compliant with the European Union’s new General Personal Data Protection Policy (GDPR). Please read the following Privacy Policy and Personal Data Protection Policy.

The current Privacy Policy establishes the processing procedure of all the personal data we collect from you or is provided to us by you. We keep some basic information when you visit our site and we acknowledge the importance of keeping this information safe and informing you of how we intend to use it.

Please read this Policy to learn more about how we collect, store, use, transmit and protect the personal data and information we receive. Also, learn about your rights in this collection and processing, how you can exercise those rights and how you can contact us for further information.

1. Principles concerning Data Processing
2. Legality of Processing
3. Minors
4. Collection and Use of Personal Data
5. Transfer of Personal Data to Third Parties
6. Rights and Exercise of the Rights
7. Connection with other websites
8. Provision of Professional Services
9. Changes to Private Policy regarding Personal Data
10. Contact

Principles concerning Data Processing

a) Legality and Transparency

All the personal data collected are subject to lawful and legal processing, always in accordance with current legislation and in transparent order respecting the information we collect about you.

b) Purpose Limitation and Data Minimization

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. collects your personal data for specified, explicit, and legitimate purposes and they are not further processed in any manner inconsistent with its purposes. In addition, only the relevant and necessary data are collected to the extent that they are being processed. That is, the information and data you share with us are not subject to further unlawful processing unless there are reasons of public interest.

c) Accuracy

Your personal data is accurate and updated when necessary. ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. takes every reasonable measure regarding the prompt deletion or personal data correction, through both the available form and email, as explained below.

d) Reduction of Personal Data Retention Time

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. retains your personal data only for the time required for the purpose of processing it or complying with each individual’s request or until each individual wishes to be deleted (in any case no further than three months, unless they are stored abiding by the current legislation provisions).

e) Integrity, Confidentiality and Data Security

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. implements the appropriate security policy and all the necessary measures to ensure that your personal data is securely processed including the protection against unauthorized or unlawful processing and accidental loss, destruction or deterioration, using appropriate technical and organizational measures.

Despite ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. efforts, potential threats cannot be totally eliminated. In the unfortunate event of loss or violation of personal data, our team of specialists of such incidents will address the issue and a procedure will immediately be put in effect to restore the violation and the possible effects of such actions while abiding by law at the same time.

Every effort is made to ensure that access to your personal data is limited to those entitled to it. People who have access to the data are required to keep the data confidential. In the event of a violation of your personal data, you will be immediately notified through any available means.

Legality of Processing

For the lawful processing of your personal data and information, certain conditions must be met. ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε., always in accordance with Greek and European legislation, collects only the necessary personal data, in compliance with the above legal requirements, which are the following;

a) Consent:

For the processing of data provided to us, we must have your consent by accepting the terms of use and our current privacy policy, the use of cookies. We may occasionally require special permission to process some of your personal data, and they will only be processed in this way if you agree to that. Your consent may be withdrawn at any given time by either filling out the “Personal Data Protection Application” which enables you to withdraw your request at any time concerning the processing of any personal data as well as the export, correction, or deletion of your personal data, kept by us, or by contacting ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. at info@fragoulis.com.gr.

Generally, you are not to submit any personal data in ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. online, however you may be asked to provide some personal data in order to receive supplementary information concerning our services and other events. ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. may request your permission for specific use of your personal data and you can either accept or decline such use. If you consent to certain services or updates, like newsletters, you will be able to unsubscribe from the recipient list at any time following the instructions provided every time. Should you decide to unsubscribe from a service or communication, we will try to delete your data as soon as possible, although we may need some time and / or information before we can process your request.

b) Execution of contract:

this is the case when processing your personal data is necessary for the fulfillment of our contractual obligations when you are a contracting party or upon your request prior to the contract.

c) Legal Obligation:

this is the case when we are forced to process your data complying to our legal obligations, such as keeping records for tax purposes, or providing information to public sector or law enforcement authorities.

d) Vested Interest:

we might process your data when we have vested interest during the execution of legal activities so that continuation of the activity is ensured provided that your interests are not surpassed.

e) Public Interest:

more often than not data processing is mandatory due to obligations towards public interest or public authority exercise.

Minors

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. is fully aware of the importance concerning the protection of minors’ personal data, especially in an online environment. If a minor who consents to the processing of his/her personal data is 16 years old, then the processing is in accordance with law. If the minor is below 16 years old, the processing is lawful only if and to the extent that such consent is granted or approved by the person having parental responsibility for the child.

Collection and Use of Personal Data

4.1 Which data is collected

Your personal data is received if you choose to provide them (for example, if you contact us through emails or subscribe for certain services). In certain cases, you may have already provided ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. with your Personal Data. Upon registering and / or submitting your personal data to ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε., you also consent to the use of this data in accordance with this Statement. Your personal data are not used for other purposes, unless we are granted permission, or unless it is required or allowed by law or by professional standards.

For instance, if you register in ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. website and provide information about your preferences, such information will be used to customize your user experience.

When you sign up or log in using a third-party subscription service, we may identify you as the same user regardless of the use of different devices and customize your user experience in any other ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. websites you may visit. If we receive your resume (CV) as an online application for a post at ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε., the information provided will be used to see if you meet the requirements of ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε.‘s existing job opportunities.

In the event that you register for certain services, your email address may temporarily be stored until we receive confirmation of the information you provided through your email (that is you will receive an email in the email address you provided through the registration process in order to confirm your registration request).

4.2 Automated collection of Personal Data

In some cases, ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. and its service providers use cookies and other technologies to automatically collect certain categories of data when you visit us online, as well as through emails we might exchange. Such data collection enables us to customize your online experience, to improve the performance, utility and effectiveness of ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε.‘s online presence and to evaluate the effectiveness of the marketing activities of our services.

4.2.1 IP Addresses

The IP address is a number assigned to your computer every time you access the internet. It allows computers and servers to recognize identity and communicate with each other. Visitors’ IP addresses may be recorded for security of information technology and system diagnostics. These data may be used collectively in order to analyze the trends and performance of the site.

4.2.2 Cookies

Cookies may be placed on your computer or on your online device every time you visit us online. This allows our website to recognize your computer or device and serve multiple purposes.

A banner will appear on our site which will require your consent to the collection of cookies. If you do not consent, your computer or your Internet-enabled device will not be tracked for promotional purposes.

A secondary type of cookies may be required to ensure the necessary functionality. These cookies will not be blocked by using the warning banner.

Your selection will be stored in a cookie and will apply for a period of 365 days. If you wish to recall your selection, you may do so by deleting your browser cookies.

Although most browsers automatically accept cookies, you can select to accept or not cookies through your browser settings (often found in your browser’s Tools or Preferences menu).

You can also delete cookies from your device at any time.

However, you must be aware that if you do not accept cookies, you may not be able to fully become acquainted with some of our site’s features and that some parts of our site may not be able to function properly.

More information on how cookies can be managed can be found in your browser’s “Help” folder or via web pages such as www.allaboutcookies.org.

Other third-party tools and widgets may be used on our site to provide additional functionality. Using such tools or widgets may install a cookie in your device to make their service easier to use, and to ensure that your activity is correctly displayed on our websites.

Cookies per se do not disclose your email address to us or personally identify you in any other way. In our detailed reports, we may receive identification information, including IP addresses, but only to identify the number of individual visitors to our web pages and the geographical origin of the visitors, and not to identify individual visitors.

By browsing our site and entering your login information to access areas only for registered users, you agree that cookies can be placed on your computer or on your Internet-enabled device.

4.2.2.1 Types of cookies

The basic types of cookies used by websites are listed below;

• Session Cookies

These are temporary cookies that remain in the cookie file of your device’s browser only during your visit and are deleted when you close the browser.

• Persistent Cookies

These remain in the cookie file of your device’s browser even after the browser closes, sometimes for one year or more (the exact length depends on the lifetime of each cookie). Persistent cookies are used when the website administrator may need to know who you are for more than one visit (e.g., to remember your username or your site preferences)

• First-party cookies

These are cookies installed on the browser and / or hard drive of your device by the site you are visiting. This includes assigning a unique identifier to you in order to monitor your navigation through the site. Website administrators often use first-party cookies for the management of visits and for identification purposes.

• Third-party cookies

These are cookies used by third parties, for instance social networks; to monitor your visits to the various websites they are advertised. The website administrator has no control over these third-party cookies.

4.2.2.2 Cookies by video service providers (Google, Vimeo, DailyMotion etc)

These providers may place cookies on your device if you watch videos on our site provided by them as an external service. If you turn these cookies off, you might not be able to watch our site’s embedded videos.

4.2.3 Google Analytics

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. uses Google Analytics. You can find more information regarding the use of Google Analytics by ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. in: http://www.google.com/analytics/learn/privacy.html

In order to provide website visitors with more choices about how their data is collected from Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. Add-on communicates with Google Analytics JavaScript (ga.js) to show that the information about visiting the website should not be sent to Google Analytics. Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the site itself or other webanalytics services.

4.2.4 Geographic Location Tools

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. may collect and use the location of your computer or portable device. These location data are collected so as to provide you with information regarding services we think might be of interest based on your geographic location, improving at the same time the products and services delivered based on geographic location.

4.3 Social networking applications and widgets

The ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. website may enable you to share through third-party social networking applications such as the Facebook Like button and the Twitter widget. These social networking applications can collect and use information regarding your use of the ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. websites (see details above regarding “Social Networking” cookies). Any personal information you provide through such social networking applications can be collected and used by other members of the respective social networking application, and these exchanges are governed by the privacy policies of the implementing companies. We have no control or responsibility over these companies or as to how they use your information.

In addition, our website can host blogs, forums, crowd-sourcing and other applications or services (collectively referred to as “social networking features”). The purpose of the social networking function is to facilitate the exchange of information and content. Any personal information you provide through ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε.’s social media may be shared with other users of the respective social media (unless otherwise stated during the collection stage), over which we may have limited or no control at all.

Publishing third-party’s personal data (pictures etc) through ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. website is illegal, unless prior consent was obtained by the third party in question.

4.4 Data collected during your registration

When you sign up for our site, we ask you to provide us with some information about you.

This information may include:

• Personal data such as name, address, email address, telephone number and other contact information. These data are collected when purchasing a product from our stores or upon your first subscription to our online services, e.g. when you do a market research, comment on social media pages (Facebook, Twitter, YouTube), you enter a competition and more.
• Account information, such as usernames and other identifiers or information used to access our online services.
• Purchase, order and “Bag” records, when you purchase a product or add it to your shopping cart without finalizing your order, we keep this data to help you with future purchases.
• Device information.
• IP address and Cookies data.
• Location.

Cases where we ask you to provide us with your personal information:

• When purchasing products in our stores or through a call center.
• When you sign up to use our online services.
• When you request to receive updates on marketing promotions.
• When you participate in one of our offers.
• When you make requests.

Transfer of Personal Data to Third Parties

We do not share personal data with third parties who are not affiliated with us unless it is a prerequisite for our legitimate business and business needs in order to meet your requests and / or if required by law or professional standards.

This includes the following third parts:

• External service providers: Where appropriate, we will outsource other companies and individuals to perform certain tasks that contribute to our services on our behalf in the context of data processing contracts. We may, for instance, provide personal data to partners to host our databases and applications, to provide data processing services, or to send you the requested information, or call centers to provide support or interview services during market research projects. All ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. partners are fully compliant with the GDPR and are contractually bound to abide by it. ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. transfers personal data to them only when they meet our strict data processing and security standards. We only disclose personal information that enables them to provide their services.
• Business transfer: In the event of reorganization, restructuring, merger, sale or other transfer of assets, we will transfer data, including personal data, to a reasonable extent, provided that the recipient agrees to respect your personal data in accordance with the current data protection laws. We will continue to ensure the confidentiality of any personal data and will inform you when your personal data is subject to a different privacy policy.
• Courts, judicial authorities or regulatory agency: ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. may disclose personal data in response to requests from courts, judicial, governmental or police authorities, or where it is necessary and prudent to comply with current legislation, court orders or court rulings.
• Public Sector: ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. may disclose personal data during public bodies and authorities’ audits regarding personal data protection, security, tax audits.

Υour personal information may be shared with the following recipients, just to cite a few examples:

• MANBIZ ISP
• Google
• Mailchimp
• Facebook
• Hetzner
• Hotjar

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. may also transfer certain personal data outside the EEA (European Economic Area) to external companies that work with us or on our behalf for the purposes described in this Privacy Statement. ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. may also store personal data outside the EEA. In such an event, your personal data will continue to be protected by contracts we have with organizations outside the EEA, which are approved by the European Commission. By providing personal data over the Internet, visitors consent to this transfer and / or the storage of their personal data abroad.

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. will not transfer the personal data you provide to any third party for their own direct use for marketing purposes.

Rights and Exercise of Rights

If you have submitted personal data in ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. you have the rights as explained below:

• Accessibility: you have the right to access and export your personal data. Before we provide you with personal information, we may request proof of your identity and sufficient information about your transactions with us from which we can identify your personal data.
• Correction: if your data is inaccurate, you can correct them by processing your profile, under the “Application for Personal Data Management” or alternatively ask us to correct any possible inaccuracies.
• Dissent and restriction of processing: you have the right to dissent our processing of your personal data, if we no longer have the right to use them, for any legal purpose or you can request to restrict the processing in certain circumstances, such as data accuracy and legitimacy reasons.
• Data portability: At your request, we will transfer your data to another controller, where technically feasible, provided the processing is based on your consent or is necessary for the performance of the contract.
• Erasure: You have the right to request the erasure of your data in some cases, such as when they are no longer required for processing or are in our records for a long time.

You can exercise the aforementioned rights by filling in the “Personal Data Protection Application” in which you may at any time request the export, correction or erasure of your personal data kept by us.

You may also submit a request or exercise these rights by contacting us at info@fragoulis.com.gr and we will make every reasonable effort to comply with your request if this is in accordance with the applicable law and professional standards.

Connection with other websites

The ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. website may contain links to other websites for your own convenience and information. These websites operate independently of ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. and therefore we have no control over them and we cannot be held responsible for any illegal processing of your personal data. They may have their own Privacy Policy, which you are encouraged to read if you follow a link to other sites before disclosing any personal data.

Provision of Professional Services

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. receives personal data when providing professional services – usually when providing services to individuals, employers, businesses with natural persons as clients and the public sector.

Our relationships with customers are governed by our cooperation letters and general terms of trade, including the use of personal data we receive. ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. provides services of various types and its role may not always be clear to the data subjects. However, ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. complies with its obligations under current Greek and European legislation on the protection of personal data, as in force, and the applicable regulatory guidelines relating to the management of personal data.

Changes to Private Policy regarding Personal Data

ΦΡΑΓΚΟΥΛΗΣ Κ ΣΙΑ Ε.Ε. may periodically modify this Policy to make it comply with national and Community law and reflect our recent Privacy Policy practices. In the event of such changes, we will record the date of the modification or revision at the end of this page and we will notify you of the changes whenever necessary.

Contact

If you have any questions, comments or complaints about managing or protecting your personal data or if you wish to modify your personal data or exercise any of your rights as a data subject, please contact us at info@fragoulis.com.gr.

This policy was last reviewed on May 23, 2018 and is in force since May 23, 2018.