Our Company’s Services are addressed to persons who have reached the age of 16 years. Any personal data of children we may collect due to the subject of our Services (i.e. physical and online children’s clothing stores) must be completed/communicated only by the person having the parental responsibility of the child.
2. WHAT PERSONAL DATA DO WE COLLECT AND FROM WHERE
We only collect the absolutely necessary personal data from you, which is appropriate and clear for the individual purpose it serves. Specifically, we collect:
1.1. Your identification data: full name, father’s name, TIN, etc. We collect this data directly from you.
1.2. Your communication data: post and e-mail address, fixed and mobile phone, etc. We collect this data directly from you.
1.3. Data from the conclusion and operation of the contract for the provision of the privilege card and the use of the services provided to you, which you communicate to us by completing the relevant forms.
1.4. Data from your participation in contests organized by our Company and which you communicate to us when you enrol in the contest.
1.5. Records of conversations and communications after your prior notification, in accordance with the legal requirements. For example, in the event of a telephone communication with our store’s customer service department, your call may be recorded after you have been informed by an audio message.
1.6. Image elements from the video recording systems at the company’s premises, which have the legally required markings. For example, when you visit one of our physical stores, your image may be recorded on the CCTV.
1.7. Invoicing details. We collect our customers’ details that are necessary for the pricing of our services, such as the home address or company address, car registration number, TIN and tax office name.
1.8. Details from social media. If you choose to gain access or connect to a Service of the Company through a social media service or if you link a Service of the Company to a social media service, the data we collect may also include your user ID and/or username associated with this social media service, the information or content that you have allowed the social media service to communicate to us, as well as your profile picture, your email address or your friends’ lists, along with the personal information you have published in relation to the particular social media service.
1.10. Data from your communication with our physical stores. In order to offer you the best and most comprehensive service, we may record details relating to complaints or comments you make, your preferences regarding our merchandise, etc., which you indicate during your visit to our physical stores.
1.11. Educational Data. If you fill out a relevant application and/or send a CV for a job vacancy with our Company, we may process your educational data relating to studies, skills, foreign language knowledge, professional experience, etc.
3. HOW AND WHY WE PROCESS YOUR PERSONAL DATA
We process your personal data via electronic as well as non-automated means, considering for their protection the latest technology, the cost of implementation and the scope, nature, context and purpose of the processing, as well as the severity of the potential risk as regards the rights and freedoms of persons. Specifically, the Company has established and employs appropriate administrative, technical measures, measures relating to its employees as well as physical measures aimed at protecting the personal data in its possession from potential loss, theft and unauthorized use, disclosure or modification.
Specifically, we process your personal data for the following purposes:
– To realize and manage the sales of our products and/or services and the general fulfilment of our contractual obligations to you. For example, we use your personal data in order to fulfil your order and deliver the products you have purchased to your chosen address, to implement a product return, to inform you of any debts to the Company, etc.
– To send—depending on your choice and after your relevant consent—via electronic (email, SMS, Viber, social media, telephone, etc.) and/or traditional means (post office etc.), updates, offers, promotions, organizational and/or commercial information, newsletters, advertising material as well as other announcements regarding our services and products.
– To control, analyse and improve our services and products by conducting customer satisfaction surveys.
– To offer you customized communication and service (“profiling”) improving your experience as to both our physical and online stores.
– To give you the opportunity to participate in games, contests, reward programs as well as other events that may interest you and which we organize either online or at our physical stores.
– To provide you with comprehensive customer service, by giving you the opportunity to send us, either orally or via electronic means, any comments and observations you may have, and to respond to your submitted queries/requests.
– To protect the rights and assets of the Company and of third parties. For example, we monitor the browsing activity at our online store in order to locate and timely resolve any problems and to ensure the integrity of our website and the protection of your account, or respectively, in the event of criminal activity within our Company’s premises, we may process the data resulting from our video recording systems in order to protect our customers, employees and partners from illegal actions.
– In order to comply with applicable legislation or legal procedures and/or to respond to any requests by competent government authorities.
– To evaluate any applications and CVs you send regarding job vacancies at our Company.
4. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA
The legal basis for the processing of your personal data by the Company may be:
1. The performance of the contract. In this case, our processing of the particular personal data is a necessary condition of the contract between us, as this data is a prerequisite for the conclusion, operation and performance of the contract between us.
2. Your consent. The processing of your personal data for marketing and/or advertising purposes and/or profiling is at your discretion. In all these cases, you can withdraw your consent at any time.
3. The legal obligation of the Company. The Company may be bound by law to process certain personal data (e.g. tax legislation). In this case, the provision of such personal data is necessary, as it will otherwise be impossible to provide the Company’s Services.
4. Legitimate interest of the Company. In certain cases, we collect your personal data in a way that is reasonably expected, as part of the operation of our enterprise, and that does not substantially affect your rights, your freedom or your interests.
5. IS THE CONCESSION OF YOUR DATA OBLIGATORY?
The provision of personal data is in no way obligatory.
Depending on the respective legal basis of the processing, the concession of your personal data to the Company may be necessary for achieving the purposes determined herein, or optional.
In any case, we shall indicate the obligatory nature of the concession of personal data with an asterisk (*) next to the obligatory data.
The provision of additional personal data to the Company, beyond those noted as obligatory, is optional and does not affect the main purposes of data collection, but its concession serves to improve the quality of the provided services.
6. WHO HAS ACCESS TO YOUR PERSONAL DATA
We limit access to your personal data to the absolutely necessary Company personnel, which has been trained and is committed to maintaining its confidentiality.
In addition, to fulfil the above purposes for the processing of your personal data, the Company may disclose or transmit personal data:
1. To third-party service providers which, in cooperation with the Company, assist in the proper provision of Services, such as technology service providers for the protection and security of our electronic systems, advertising companies, customer satisfaction surveying companies, logistics, transport, order management service providers, etc.
2. To associated companies in their capacity as data controllers or data processors.
3. To the competent authorities for the purposes of compliance with applicable laws.
In the above two cases, the Company remains responsible for the processing of your personal data and sets out the individual details of the processing and signs a special contract with the third parties to which it entrusts the processing activities, in order to ensure that the processing is carried out in accordance with the current legislative framework and that any natural person may freely and without hindrance exercise the rights offered by the applicable legislative framework.
7. IS YOUR PERSONAL DATA TRANSFERRED ABROAD?
The personal data we process in order to provide our Services is stored in Greece.
However, some of the recipients of the personal data with which the Company shares your personal data in the context of the above paragraph 6 may be located in other countries outside Greece and the European Economic Area (hereinafter “EEA”). Legislation in such countries may not provide the same level of data protection. Therefore, in the case of data transfers from the EEA to countries not considered safe by the European Commission, we have established suitable and appropriate safeguards with the purpose of protecting your personal data and their transfer, in accordance with applicable data protection laws, such as standard contractual clauses approved by the European Commission, according to Articles 45 and 46 of the General Data Protection Regulation (EU) 2016/679.
8. HOW LONG DO WE MAINTAIN YOUR DATA
The Company undertakes to maintain, with absolute confidentiality, the record of personal data you have provided in your registration on our website or at our physical stores, as well as your transaction history at the www.lapinkids.com online store and only for the purposes of processing those mentioned above.
The data storage period is decided based on the following specific criteria, as appropriate:
• When processing is required as an obligation under the provisions of the applicable legislative framework, your personal data will be stored for as long as required by the relevant provisions.
• When processing is performed based on a contract, your personal data will be stored for as long as necessary for the performance of the contract and for the establishment, exercise, and/or support of legal claims based on the contract.
• For various marketing activities, your personal data is maintained until your consent is withdrawn. You may exercise this right at any time. The withdrawal of your consent does not affect the legitimacy of the processing based on your consent during the period before it was withdrawn. We will also store the data of the account you have created on our website for as long as you maintain it and have not requested its deletion. Where necessary, in order to comply with legal or regulatory requirements, to resolve disputes, prevent fraud and abuse, or impose the terms and conditions for access to this website, we may keep your data stored as needed even after deletion of your account.
To withdraw your consent, please contact the company’s Data Protection Officer (DPO).
9. WHAT ARE YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
You may exercise the following rights at any time:
1. Right to access your personal data. You have the right to be informed if we are processing your personal data. If we are processing your personal data, you may ask to be informed about the purpose of the processing, the type of data we maintain, who we give it to, how long we store it for, whether automated decision making is carried out, as well as about your other rights.
2. Right to rectify your inaccurate personal data. If you find that there is an error in your personal data, you may apply for its correction (e.g. correcting a telephone number or updating a changed address).
3. Right to erasure (“right to be forgotten”). You may ask us to delete your data if it is no longer necessary for the above-mentioned processing purposes or if you wish to withdraw your consent in the event that this is the only legal basis.
4. Right to the portability of your personal data. You may ask to receive the personal data you have provided in a readable form or ask us to forward it to another data controller.
5. Right to restrict processing of personal data. You may ask us to restrict the processing of your personal data for as long as the consideration of your processing objection is pending.
6. Right to object and withdraw consent to the processing of your personal data. You may object to the processing of your personal data and we will stop processing it, unless there are other compelling and legitimate grounds that override your right. If you have stated your consent to the collection, processing and use of your personal data, you may withdraw your consent at any time with future effect.
Lastly, you have the right to lodge a complaint with the competent Greek Independent Authority, which is the Data Protection Authority (http://www.dpa.gr, address 1-3 Kifisias Av., Postcode 115 23 Athens, Tel. 210. 6475600, email: [email protected]).
10. HOW CAN YOU EXERCISE YOUR RIGHTS
In order to exercise any of your rights, you may submit a relevant request to the Data Protection Officer of our Company at its headquarters (ST. PAPAIOANNOU S.A., 4 Styl. Gonata St. – Peristeri, Attica, Postcode 121 31) or to the email address ([email protected]) titled “Exercise of Right” and we will make sure to review it and reply as soon as possible.
A request is not required in cases where:
– you wish to correct the personal data of your user account on our e-shop, so that you may log in and make any corrections/changes.
– you wish to withdraw your consent from receiving a newsletter, in which case you may do so by selecting the link “To unsubscribe from the newsletter mailing list, click here” at the bottom of each newsletter.
– you wish to stop receiving web push notifications from the Company, in which case you may disable the setting from your browser.
12. CONTACT US