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Privacy Policy


PRIVACY POLICY


This Privacy Policy contains the information that dictates the handling of the personal data of users (hereinafter the ‘User’) who access and use the website www.dimitrios-exclusive.com (‘the Website’) to consult it or to order the products on sale (“Products”).


DIMITRIOS EXCLUSIVE Inc (“www.dimitrios-exclusive.com”) is registered on the Companies Register of the Athens Chamber of Commerce, with legal head office in Athens, 52 Kyprou Ave., Peristeri 121 32, Greece, under Company Reg. n. 085978602000.


This Privacy Policy is to be considered  in addition to the Terms and Conditions of Sale and Use of the www.dimitrios-exclusive.com website.


The information contained in the Privacy Policy are in compliance with the article 13 of the General Data Protection Regulation N° 2016/679 (“GDPR”) to all Users who access and use the Website and/or purchase Products on the Website. This Policy refers solely to the use of the Dimitrios-exclusive.com website and to no other third-party website, even if it is in some way mentioned and\or linked within the Dimitrios-exclusive website. 


Any changes will take effect immediately and will only apply to Members using the Site after the change. Therefore, we invite you to refer to it on each visit to our Site, to read its latest version permanently available on the Site.


Version of May 16, 2019


DEFINITION OF DATA

” Personal Data ” or ” Data”: means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, identification number, location data, online identifier, or one or more elements specific to his physical, physiological, genetic, psychic, economic, cultural or social identity. Thus, the data we collect may include your strictly personal data, in that it makes it possible to identify you as a particular person. Conversely, some data does not allow us to identify you directly, such as your profession or your browsing data (the type of browser, Terminal and operating system, the path followed on the Site, etc.) but is still considered as Personal Data as it is attached and/or attachable to the first;


1. Purpose for which we process Data

Data provided by Users when registering with the Website or subscribing to the Website’s newsletter and when submitting each order, will be used for purposes strictly relevant to the purpose indicated by DIMITRIOS-EXCLUSIVE when the data itself is provided. More precisely, for sending the newsletter and/or for fulfilling an order and all the services connected to this such as, for example, communication and shipping. 

The personal data of Users will also be used by DIMITRIOS-EXCLUIVE and by authorized third parties to fulfil all accounting and tax obligations related to the purchase of Products and to complete all activities directly related and preparatory to the management of Website-Client relations.

We used your Data to perform operations relating to our commercial relationship, i.e. concerning your registration to the Services (in particular verifying the veracity of your email), Orders, deliveries, invoices, accounting, monitoring of the ” customer relationship ” with a Member, such as conducting satisfaction surveys, claims and after-sales service management, refunds, specific commercial gestures, returning Orders, exercising your right of withdrawal, and  the management of non-payments and litigation.


In the event that the User has expressed their consent, their personal data may be used for other purposes related to the sale of products on the Website:

i) sending promotions, offers and suggestions of products on sale;

ii) verification of customer satisfaction;

iii) sending promotional and/or publicity material relative to other activities by Dimitrios-exclusive.com and its Partners;

iv) complete market surveys and post-sale analyses;


v) offer you commercial offers close to your geographical location, especially in the context of offers through the “In-store collection” service;

vi) the management of your comments on the Website and/or on the web pages published by us and hosted on the websites of our Social Networks.


Method of handling

All User information collected will be handled exclusively and with due expertise by individuals specifically employed for this task and specifically trained in the matter. The purposes of Data handling are those for which the Data was collected, principally with electronic and digital tools.

The Data will be recorded in digital and paper formats, as well as in any other format considered appropriate and with respect to security measures dictated by applicable regulation.

The Data is preserved in such a way as to minimize the time necessary to identify the User in order to achieve the objectives for which it was collected and then handled and, in every way, always conforming to the prescriptions of the law. 

Any damages caused by causes not directly attributable to Dimitrios-exclusive.com, such as inaccessibility of the Website, or viruses, damaged files, interruption of internet or telephone connections, or other causes similar to the cases listed above, are not attributable to Dimitrios-exclusive.com.

Furthermore, the User is bound to diligently and responsibly preserve all the personal information directly related to the Website, such as, for example, log-in details for the Website, any order numbers, shipping numbers or other data. Any misappropriation or improper use of this data, and the consequences derived from this event, are the full responsibility of the User.


3. Nature of acquisition of data

The Personal Data requested by Dimitrios-exclusive.com during use of the Website may be mandatory or optional.

If the User does not consent to provide mandatory Personal Data will not allow the perform of the services for which the Data was requested. 

The compilation of optional Data, however, is completely subject to the discretion of the User who may choose to provide it or not. In this case, the refusal will bear no consequence on the carrying out of the purpose indicated when the information is requested. 

The User is also responsible for keeping this data updated, so that Dimitrios-exclusive.com may carry out all its services effectively and efficiently without incurring lateness, errors or additional costs due to the lack of up-to-date Data. 

Dimitrios-exclusive.com collects the Data that you voluntarily provide it with from a collection form on the Site, in particular at the time of your registration as a Member or of an Order, including socio-professional information (your profile, i.e. your surname, common name, first names, gender, date of birth, sponsor and/or sponsors, delivery address, profession, for example).

During an Order, our banking providers also collect and process Personal Data concerning your means of payment (credit card number, expiry date of the credit card, visual cryptogram, which is not kept, etc.). As for us, we process the partial number of your bank card consisting of the first six (6) and last four (4) numbers and the expiry date of your credit card as transmitted by your bank. 


We also collect information about the transaction (transaction number, purchase details, etc.), or the payment of invoices issued from or via the Site (payment terms, discounts, receipts, balances and unpaid amounts, or relating to loans taken out, amount and duration, name of the lender, etc.).


Some Data is mandatory and some optional, as indicated in the collection form on our Site.

Dimitrios-exclusive.com collects and/or receives from its Partners and processes Data relating to the monitoring of the commercial relation with you: product and/or service purchased, service or subscription purchased, quantity, amount, periodicity, delivery and/or billing address(es), telephone number, Digi code, as well as any other relevant delivery information (tracking numbers, shipment status, etc.), history of purchases and services, product returns, correspondence and/or telephone exchanges with you and our after-sales service, Members’ exchanges and comments, person(s) in charge of the customer relation, etc.


4. Communication of Data

The communication of the User’s personal Data to third parties will only take place in accordance with applicable laws and for the purposes listed in this privacy policy. Third parties involved fall under the following categories:

i) those handling warehouse, packaging, shipping, delivery and returns services of the products.

ii) the individuals employed by Dimitrios-exclusive.com for the administrative, contractual, accounting and legal management of the Website’s activities

iii) credit and insurance institutions and the company employed to manage payments, including electronic payments

iv) the individuals employed in the management and maintenance of the Website and all its functions

vi) any other individuals to which Dimitrios-exclusive.com has given the ability to access the data, always with respect to the dispositions of law and to regulations.


v) to related company, subsidiaries, branches or associated offices 

Finally, the User’s personal Data may be used for contests and/or participation in prizes, for sending publicity and promotional material relating to the Website and Partners of Dimitrios-exclusive.com, only with the prior, explicit and voluntary consent expressed by the User.


5. Consent to handling

In the event that data handling receives the explicit and voluntary consent of the User, it will be collected in a specific manner with an explanation of the individual purposes pursued.  

Specifically, article 6 GDPR provides for cases in which the handling of data does not request the express authorization of the User, such as, for example, for fulfilling legal or contractual obligations undertaken toward the User.


6. Rights of interested parties

In accordance with the Personal Data Regulations, User (“You”)  have the following Specific Rights:

–         access (Article 15 of the GDPR),

–         rectification (Article 16 of the GDPR),

–         erasure (Article 17 of the GDPR),

–         limitation of processing (Article 18 of the GDPR),

–         portability (Article 20 of the GDPR),

–         opposition (Articles 21 and 22 of the GDPR),

–         post-mortem instructions (Law No. 78-17 of January 6, 1978 on computers, files and freedoms);


Rights of access

You have the option to obtain from Dimitrios-exclusive.com confirmation that the Data concerning you is or is not processed and, when it is, access to said Data as well as the following information:


a)       the purposes of the processing;

b)       the categories of Data;

c)       the recipients or categories of recipients to whom the Data has been or will be communicated;

d)       when possible, the intended Data retention period or, when this is not possible, the criteria used to determine this period;

e)       the existence of the right to request Dimitrios-exclusive.com to rectify or erase Data, or a limitation of the processing of your Data, or the right to oppose such processing;

f)        when the Data is not collected from you, any information available as to its source

When the Data is transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees with respect to this transfer.


Dimitrios-exclusive.com provides a copy of the Data that is subject to processing.


Dimitrios-exclusive.com may require the payment of reasonable fees based on the administrative costs for any additional copy requested by the Member.

When you submit your request electronically, the information is provided in a commonly used electronic form, unless the Member requests otherwise.

Your right to obtain a copy of your Data must not affect the rights and freedoms of others.


 Rights of rectification

You have the possibility to obtain from Dimitrios-exclusive.com, as soon as possible, the rectification of Data concerning you which is inaccurate. You also have the possibility to have incomplete Data completed, including by providing a supplementary declaration.


Rights to erasure

You have the possibility to obtain from Dimitrios-exclusive.com the erasure, as soon as possible, of Data concerning you when one of the following reasons applies:

a)       the Data is no longer necessary for the purposes for which it was collected or otherwise processed by Dimitrios-exclusive.com;

b)       you have withdrawn your consent to the processing of such Data and there is no other legal basis for the processing;

c)       you exercise your right to object under the conditions set out below and there is no compelling legitimate reason for the processing;

d)       the Data has been unlawfully processed;

e)       the Data must be erased to fulfil a legal obligation;

f)        the Data was collected from a child.


Rights to limitation

You have the possibility to obtain from Dimitrios-exclusive.com the limitation of the processing of your Data when one of the following reasons applies:

a)       Dimitrios-exclusive.com verifies the accuracy of the Data following your challenge of the accuracy of the Data,

b)       the processing is illegal, and you oppose the erasure of the Data and require instead the limitation of its use;

c)       Dimitrios-exclusive.com no longer needs the Data for the purposes of processing but it is still necessary for you to ascertain, exercise or defend legal rights;

d)       You have objected to the processing under the conditions described below and Dimitrios-exclusive.com checks to see if the legitimate reasons pursued prevail over your alleged reasons.

 Right to Data portability


You have the possibility to receive from Dimitrios-exclusive.com the Data concerning you, in a structured format, commonly used and readable by machine when:

a)       the Data processing is based on consent, or on a contract and

b)       the processing is performed using automated methods.

When exercising your right to portability you have the right to have the Data sent directly by Dimitrios-exclusive.com to a data controller you designate, when this is technically possible.


Right of opposition

You have the right to object at any time, for reasons relating to your particular situation, to a processing of your Data based on the legitimate interest of Dimitrios-exclusive.com. Dimitrios-exclusive.com will no longer process the Data unless it demonstrates that there are legitimate and compelling reasons for the processing that prevail over your interests and your rights and freedoms or may retain it for the purpose of the ascertainment, exercise or defense of rights in court.

Finally, the User has the right to oppose, wholly or in part, for reasons legitimate to the handling of personal data pertaining to them, even if pertinent to the purpose of the collection as well as to the handling of personal data pertaining to them in order to send publicity material or direct selling or for completing market research or commercial communication.

For exercising the rights provided under GDPR, you can send your request to: info@dimitrios-exclusive.com


7. Data Handling Manager

The Manager of data handling for the personal data of Users who use the Dimitrios-exclusive.com Website – DIMITRIOS EXCLUSIVE INC., 52 Kyprou Ave., Peristeri 121 32, Athens, Greece. To exercise their rights and for any further information related to data handling, the User may contact the Data Handling Manager at the following address: DIMITRIOS EXCLUSIVE INC.  52 Kyprou Ave., Peristeri 121 32, Athens, Greece


8. Term 

Your Personal Data is kept, in an active database, for a period of three (3) years from your last activity on the Site or on an electronic communication medium (in particular an email). At the end of this period, your profile is considered “inactive” and will be automatically disabled. You will therefore have to create a new one for any new Order.

Your Personal Data in relation with an Order on the Site is kept for a period of three (3) years following an Order. It remains accessible by you and by us, in particular from your account, to allow you and us to have a complete history of your Orders. We can delete it at any time on request from you.

However, at the end of these periods, including where applicable from the date of your deletion request, your Personal Data may be subject to intermediate Archiving to meet our legal, accounting and tax obligations.


Social Network

Dimitrios-exclusive.com is present on the Social Networks. To learn more about the protection of your Personal Data when browsing these Social Networks, we invite you to consult their respective privacy policies.

In order to enable you to register or connect more easily to our Site, you have the possibility to authenticate yourself on our Site via the account of a Partner Social Network. All you have to do is click on the button to automatically pre-fill your registration with the information you have already provided to the Network. We are able to collect information, as recipient, when you browse the pages of our Social Networks or use their authentication features.


Guidelines for children

By accessing the Web Site and/or Service(s), you affirm that you are more than 16 years old, are an emancipated minor, or have the consent of your parents or legal guardian and, therefore, are fully capable and competent to abide by and enter into the agreements and obligations set forth in these Terms of Services. When Children are permitted to register for a Service with parental approval, we will take additional steps to protect the Children’s privacy. 


 COOKIES POLICY

A “cookie” is a text file that can be saved, subject to your choices, in a dedicated space of the hard drive of your Terminal, when consulting the Site. A cookie file allows its issuer to identify the Terminal in which it is stored, during the period of validity or storage of the cookie and must therefore be considered as Personal Data.

When consulting our Site, the information may be stored in the cookie files installed on your Terminal, subject to the choices you have expressed concerning Cookies and that you can change at any time.

The personal data of the users is never deliberately acquired by the site.

The site does not make use of cookies to transmit information of a personal nature, nor does it use permanent cookies of any type or any other system for tracing the user.

The use of session cookies (which are not permanently memorized by the computer of the user and disappear when the browser is shut down) is strictly limited to the transmission of the identification data for the session (made up of random numbers generated by the server) which are necessary for the safe and effective exploration of the site.

The session cookies on this site are used to avoid the use of other computer technologies which would be potentially harmful for the privacy of the user’s navigation and do not allow the acquisition of the user’s personal data.


THIRD-PARTY COOKIES

The use of third-party cookies, both temporary and permanent, by the site is anonymous and solely for allowing the owner of the site to make use of web analysis services provided by others. These cookies make it possible to anonymously collect and record information on the site pages that have been visited but do not permit the identification of the visitor and are in no way connected with other information. These data are used exclusively to trace and examine the use of the sites by the users, compile statistics based on the information that has been collected anonymously and using data in aggregate form.

Specifically, users of the site should know that the analysis service that issues the cookies that we use is ‘Google Analytics’, which is described below.

Google Analytics is a web analysis service that is supplied by Google, Inc. (‘Google’) which uses cookies that are deposited on the hard disk of the user’s computer to analyze the way in which the user visits the web site. The information that is generated by the cookies concerning the way in which the site was visited (including the IP address) are transmitted to Google and deposited in the Google servers in the United States.  Google uses this information for tracing and analyzing the use of the web site by the user, compiling a report on the activities of the site for the site operators and supplying other services related to the activity of the web site and the use of Internet. Google may also communicate this information to third parties in those cases where it is required by law or where the third parties treat the information on behalf of Google. Google will not associate the IP addresses of the user with any other data possessed by Google.  At any time, the user may refuse to use the cookies by selecting the appropriate set up on their browser.

By using this site, the user automatically consents to the treatment of his/her data by Google for the purposes described above.  To consult the privacy policy of Google about the service of Google Analytics, please visit the internet site http://www.google.com/intl/en/analytics/privacyoverview.html.

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