PERSONAL DATA PROTECTION POLICY

The respect to your privacy and the management, protection and security of your personal data are a priority for the Greek Single Member Private Company under the name “The Upper Hand M.I.K.E.” and distinctive title “The Upper Hand”, located in Glyfada Attica, 7 Ious Street (Tax Identification Number: 801448119 / Tax Authority Glyfada (the “Company”). The Company has established this Data Protection Policy (hereinafter referred to as the “Data Policy” or the “Policy”), in order to inform about the type of data it collects or produces for you who visit or purchase from www.the-upperhand.com (hereinafter referred to as “e-shop”, “Online Store” or “Website”), or become a member or subscribe to the list of recipients of our newsletters, or in any other capacity you make use of the services of www.the-upperhand.com or participate in its promotions or other activities, or make use of social media for the purpose of collecting and processing data and the way this data is processed and its recipients, about your rights and choices in your personal data as well as how to contact us for any issues that may concern you in relation to your personal data.

What is “Personal Data”?

Personal data is information that identifies you, such as name, email address, home address, mobile phone number, usernames and shopping habits, user-generated content, financial information and social security information. They may also include unique numeric IDs such as your computer’s IP address as well as cookies.

Collection & Processing of Personal Data

The online store of www.the-upperhand.com does not collect your personal data, unless you have provided it for a specific purpose. For example, when you choose to receive our informative e-mail, you create an account / register as a member, contact us, make purchases through our online store and if you have given your consent to process them.

We can also collect them using cookies which we use to analyze the traffic of our website. No further processing, promotion or exchange of this data takes place. We need the information needed for your best shopping experience (immediate delivery of products you ordered, secure payment of your order and personalized service based on your needs).

Cookies

Cookies are stored on your computer when you visit and use our website. It is a set of text information stored by the browser on your device. The information stored in cookies will then be transmitted to our website. Each cookie is unique to your browser and contains some anonymous information. We use cookies to improve the experience of the use of the website by its visitors. The operation of the website will be significantly affected if you disable or do not accept the use of cookies. You have the right to disable cookies which you can specify through your browser settings. However, disabling them may not allow you to use certain parts of our site.

Types of cookies

Functional

These cookies are necessary for the proper operation of our online store. They allow you to navigate the Website and enjoy its functions. These cookies remain on your computer for a long time (persistent 1 day to 1 year)

Examples: PHP application cookie, PHP session cookie, frontend_cid, session_id, frontend, popup_newsletter

Performance

These cookies are used to measure performance and improve functionality, recording anonymous data for the use of the online store. These cookies remain on your computer during a session (session) but for a long time (persistent)

Examples: Ga, Gat, utm, utma, utmc, zlcmid, atuvs

Social media

With social networking cookies you can connect to social networks (eg Facebook – Twitter – YouTube – Instagram) and share content from our site. Advertising cookies (third parties) collect information that contributes to better personalization of ads. These cookies remain on your computer during a session (session) but for a long time (persistent).

Examples: fbcsrf

Third party cookies we use on this site

Google Analytics

In addition, third party social networks (e.g. Facebook, Instagram, etc.) can place cookies on your device if you choose to share content from our site.

From time to time, our websites and applications may contain links to and from the websites of our affiliate networks, advertisers and affiliates. If you follow a link to any of these sites, it is noted that these sites have their own privacy policy and we are not responsible for such policies. Please review these policies before submitting any personal information data on those sites.

We may also offer you the opportunity to use your social media login information. If you use this feature, you should be aware that you are sharing your profile information with us, depending on your settings on the relevant social networking platform. Please visit the relevant social media platform and check their privacy policy to understand how your personal data is shared and used in this context.

We do not knowingly collect any information from any person under the age of 15. Our services are aimed exclusively at people who are at least 15 years old or older. If you are under 15 years of age, do not use or provide any information to us, do not register as a Member or our mailing list recipient, do not make any purchases and do not provide any information about yourself to us, including your name , your address, or contact information (phone, e-mail, etc.). If we find that we have collected or received personal data from a child under the age of 15, we will delete it immediately unless a parent or guardian has given its consent. If you think we may have information from or about a child under 15, please contact us.

How and Why do we use your personal data?

All the above personal data which as mentioned or you provide to us compulsorily or optionally, or we collect from third parties or are produced by automated means, we use for the following legal purposes. Please note that in the event that Community or national law restricts or prohibits certain actions of the Company for which we use your data, we will cease to use the information that concerns you for these purposes.

In particular, your personal data is used by us for the following purposes:

To receive your orders, to process them, and to send the products to you and to contact you for issues related to the sale of our products to you.

For the management and processing and processing of your payments including the security of our financial transaction.

For your service as a Member in www.the-upperhand.com  by opening your Account to us.

For the creation, storage and maintenance of a database with our clientele and its analysis.

To send you commercial communication via newsletter, sms, or other multimedia related to our Company news, products, offers and promotions and / or to send you personalized updates based on your preferences and your profile in us and for understanding and analyzing the results of our ads and promotions.

For the processing of your requests such as for example withdrawal, replacement, etc., and the exercise of your rights.

For the security of transactions

For business analyzes and improvements, such as for the marketing and optimization of our products, for the optimization of your experience and your service by us in our Online Store, for the management of customer loyalty programs (Loyalty), as well as and to adapt your experiences to our Online Store.

For market research, statistical analysis, for the development of marketing strategies and the management of marketing campaigns and to inform you or our partners about possible opportunities to participate in marketing initiatives or product promotion.

For other purposes for which we will notify you, or as the case may be, at the point where the information about you is first collected

To whom do we share your personal data and why

In the context of the operation of our online store, the fulfillment of the contractual obligations of our Company and your best service, our Company reserves the right to cooperate with third companies-service providers, who provide us with support and gain access only to such data are absolutely necessary for the service they offer us (eg your registration in the e-shop and management of your account, the execution of the purchase agreement between us and the general provision of our services to you, the functional and computer organization of the www.the-upperhand.com website, the optimization of our products and services, etc.). These third party service providers agree under contract not to use your information in any way other than to help us provide you with the products and services we agree to.

We reserve the right to disclose your personal data to a third party to whom we reserve the right to choose to transfer all or part of our business. In addition, in case of merger or acquisition, or other change in our business, the new owners, shareholders, managers, etc. have the right to use your personal data in the same way as set forth in this privacy statement.

Your kept data may be disclosed to the competent judicial, police and other administrative authorities upon their legal request and in accordance with the applicable legal provisions. In addition, in case of a legal order, service order or official preliminary examination, the Company has the right to make the relevant data available to the respective service.

The Security of your personal data

We apply appropriate technical and organizational measures to protect the personal information we hold against unauthorized disclosure, use, conversion or destruction. Where appropriate, we use encryption and other technologies that can help secure the information you provide. We also require our service providers to comply with strict data protection and security requirements.

In particular, the data you submit to the Company are managed exclusively by authorized personnel of the Company who are under our control respectively and only by our order. For the processing, the Company selects persons or third parties with corresponding professional qualifications that provide sufficient guarantees in terms of technical knowledge and personal integrity for the observance of confidentiality. The Company, through the respective contractual commitments and its associates, takes all the necessary security measures to protect and ensure the confidentiality, confidentiality and integrity of personal data. In any case, their security in the environment of the platform is subject to reasons that go beyond its sphere of influence, as well as reasons due to technical or other weakness of the network not controlled by the Company or reasons of force majeure or accidental events. You must not disclose the details / codes you have stated for opening your Account, which is personal and non-transferable. For personalized communication, our Company uses appropriate mathematical and / or statistical procedures for the compilation of the profile and performs regular quality and security checks on the systems and algorithms it uses, in order to correct the factors that lead to inaccuracies in the data.

Retention time of your personal data

We will retain your personal information for as long as you continue to interact with us (you maintain an Account, you are registered to receive commercial communication from us, you make a purchase from our online store, you contact our customer service points, you take part in a contest etc.) and are necessary for the fulfillment of the purposes for which we have collected and processed them, as described in detail above, or for the period during which liability could arise from the processing, in accordance with the applicable legislation or if these purposes disappear, we are not required to keep them within the law e.g. for tax purposes. In addition, we retain them until you ask us to delete them, or what we retain and process as part of your consent, until you remove it, or until you oppose their processing by us which we base on our legitimate interest.

To determine the retention time of your personal data, we take into account the nature of your data, the quantity, the purpose of their processing, their security, etc. You have the right to request the deletion of your data. To exercise your right please visit the relevant Section in this Policy. In some cases, we reserve the right to anonymize your data for research or statistical purposes, in which case they are no longer associated with an identifiable person, so we reserve the right to use this information indefinitely. In any case, your data is stored securely.

Transfer of your personal data to third countries

The Company generally maintains your personal data within the European Economic Area. In the event that data are to be transmitted to third countries outside the European Economic Area for which there is no adequacy decision of the European Commission or to International Organizations, all appropriate guarantees under current data protection legislation will be taken. transfers to third countries and the relevant information will be posted on the company website.

Your rights and choices

It is important to be able to control your personal data.

You have the right to information

You have the right to receive clear, transparent and comprehensible information about how we use your personal data, as well as about your rights.

You have the right of access

You have the right to access the personal data we hold about you (subject to certain restrictions). We may charge a reasonable fee which takes into account the administrative costs involved in providing this information.

You have the right to correct / edit

You have the right to request the correction of your personal data if it is incorrect or out of date and / or to complete it if it is not complete.

You have the right to delete

In some cases you have the right to request the deletion of your personal data. Please note that this is not an absolute right, as we may have legal, commercial or tax reasons to keep your personal data.

You have the right to object to direct marketing, including profiling

You can unsubscribe at any time or refuse to receive instant promotional notifications. It is easier to do this by clicking the “Unsubscribe” link in any email or notification we send you. Alternatively, you can contact us using the contact details listed below.

You have the right to withdraw consent for the processing of data performed on the basis of consent at any time

You may revoke your consent to the processing of your data by us when such processing is based on your consent. Revocation of consent does not affect the legality of the processing carried out on the basis of consent prior to its revocation.

You have the right to object to the processing based on legitimate interests

You may object to the processing of your data at any time where such processing is based on a legitimate interest.

You have the right to file a complaint to a supervisory authority

You have the right to file a complaint with the local supervisory authority regarding the processing of your personal data. In Greece, the supervisory authority for data protection is the Authority for the Protection of Personal Data – APDPH (www.dpa.gr).

You have the right to data portability

You have the right to move, copy or transfer data from our database to another. This only applies to the data you have provided and the processing is based on a contract or your consent and that processing is done by automated means.

Contact

To ask us questions or if you wish the online store to change or modify your profile, please contact us by sending an email to info@the-upperhand.com