The security of your personal data is a top priority for our Company. Our Company in its capacity inter alia as controller of how your personal data are processed when you visit, register to or generally use and make purchases on our Website, has created this Personal Data Protection Policy to inform you in accordance with Regulation (EU) 2016/679, Law 4624/2019 and the other provisions of the relevant applicable Greek and EU legislation on personal data protection, of your rights and how to exercise them. This notification is supplemented in cases of processing of personal data via cookies by the specific Cookies Policy.
1. DETAILS OF THE CONTROLLER OF YOUR PERSONAL DATA
The controller of your personal data is the société anonyme under the name ‘TELEUNICOM A.S.’, trading as ‘TeleUnicom S.A.’ (hereinafter the “COMPANY” or “we” or “us”), with registered address at 21, Ploutarchou Street, Pallini, Attica, duly represented, with General Commercial Registry (GEMI) Reg. No 8497601000, which manages and operates the Website www.huaweistore.gr and the e-shop operating therein (hereinafter “Website” or the “Huawei Online Store”).
2. WHOM DOES THE INFORMATION PROVIDED THROUGH THIS POLICY CONCERN
This Personal Data Protection Policy applies to all users/visitors of the Websites, i.e. including persons visiting Huawei Online Store without having registered and created an account as well as persons who have registered and created an account, regardless of whether or not they carry out any transactions during their visit to Huawei Online Store.
a. Identification Data which include your first name, last name and data on your electronic authentication for your log-in when you create an account on the Website (username and password). Where invoices are issued, the following are also required: Tax Office, Tax Identification Number, occupation, corporate name.
b. Contact Data which include your contact information, shipping or billing address of products, which need not be the same, e-mail address and mobile or landline telephone number. Furthermore, data we receive from communication with you, requests for assistance, complaints, queries, data of telephone communication with you (e.g. orders over telephone) in accordance with the legal requirements for reasons of provision of commercial transaction receipts or other professional communication.
c. Financial Data including information concerning your payments and the bank account through which you carry out remittances to us.
d. Transaction Data including, for instance, information concerning completed sales of products to you, including information on products or services you had purchased via Huawei Online Store in the past, returns, etc.
e. Data of a technical nature concerning your use of and interaction with the Huawei Online Store, including but not limited to: your computer’s Internet Protocol (ΙΡ) address, your browser software and operating system, the speed of your connection and information concerning the software programmes installed on your computer, basic information concerning connection to the server and other information collected via cookies and related technologies (provided you have consented to the use of those that are not technically vital — for further information on cookies please consult our Cookies Policy).
f. Advertising Data including, for instance, information on your response to our Company's promotional actions, your choices, your search history, the product categories you prefer, links from which you were redirected to Huawei Online Store, as well as the methods of communication you use the most, which data mainly originate from advertising cookies and from which we collect data only if you have consented to their use — for further information on advertising cookies please consult our Cookies Policy).
g. Data concerning your answers and responses to surveys conducted by the Company, insofar as these are not anonymised data.
h. Data concerning the conduct of (implementation, participation validity check, contact with winners, award of prizes, etc.) and your participation in lotteries, contests and promotional actions carried out by the Company.
i. Data collected when you connect via social networking media. If you connect to the Huawei Online Store via any social networking media, the data we collect include but are not limited to the username or alias you use on the social networking medium in question, as well as the profile information or content you have permitted the social networking service to disclose on the basis of your privacy settings, etc.
It is expressly clarified that we are neither interested in nor collect:
- Data of minors. The Company understands the importance of protecting the personal data of minors. The Website neither addresses or nor is intentionally designed to be addressed to minors. It is the Company's intention to neither collect nor knowingly retain personal data of minors who might access the Website. For this reason, the Company requests a statement from persons conducting transactions on its Website that they are over 18 years of age, and expressly clarifies that only persons over the age of 18 may connect to its Website. Where it is found that, despite the foregoing, any personal data have been collected from a minor, said data shall be erased immediately.
- Special categories of data / Sensitive personal data. We request that you do not send us or disclose sensitive personal data (such as information concerning your racial or ethnic origin, ideology or political, religious or philosophical beliefs, information concerning your physical or mental health, biometric data or genetic characteristics, sexual orientation, trade union membership or information relating to criminal convictions) on Huawei Online Store or in any other manner. Where it is found that, despite the foregoing, any sensitive personal data have been collected, said data shall be erased immediately.
The following are also expressly clarified:
- Any connection of the Website, e.g. via special hyperlinks (links, hyperlinks or banners) or any other manner, to any other website belonging to third parties (e.g. social networking media etc.) shall not mean that the Company accepts any liability for the policy said websites use with respect to the protection and management of personal data. You must learn about the protection and management of your personal data by the aforesaid websites yourselves.
4. SOURCES OF COLLECTION OF PERSONAL DATA
Your personal data are collected from the following sources:
1. We collect data you voluntarily provide when using the services of Huawei Online Store and, in particular, when you order a product, create an account on the Website, participate in surveys or promotional actions, etc. The data we collected directly from you are those specifically noted above under 3.a, 3.b, 3.c, 3.g and 3.h.
2. We reproduce or collect certain information from your computer or device when you interact with the Website. The data listed above under 3.e belong to this category.
5. PURPOSES OF DATA COLLECTION:
A. Provision of services to you, performance of the performance of the agreement between us, or taking of pre-contractual measures upon your request. This purpose includes but is not limited to processing on our part in order to be able to fulfil product orders you place via the Website or by telephone, to track the progress of a product order you have placed or to manage the order in the event of a problem in its progress, to contact you, to handle your requests or complaints concerning your orders, to issue invoices, to provide support services and, generally speaking, to monitor the performance of obligations on both parts under the agreement between us.
B. Managing your registration on the Website if you choose to create an account.
C. Communication with you.
D. Advertising purposes. This purpose includes processing on our part:
E. For analysis and survey purposes. This purpose includes processing on our part to send or submit questionnaires to you in order to examine and analyse your degree of satisfaction with the Company’s services, to upgrade/improve its services and its general transactional relationship with you.
F. For purposes of the Company’s compliance with the obligations imposed by the legal, regulatory framework in force from time to time, as well as the decisions of authorities (State, supervisory, independent, prosecution, etc.) or courts (ordinary or arbitral).
G. For the purposes of the legitimate interests of the Company or a third party (indicatively: companies of the group to which the Company belongs, collaborating with the Company, corporate social responsibility, etc.). This purpose includes processing for reasons that include but are not limited to: a. establishment, exercise and support of the Company's legal claims; b. purposes of fraud prevention, security, protection of rights, computer systems, the Company's assets and parts thereof, its employees and Website users in general; c. the Company's compliance with is obligations under agreements with third parties; d. realisation of corporate transactions in the framework of which we may transfer or encumber the Company's assets.
Under the requirements of the legal framework on personal data, we ensure having a valid legal basis for the processing of your personal data. Below you will find an analysis of the legal bases for the processing of your data according to their processing purpose (you can view the purposes in section 5 immediately above, cases A through G):
For the purposes enumerated between 5.A and 5.C above, the legal basis for processing is the need to perform the agreement between us. The provision and corresponding processing of the data relevant to these purposes are necessary for the performance of our obligation, e.g. concerning your orders and the provision of customer support and services; any non-provision thereof would render impossible the provision of services by the Company to you. The processing for the purpose noted under 5.C is premised on the legal basis of our Company's legitimate interests in cases of communication between the Company and subjects with whom there is no contractual relationship.
For the purposes enumerated between 5.D(a, b, c, d) and 5.B above, the legal basis for processing is the provision of consent on your part. It is expressly clarified that your filling out of a Website registration form constitutes consent given by a clear affirmative act for the subsequent processing of the data necessary for this purpose, i.e. achieving the purpose of your registration on the Website. The processing of your data for these purposes is left at your discretion. Moreover, you can exercise your right to withdraw your consent at any time, without consequences, except for ceasing to receive advertising messages and newsletters and to be a registered Website user. On how to withdraw your consent, see below under 13. Where appropriate, we shall inform you of specific withdrawal methods, depending on the manner in which consent was provided, e.g. with regard to advertising messages and newsletters you receive, they will include a link at their end to withdraw your consent and unsubscribe from the lists of recipients of advertising messages, newsletters, etc. You can also deregister from the Website by choosing to delete your account on it.
For the purposes noted under 5.F above, the legal basis for processing is the need of the Company to comply with a legal obligation. The provision and processing of these data are mandatory, as non-provision would lead to the Company breaching an existing legal obligation.
For the purposes enumerated under 5.G, 5.E and 5.D.ed above, the legal basis for processing is the legitimate interests of the Company or a third party (for the understanding of the customer and his needs, the improvement of its services and the satisfaction of its customers, the increase of its sales and its market share, the avoidance of cases that may undermine its operation e.g. fraud etc). This processing is preceded by weighting of the fact that the interests of the Company or the third party are not overridden by your interests your or fundamental rights and freedoms which require protection of your personal data.
8. PRINCIPLES OF PROTECTION OF YOUR PERSONAL DATA
9. HOW WE KEEP YOUR PERSONAL DATA SECURE
The Company has access to your data and in particular the competent employees and members of its management within the framework of their duties (on a need to know basis).
In the performance of the Company’s contractual and legal obligations, the service of its legitimate interests or those of third parties, and where the Company has received your consent, the recipients of your data that are necessary on the basis of the purpose of each transmission may include the following:
1. Third parties we work with or which provide services that support or facilitate the provision of services by our Company, including but not limited to the following:
a. providers of e-mail management and distribution tools - for instance, if you subscribe to Huawei Online Store newsletters or other promotional messages, we will manage their delivery to you by using a third-party e-mail message distribution tool;
b. providers of security and fraud prevention services - for instance, we use providers to identify users of automated software that could disrupt our services and to prevent poor use of our services;
c. providers of data aggregation and analysis software services, allowing us to monitor and effectively optimise delivery of your orders;
d. software platform providers that help us contact your or provide you with customer support services - for example, we handle and answer any messages you sent via the assistance centre, using a third-party communication management tool;
e. providers of IT products and / or services (including cloud computing services) and / or support for all types of information and electronic systems and networks, including online systems and platforms;
f. postal service and or transport/courier service providers;
g. product and/or service promotion companies - advertising companies;
h. customer satisfaction or general market survey companies;
i. call centres;
j. companies providing reviewing services for the evaluation of products offered on Huawei Online Store and servicing of electronic orders placed by customers.
2. Supervisory, independent, court, prosecution, police, state and/or other authorities in the context of their remit, accredited mediators and mediation service provision centres, arbitral courts and alternative dispute resolution bodies.
3. Attorneys, law firms, court process services, experts, consultants, certified public / administrative accountants/auditors and providers of consulting services (e.g. financial), in the context of their remit.
4. We may forward your data to third parties, potential or existing purchasers of all or part of the Company's activities or assets (including rights) or persons entitled to encumber the foregoing.
5. Information may also be collected from you by certain third parties, e.g., advertisers, marketing networks, etc., using cookies and similar technologies (for further information please refer to our Cookies Policy which contains a specific section on third-party cookies). This can only take place if you have consented to the use of these cookies.
6. Other parties for the transmission of data for which you have granted your consent.
11. TRANSMISSION OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
You have the following rights:
a) To request to be informed of the categories of your personal data that we retain and process, their origin, the purposes of their processing, the categories of their recipients, their retention period as well as your relevant rights (right of access);
b) To request the rectification or/and supplementation of your personal data so that they are complete and accurate (right to rectification) by producing any necessary document justifying the need for rectification or supplementation;
c) To request the restriction of processing of your data (right to restriction);
d) To object to any processing of your personal data (right to object);
e) To request the erasure of your personal data from the records we keep (right to be forgotten) under specific conditions, e.g. when the data are no longer necessary, you have withdrawn your consent, the data have been unlawfully processed, and so forth;
f) To request the transfer of your data by the Company to a different controller (right to data portability);
g) To withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
h) Right to appeal to an Authority: If you consider that your rights have been infringed in any manner, you have the right to appeal to the Hellenic Data Protection Authority (1-3, Kifissias Street, GR-11523, Athens). For detailed information on the Authority's remit and on how to file a complaint, you can visit its website (www.dpa.gr - My rights - Filing a complaint).
Please note the following with regard to your aforementioned rights:
i. We may need to request additional information to confirm your identity in order to respond to your request.
ii. Your rights under c, d and e may not be satisfied in part or in whole where they concern data necessary for the drafting and/or performance of an agreement.
iii. The Company is entitled to deny your request for restriction of processing or erasure of your personal data in all cases if their processing or retention is necessary for the establishment, exercise or defence of the Bank’s legitimate rights or the performance of its legitimate obligations.
iv. The exercise of the above rights applies to the future and does not concern data processing already performed.
In order to exercise your rights, you may contact the Company's data protection officer in writing at the postal address 21, Ploutarchou Street, GR-15351 Pallini, Attica or via e-mail at firstname.lastname@example.org or via the form concerning exercise of rights. You can use the above contact details to address any questions or queries concerning this Policy.
With specific regard to your right to withdraw consent, it is clarified that you can exercise this right as described in the immediately preceding paragraph of section 13 and, where appropriate, in specific ways, e.g. by clicking on a specific unsubscribe hyperlink at the end of each e-mail message you receive (e.g. newsletters or promotional messages/advertisements).
Furthermore, through your account you can access your data collected for your registration and for the operation of your account, and you can rectify them, delete your account and de-register from the Website; this will result in the erasure of your data as noted above in detail in section 7 hereof.
We will make every effort to respond to your request within thirty (30) days of the date it is received. This time limit may be extended by sixty (60) additional days, where deemed necessary, taking into account the complexity and number of requests. You will be notified in any case of extension of the deadline within thirty (30) days of the date the request is received. This service is provided free of charge. However, where your requests are manifestly unfounded, excessive or repetitive, you may be charged a reasonable fee, following notification to you and taking into account the administrative costs for the provision of the notification requested or performance of the action requested, or action on your request(s) may be refused.
Date of drafting: 18 November 2021