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PRIVACY NOTICE

Data privacy is of high importance for KOOLFLY and we want to be open and transparent with our processing of your personal data.

We therefore have a policy setting out how your personal data will be processed and protected.

Who is the controller of your personal data?
The Greek company "Enovaway-Internet Services Société Anonyme" (hereinafter referred to as "KOOLFLY") is the controller of your personal data under applicable law.
Enovaway - Internet Services S.A
Address: 12 Angelou Sikelianou,
Neo Psychiko, Athens, GR-11525, Greece
General Electronic Commercial Registry (GEMI) No: 119802401000
Tax Reg. No: 800391291
Tel: +30 210 6710207, Mr Theodoros Simos
contact e-mail for personal data issues: dataprivacy@koolfly.com

Where do we store your data?
Unless otherwise provided in this Privacy Notice, the data we collect from you is stored within the European Economic Area.

Your rights
Right to access:
You have the right to request information about the personal data we hold on you at any time. For this purpose, you can send us an e-mail to dataprivacy@koolfly.com

Right to portability:
Whenever KOOLFLY processes your personal data by automated means based on your consent or based on an agreement, you have the right to get a copy of your data on a structured, commonly used and machine readable format. You can also request to have your data transferred to a third person. This only includes the personal data you have submitted to us.
In order to exercise the above right you can send us an e-mail at dataprivacy@koolfly.com

Right to rectification:
You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed. 
If you have a KOOLFLY account, you can edit your personal data under your account.
You can also send us an e-mail at dataprivacy@koolfly.com

Right to erasure:
You have the right to ask for your personal data, which are processed by KOOLFLY, to be eased at any time, especially when:

  • Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
  • The processing of your data is based on your consent and you withdraw that consent
  • Your data have been illegally processed.

The above right does not exist in particular where:

  • The processing of your data is necessary to establish, exercise or defend legal rights
  • The processing of your data is necessary to comply with a legal obligation of KOOLFLY that requires processing.
  • In any case, we will notify you whether or not your claim is satisfied and, in the event of non-satisfaction, the reasons involved in it.
    In order to exercise the above right you can send us an e-mail at dataprivacy@koolfly.com

Right to object: 
You have the right to object to the processing of your personal data which is based on legitimate interest of KOOLFLY. In that case, we will not continue to process the personal data unless we can demonstrate compelling and legitimate grounds for the processing which overrides your interest and rights or to establish, exercise or defend legal rights.
In order to exercise the above right you can send us an e-mail at dataprivacy@koolfly.com

Right to object to direct marketing: 
You have the right to object to the processing of your personal data for direct marketing purposes.
You can state your preference by the following means:

Right to restriction: 
You have the right to request the restriction of processing of your personal data under the following circumstances:

  • If you question the accuracy of your personal data and until KOOLFLY verifies their accuracy.
  • If processing of your data is unlawful and you object to their erasure by asking instead restriction of their use.
  • If KOOLFLY no longer needs your personal data for the purpose of processing, but the data is necessary to establish, exercise or defend legal rights
  • If you object to the processing of your data by KOOLFLY which is based on legitimate interest of the latter and until the existence of KOOLFLY's legitimate grounds overriding your freedoms or rights has been verified.

In order to exercise the above right you can send us an e-mail at dataprivacy@koolfly.com

Right to complain with the competent data protection authority: 
If you consider KOOLFLY to process your personal data in an incorrect way, you can contact us at dataprivacy@koolfly.com or by phone at +30 210 6710207. You may also raise a complaint to the Hellenic Data Protection Authority or any other competent supervisory authority.

Updates to our Privacy Notice:
We may need to update our Privacy Notice. The latest version of the Privacy Notice is always available on our website.

ONLINE PURCHASE

Why do we use your personal data?
We will process your personal data to manage your purchase online at KOOLFLY by processing your orders and returns via our online services and send you notifications of the delivery status of your items.
Your personal data is being used to identify you and to validate your legal age for shopping online and to confirm your address with external partners.

What types of personal data do we process?
We will process following categories of your personal data:

  • contact information, such as name and surname, address, e-mail address and telephone number, gender (if you choose to enter this information) and date of birth (if you choose to enter this information)
  • payment method information (such as the payment method selected, the transaction date and the amount of payment)
  • order information

If you have a KOOLFLY account, we will also process your personal data submitted in relation to the account, such as:

  • shopping history
  • wishlist

Who has access to your personal data?
Your personal data that is forwarded to third parties is only used to provide you with the services mentioned above. As a result, recipients of your personal data may be warehouses and co-operating courier companies and our accountants/tax consultants.
In any case, only the data, which are necessary for the provision by each partner of the corresponding service for which the transmission is made, are forwarded.
Some of these recipient companies may have an independent right or obligation to process your personal data. In this case they act themselves as controllers.

What is the legal basis for processing your personal data?
The processing of your personal data is necessary for KOOLFLY to fulfil the service of managing and delivering the order to you.

How long do we save your data?
We will keep your personal data for three years from your last purchase.

DIRECT MARKETING

Why do we use your personal data?
We will process your personal data to send you newsletters and marketing offers via e-mail and/or phone calls.
In order to optimise your experience as a KOOLFLY user, we will provide you with relevant information, recommended products, send you reminders of products left in your shopping bag and send you offers.

What types of personal data do we process?
We will process following categories of personal data

  • contact information, such as e-mail address and telephone number
  • gender (if you choose to let us know this information)

If you keep a KOOLFLY account, we will also process your personal data submitted in relation to the account such as:

  • name
  • address 
  • age
  • shopping history
  • wishlist

Who has access to your personal data?
Your personal data that is forwarded to third parties is only used to provide you with the services mentioned above. As a result, recipients of your personal data may be media agencies and technical suppliers for distribution of promotional messaging.

We never pass on, sell or swap your personal data for marketing purposes to third parties.

What is the legal basis for processing your personal data?
The processing of your personal data is based on your consent or, in the case of the purchase of products, regarding the promotional e-mails that we send you, on our legitimate interest.

Right to withdraw your consent:
You have the right to withdraw your consent at any time by sending an e-mail to dataprivacy@koolfly.com, and the right to object to the use of your personal data for direct marketing purposes.
When you do so, KOOLFLY won't be able to send you any further direct marketing offers or information based on your consent.
You can opt out from direct marketing by the following means:

How long do we save your data?
We will retain your personal data for direct marketing purposes until you withdraw your consent or opt out from the use of your personal data for direct marketing purposes.

KOOLFLY ACCOUNT

Why do we use your personal data?
We will process your personal data to manage your personal account and in order to give you a more enjoyable user experience at KOOLFLY.
We will provide you with your order history, details around your orders, refunds and points and enable you to handle your account settings. We will also provide you with easy ways to maintain accurate and updated information such as contact details and payment information. We will also allow you to store items in your cart and wishlist.

What types of personal data do we collect?
We will always process your e-mail address and password that you submit when you sign up for KOOLFLY account.
We will also process following categories of personal data:

  • contact information such as name and surname and e-mail address
  • address and phone (if you choose to enter this information)
  • date of birth (if you choose to enter this information)
  • gender (if you choose to enter this information)

We will process the following categories of personal data if you buy and/or return products

  • order history
  • return history
  • KOOLFLY Rewards

Who has access to your personal data?
Your personal data is forwarded to third parties only to the extent required to provide you with the services mentioned above and for that purpose.

What is the legal basis for processing your personal data?
The processing of your personal data for your account is based on your consent when you create your account.

Right to withdraw your consent:
You have the right to withdraw your consent at any time by sending an e-mail to dataprivacy@koolfly.com. When you do so, your account will cease to exist.

How long do we save your data?
We will keep your personal data for as long as you have an active account.
You have the right to terminate your account at any time. If you choose to do so, we will keep your personal data only if there are any legal requirements and if there is an open dispute.

Your account will cease to be considered active if you have not made any order for three years.  After your account has become inactive your personal data will be deleted.

CUSTOMER SERVICE

Why do we use your personal data?
We will process your personal data to manage queries, to handle complaints, enquiries, product return issues and technical support matters.
We may also contact you if there is a problem with your order.

What types of personal data do we process?
We will process any data you provide to us, including the following categories: 

  • contact information such as name and surname, address, e-mail address and telephone number
  • payment information and payment history
  • order information
  • account information
  • all correspondence in the matter

Who has access to your personal data?
Your personal data is forwarded to third parties, such as courier companies, companies managing returns and/or warehouses, only to the extent necessary to provide you with the services mentioned above and for that purpose.

What is the legal basis for processing your personal data?
The processing of your personal data when you have made an order is based on a contract of sale between us, otherwise it is based on our legitimate interest.

How long do we keep your personal data?
We will keep your personal data for five years from the final settlement of the request, enquiry, complaint, query or other matter

LIVE CHAT

Why do we use your personal data?
On our site we offer live chat with fashion slylists. When you use this feature, we will process the personal data you submit to us in order to provide you with styling and fashion advice.

What types of personal data do we process?
We will process following categories of personal data

  • name and surname
  • e-mail address

Who has access to your personal data?
Your personal data is forwarded to third parties, such as co-operating fashion stylists, only to the extent required to provide you with the services mentioned above and for that purpose. Your personal data may be transferred outside the European Economic Area. In this case, we ensure that there is an adequacy decision by the Commission or that appropriate or suitable safeguards are being taken in order to ensure that the level of protection of your personal data is adequate.

What is the legal basis for processing your personal data?
The processing of your personal data when you have made an order is based on a contract of sale between us, otherwise it is based on our legitimate interest.

How long do we keep your personal data?
We will keep your personal data for three years from our last contact.

COMPETITIONS

Why do we use your personal data?
We will process your data when you enter our competitions. In this case, we will use your personal data to identify you, to verify your age, to contact you regarding the competition, before and after an event, to contact you if you win, and deliver the respective prize.

What types of personal data do we process?
We will process following categories of personal data

  • contact information such as name and surname, address, e-mail address and telephone number
  • age
  • information you submit to the contest

Who has access to your personal data?
Your personal data is forwarded to third parties, such as courier companies, for the delivery of the prize and to collaborating companies which organize and conduct the competitions on our behalf, only to the extent required to provide you with the services mentioned above and for that purpose.

Your personal data may be transferred outside the European Economic Area. In this case, we ensure that there is an adequacy decision by the Commission or that appropriate or suitable safeguards are being taken in order to ensure that the level of protection of your personal data is adequate.

What is the legal basis for processing your personal data?
The processing of your personal data is based on your consent when you choose to enter a competition.

Your right to withdraw your consent:
You have the right to withdraw your consent given above at any time by sending an e-mail to dataprivacy@koolfly.com. However, when you do so, we will not be able to provide you with the services mentioned above.

How long do we keep your personal data?
We will keep your personal data for three months after the competition has ended.

FULFILMENT OF LEGAL OBLIGATIONS

Why do we use your personal data?
We will use your personal data to comply with obligations in laws (including tax – accounting obligations), court rulings and decisions from authorities.

What types of personal data do we process?
We will process following categories of personal data as an example

  • order number
  • name and surname
  • postal address
  • transaction amount
  • transaction date

Who has access to your personal data?
We will share your personal data with our associates, who will assist us in fulfilling our obligations mentioned above, such as our accountants and our tax and legal advisers.

What is the legal basis for processing your personal data?
The above processing is necessary to fulfil our legal obligations.

How long do we keep your personal data?
We will keep your personal data for as long as required by applicable law to comply with our obligations mentioned above.

PREVENTION OF MISUSE AND CRIME

Why do we use your personal data?
We will use your personal data to detect, prevent and deal with misuse of our services and to prevent and investigate cases of fraud and/or other criminal acts.

What types of personal data do we process?
We will process following categories of personal data as an example

  • contact information such as name, address, telephone number and e-mail address
  • order history and information
  • history of deliveries and returns
  • payment information

Who has access to your personal data?
Your personal data is forwarded to third parties only for purposes mentioned above.
We may share your personal data with insurance companies, legal authorities and consultants, law enforcement authorities to complete investigations. Some or all of the above recipients may have an independent right or obligation to process your personal data acting in that case as controllers.

What is the legal basis for processing your personal data?
The processing of your personal data to prevent misuse of our services is based on our legitimate interest.

How long do we keep your personal data?
We will keep your data for the time we need to prevent and/or report potential fraud and other offences.


25/5/2018