Tselos Theodoros A. (hereinafter referred to as “Xercise”, “We” or “Us”) appreciates your visit to our websites and mobile applications (together also “online offer”) and also your interest in our company and our products.
1. Xercise respects your private sphere
The protection of your private sphere during the processing of personal data as well as the security of all business data is a major concern for us that we take into consideration in our business processes. We process personal data, collected during your visit to our online offers confidentially and only in accordance with the legal directives.
Data protection and information security are an integral part of our corporate policy.
Tselos Theodoros A. is responsible for the processing of your personal data.
Our contact details are the following:
Tselos Theodoros A. Geor. A 26, Tripoli, 22132
Τηλ. +30 2710239437 sales@ xercise.gr
3. Processing of personal data
3.1 · Processed data categories
Communication data (e.g. name, telephone number, e-mail address, address, IP address) are processed.
3.2 · Processing principles
Personal data are all the information which relate to an identified or identifiable natural person, for example, names, addresses, telephone numbers or e-mail addresses which are the expression of the identity of a person.
We process personal data only when there is a statutory legal basis for doing so or if you have given us your consent, e.g. in the scope of a registration.
3.3 · Processing purposes and legal grounds
Our delegated service providers and we process your personal data for the following objectives:
3.3.1 · Provision of this online offer
· Legal basis: Predominantly, justified interest in direct marketing on our part, as long as this is carried out in compliance with data protection regulations and competition law regulations
3.3.2 · In reply to user inquiries in the framework of a contact form
· Legal basis: Predominantly, justified interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations resp. contractual performance resp. consent
3.3.3 · Determination of malfunctions and for safety reasons
· Legal basis: Fulfilment of our legal obligations in the field of data security and predominantly, justified interest in the rectification of malfunctions and the security of our offers.
3.3.4 · Our own and third party advertising as well as market research and reach measurement in accordance with the legally permissible extent resp. consent-based
· Legal basis: Consent or predominantly, justified interest in direct marketing on our part, as long as this is carried out in compliance with data protection regulations and competition law regulations.
3.3.5 · Safeguarding and defending our rights
· Legal basis: Justified interest on our part in the assertion and defense of our rights.
3.4 · Log files
Whenever you use the Internet, specific information will be automatically transmitted from your Internet browser and stored by us in so-called log files.
We save the log files for the determination of malfunction and for safety reasons (e.g. for the investigation of attempted attacks) for a short period and delete them afterwards. If a further retention of log files is required for evidence purposes, these will be exempted from deletion until the final clarification of the respective incident and can be handed over to investigating authorities in individual cases.
Log files are (without or without the complete IP address) under the prerequisites of section 3.3.4 “Our own and third party advertising as well as market research and reach measurement in accordance with the legally permissible extent resp. consent-based” also used for analytical purposes.
The following information, in particular, is stored in the log files:
· IP address (Internet protocol address) of the end device from which the online offer is accessed;
· Internet address of the website from where the online offer has been accessed (so-called origin or referrer URL);
· Name of the service provider through which access to the online offer is achieved;
· Name of the retrieved files or information;
· Date and time as well as duration of the access;
· Transferred data volume;
· Operating system and information on the Internet browser used, including add-ons (e.g. for the flash player);
· http status code (e.g. “Inquiry successful” or “Requested file not found”).
3.5 · Children
This Online Offer is not meant for children under 16 years of age.
3.6 · Transfer of data
3.6.1 · Transfer of data to other responsible parties
We will principally only transfer your personal data to other responsible parties insofar as if this is necessary for the contract performance, we or the third party has a predominantly justified interest in the transfer or if you have given your consent. You will find details concerning the legal bases in section “Processing purposes and legal bases” (see no. 3.3).
Moreover, data can also be transferred to other responsible parties, insofar as we are obligated to do this on the basis of statutory regulations or due to enforceable official or judicial order.
3.6.2 · Transfer of data to service providers
We assign tasks such as marketing services, programming, data hosting and hotline services to external service providers. We have selected these service providers with utmost care and monitor them on a regular basis, in particular with regard to their diligent handling and protection of the data stored by them. All providers are bound to confidentiality and adherence to the legal specifications by us.
3.6.3 · Transfer to recipients outside the EEA
We might transfer personal data to recipients located outside the EEA into so-called third countries. In such cases, prior to the transfer we ensure that either the data recipient provides an appropriate level of data protection or that you have consented to the transfer. You are entitled to receive an overview of third country recipients and a copy of the specifically agreed-provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the “Contact” section (see no. 14).
You can obtain an overview of the recipients in non-member countries and a copy of the concrete agreed regulations to guarantee the appropriate standard of data protection from us. Please use the information contained in section “Responsible authority and contact” (see no. 2).
3.7 · Duration of storage; retention periods
On principle, we store your data for as long as it takes for the provision of our online offer and the associated services or when we have a justified interest in further storage (e.g. after the fulfilment of a contract, we could still have a justified interest in postal marketing). In all other cases, we will delete your personal data with the exception of such data that we are obliged to retain for the fulfilment of legal obligations (e.g. as a result of fiscal and commercial retention periods, we are obliged to retain documents such as contracts and invoices for a specific period of time).
4. Usage of cookies
In the context of our online service, cookies and tracking mechanisms may be used. Cookies are small text files that may be stored on your device when visiting our online service. Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis.
4.1 · Categories
We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.
It is generally possible to use the online service without any cookies that serve non-technical purposes.
4.1.1 · Technically required cookies
By technically required cookies we mean cookies without those the technical provision of the online service cannot be ensured. These include e.g. cookies that store data to ensure smooth reproduction of video or audio footage.
Such cookies will be deleted when you leave the website.
4.1.2 · Cookies and tracking mechanisms that are technically not required
We use marketing cookies and tracking mechanisms. We only use such cookies and tracking mechanisms if you have given us your prior consent in each case:
By using marketing cookies and tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behaviour:
· Statistics: By using statistical tools, we measure e.g. the number of your page views.
· Conversion tracking: Our conversion tracking partners place a cookie on your computer (“conversion cookie”) if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a conversion tracking tag.
Please note that using the tools might include transfer of your data to recipients outside of the EEA where there is no adequate level of data protection pursuant to the GDPR (e.g. the USA). For more details in this respect please refer to the following description of the individual marketing tools.
4.2 · Management of cookies and tracking mechanisms
You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings.
Note: The settings you have made refer only to the browser used in each case.
4.2.1 · Deactivation of all cookies
If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website.
4.2.2 · Management of your settings with regard to cookies and tracking mechanisms not required technically
When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any marketing cookies or tracking mechanisms, respectively.
In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.
5.1 · OpenstreetMap
This page uses the map service OpenstreetMap Maps via an API.
For the use of the functions of OpenstreetMap it is necessary to store your IP address. This information is usually transmitted to a server of OpenstreetMap and saved there. The provider of this page does not have any influence on this transmission of data.
6. Social plugins
In our online offer, we use so-called social plugins of different social networks; these will be described individually in this section.
On application of the plugins, your Internet browser will establish a direct connection to the servers of the respective social network. Hereby the relevant provider obtains the information that your Internet browser has called up the corresponding page of our online offer, even if you do not possess a user account with the provider or are not currently logged in with the provider. Log files (including the IP address) are directly transmitted from your Internet browser to a server of the relevant provider where they are stored if necessary. The headquarters of the provider or his/her server could be located outside the EU or the EEA (e.g. in the USA).
The plugins represent independent extensions of the providers of social networks. Therefore, we have no influence on the extent of the data collected and stored by the social network providers via the plugins.
The purpose and extent of the collection, the further processing of the data by the social network as well as your associated rights and setting options for the protection of your private sphere can be taken from the data protection notes of the respective social network.
You should not use the respective plugins if you do not want social network providers to obtain data concerning this online offer or to continue to use this data.
6.1 · Social plugins of Facebook
Facebook is provided under www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and under www.facebook.de by Facebook Ireland Limited, Hanover Reach, 5–7 Hanover Quay, Dublin 2, Ireland (“Facebook”). You will find an overview of the plugins from Facebook and their appearance here: https://developers.facebook.com/docs/plugins/?locale=en_EN; you will find information on data protection at Facebook here: http://www.facebook.com/policy.
7. Newsletter with opt-in; Right of withdrawal
Within the scope of our Online Offers you can sign up for newsletters. We provide the so-called double opt-in option which means that we will only send you a newsletter via email, mobile messenger (such as, e.g. Email). SMS or push notification after you have explicitly confirmed the activation of the newsletter service to us by clicking on the link in a notification. In case you wish to no longer receive newsletters, you can terminate the subscription at any time by withdrawing your consent. You can withdraw your consent to email newsletters by clicking on the link which is sent in the respective newsletter mail, or in the administrative settings of the online offer. Alternatively, please contact us via the contact details provided in the Contact section.
8. External links
Our online offer can contain links to the websites of third parties − to providers who are not affiliated with us. After you click the link, we no longer have any influence on the collection, processing and utilization of any personal data that is transferred to third parties after clicking the link (for example, the IP address or the URL of the site on which the link is located), as our control of the conduct of third parties is then naturally withdrawn. We assume no responsibility for the processing of this kind of personal data by third parties.
Our staff and our delegated service provider companies are obliged to maintain secrecy and to adhere to the regulations of the applicable data protection laws.
We take all necessary technical and organizational measures in order to ensure an appropriate standard of protection and to protect your data that are administered by us especially from the risks of unintentional or unlawful destruction, manipulation, loss, alteration or unauthorized disclosure or unauthorized access. Our security measures are continually improved according to the technological development.
10. User rights
To enforce your rights, please use the details provided in the “Contact” section (see no. 14). In doing so, please ensure that an unambiguous identification of your person is possible.
10.1 · Right to information and disclosure
You have the right to obtain information from us concerning the processing of your data. For this purpose, you can enforce a right to information in relation to the personal information that we process from you.
10.2 · Right of rectification and deletion
You can demand from us the rectification of false data and – insofar as the legal prerequisites are fulfilled – the completion or deletion of your data.
This does not apply to data which are necessary for invoicing or accounting purposes or are subject to the statutory retention obligation. Insofar as the access to such data is not required, the processing thereof will be restricted (see below).
10.3 · Restriction of processing
You can demand from us the restriction of the processing of your data insofar as the legal prerequisites are fulfilled.
10.4 · Data portability
As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – that we transfer those data to a third party.
10.5 · Right of objection
10.5.1 · Case-related right of objection
Insofar as we undertake processing of data on the basis of a predominantly justified interest, as represented in this data protection policy, you have the right to file an objection to this processing, at any time, for reasons resulting from your special situation.
We will then discontinue the processing of your data, unless we can prove, in accordance with the statutory regulations, mandatory reasons worthy of protection for further processing, which outweigh your interests, rights and liberties, or if the further processing serves the assertion, exercising or defending of legal claims.
10.5.2 · Objection against the processing of data for direct marketing purposes
Furthermore, you can file an objection to the processing of your personal data for commercial purposes at any time (“objection to advertising”). Please take into consideration the fact that there could be an overlapping between your objection and the utilization of your data in the scope of an ongoing campaign.
10.6 · Rights of revocation
If you have given us your consent to the processing of your data, you can revoke this with future effect at any time. This also applies to the revocation of declarations of consent, granted to us prior to the validity of the GDPR, therefore prior to 25. May 2018. The legality of the processing of your data shall remain unaffected unless revoked.
11. Right to appeal to the supervisory authority
You have the right to submit an appeal to a data protection supervisory authority. For this purpose, you can refer to the data protection supervisory authority, which is competent for your place of residence of federal state or to the data protection supervisory authority which is competent for our group.
The competent authority is:
Hellenic Data Protection Authority Headquarters: 1-3 Kifissias Ave., P.C. 115 23, Athens
Call center: +30 210 6475600 Fax: +30 210 6475628 E-mail: email@example.com
12. Change of the data protection policy
We reserve the right to make modifications to our security and data protection measures, insofar as this is necessary due to the technical development. In these cases, we will also adapt our data protection policy accordingly. Therefore, please note the currently valid version of our data protection policy.
If you wish to contact us, please find us at the address stated in the “Controller” section (see no. 2).
Effective date: 30-09-2021