Privacy and Cookies Personal data protection policy

Overview

1. The data controller and his data protection officer

2. What data are processed by AlphaDiscounters and its partners, for what reasons and for how long?

3. Security measures

4. How to exercise your rights?

5. Cookies

6. Profiling

7. Why are cookies and/or similar technologies important to the Internet?

8. Security and Privacy Issues

9. Links and additional useful information

1. The data controller and his data protection officer

ALPHADISCOUNTERS S.A. (hereinafter referred to as the “Company”) Republic of Greece with TAX NUMBER 801968309 and no. REGISTRATION NUMBER – GEMI 167239301000. AlphaDiscounters, as data controller, publishes the AlphaDiscounters site and, as such, makes various uses of your personal data, i.e. any information allowing you to be identified (for example your name, your email address, -mail, your billing information) (hereinafter the “Data”). AlphaDiscounters Data Protection Officer (hereinafter the “DPO”) ensures the compliance of personal data processing carried out by AlphaDiscounters. You can contact him (i) by email sent to [email protected] or (ii) by post addressed to AlphaDiscounters, Personal Data Protection Officer.

2. What data are used by AlphaDiscounters and its partners, for what reasons and for how long?

We process your Data for the following purposes:

2.1. The fight against fraud

Description: we process your Data in order to fight against fraud. The legal basis for this processing is our legitimate interest.

Category of data: your identification data (example: surname, first name, postal and electronic contact details, etc.), your payment data, your connection data (IP address, navigation data, etc.) and your tracking data. the commercial relationship (example: orders, invoices, amount of the order, purchase history, etc.).

Storage periods: in the event of regularization of the unpaid, your Data are kept for 48 hours from the regularization OR in the event of absence of regularization, 3 years from the unpaid. At the end of this period, the data is anonymized or deleted.

Recipients of your Data: your Data may be transmitted to external service providers specializing in the publication of anti-fraud solutions.

2.2. The facilitation of your subsequent payments

Description: your Data is processed in order to offer you a feature to facilitate your possible subsequent payments (“Quick payment” feature as indicated in your customer area).

Data category: your identification data (example: surname, first name, postal and electronic contact details, etc.) and your payment data.

Storage periods: When you register your bank card in your customer area, the information is kept until the withdrawal of your consent or until the expiration date of the bank card.

Recipients of your Data: your Data may be transmitted to external service providers specializing in payment and transaction services.

2.3. Follow-up and improvement of the customer relationship

Description:
– We process your Data in order to manage your responses to our satisfaction surveys and to improve customer relations. For the use of your Data, we rely on your consent or our legitimate interest.

– We process your Data to manage your complaints (which includes creating vouchers for you), manage our after-sales service and respond to any requests you may have relating to your contracts. The legal basis for this processing is the performance of the contract.

– We process your Data in order to respond to your requests for rights in accordance with paragraph 4 as well as requests from third party authorities (for example, the judicial police). The use of your Data is based on our legal obligations.

Category of data: your identification data (example: surname, first name, postal and electronic contact details, etc.), data related to your personal situation, your payment data, your connection data (IP address, browsing history …) and your business relationship monitoring data (example: orders, invoices, order amount, purchase history, subscriptions taken out, etc.).

Storage periods: your Data is kept on a current basis for the time necessary to perform the contract concluded with AlphaDiscounters. Your Data is kept on an intermediate basis for the time necessary for the legal defense of AlphaDiscounters rights.

The identity documents requested in the event of the exercise of your rights are kept for the time necessary to verify your identity and then are deleted immediately.

Recipients of your Data: your Data may be transmitted to: – Service providers enabling the management of satisfaction questionnaires – Service providers specializing in customer relationship management (call center, after-sales service) – Public and administrative authorities at their request.

2.4. Recovery

Description: we process your Data in order to identify unpaid bills and allow the recovery of outstanding sums. In addition, we use them to identify people in default of payment for the purpose of exclusion from any future transactions. The legal basis is the performance of the contract or our legitimate interest.

Category of data: your identification data (surname, first name, postal and electronic contact details, etc.), your transaction and payment data and your commercial relationship monitoring data.

Storage periods: in the event of regularization of the unpaid, your information is kept for 48 hours from the regularization OR in the event of absence of regularization, 3 years from the unpaid. At the end of the period, the data is anonymized or deleted.

Recipients of your Data: your Data may be transmitted to: – External service providers specialized in collection and credit risk – Public and administrative authorities at their request.

2.5. Management of customer reviews

Description:
– We process your Data in order to allow us to manage your opinions on the products offered on the www.alphadiscounters.com site and/or on the sellers present on the www.alphadiscounters.com site and/or to allow us to integrate your reviews on other sites. We process your Data based on your consent or our legitimate interest.

– We process your Data in order to conduct test campaigns for the products offered on the www.alphadiscounters.com website. The legal basis is the execution of the contract.

Data category: your identification data (example: surname, first name, postal and electronic contact details, etc.), your connection data (IP address, browsing history, etc.), your commercial relationship monitoring data (example: orders, delivery tracking, etc.) and data relating to the contributions of people who submit opinions on products, services or content, in particular their pseudonym.

Storage periods: Opinions on a product are published on the site for a period of 10 years from their publication on the site. Opinions relating to the AlphaDiscounters product are published on the site for a period of 3 years from their publication on the site. Reviews of a marketplace seller on the site for a rolling period of 12 months from their publication on the site. After these deadlines, AlphaDiscounters anonymizes the reviews (i.e. it is impossible for it to identify the natural person originating the review) in order to keep them indefinitely.

Recipients of your Data: your Data may be transmitted to service providers specializing in the moderation of reviews and the management of tester campaigns.

2.6. Optimization and personalization of your navigation

Description: we process your Data in order to personalize your browsing on our site by offering you products that may be of interest to you. The legal basis is your consent or our legitimate interest.

Category of data: your identification data (example: surname, first name, postal and electronic contact details, etc.), data related to your personal situation (CSP), your transaction and payment data, your connection data (IP address, etc.) and your commercial relationship monitoring data (example: orders, invoices, order amount, purchase history, subscriptions taken out, etc.).

Storage periods: your Data is kept for a maximum period of 5 years. At the end of the period, the data is anonymized.

Recipients of your Data: your Data may be transmitted to:
– Service providers specialized in optimizing your browsing by displaying personalized products, personalizing the products presented on the site according to your browsing and your interests
– Service providers allowing sending mobile, web and/or SMS notifications

2.7. Statistical reports

Description: we process your Data in order to develop statistics to improve our knowledge of your expectations of our products and services. The legal basis is our legitimate interest.

Data category: your identification data (customer number) and your connection data (IP address).

Storage periods: the time necessary to achieve the objective targeted by the statistics or until the exercise of your right of opposition.

Recipients of your Data: your Data may be transmitted to service providers specialized in the production of statistical reports.

3. Security measures

We are committed to implementing the appropriate technical and organizational measures to guarantee a high level of security.

These measures are defined taking into account in particular the state of technological knowledge, the nature, scope, context and purposes of the processing as well as the identified risks.

We inform you that we comply with the operation of the Mixed CPC/CPS Billing Model billing services payment card industry security standard, a guarantee of our expertise in terms of security. Within this framework, AlphaDiscounters undergoes a technical and organizational audit every year, which is conducted by independent external auditors. In addition, our internal procedures include a so-called “Privacy by design” procedure ensuring that all of our IT projects respect a high level of confidentiality and security for your Data.

This procedure provides, for all projects, an analysis of the latter’s maturity with regard to issues relating to Data protection and IT security.

Periodic audits and controls of our IT solutions are carried out throughout the year by the DPO and the team dedicated to IT security to maintain this high level of requirement over time.

4. How to exercise your rights?

You will find below a description of your rights as well as the technical methods at your disposal to exercise them.

Regarding requests that may be sent to the DPO by e-mail at [email protected]. or (ii) by post addressed to AlphaDiscounters, Personal Data Protection Officer, please to indicate the email address attached to your customer account on the Site (or to use it in the case of an email) as well as your first and last names.

In the event that you are unable to find the e-mail address attached to your customer account on the site or in the event of serious uncertainty about your identity, additional information relating to your identity may be requested from you in accordance with Article 11 GDPR.

We will send you a response within a maximum of one (1) month following the date of receipt of your request. This period may be extended by two (2) additional months given the complexity and number of requests.

For the sake of transparency, you will find below a presentation of your rights:

Right of access: You have the right to ask us for confirmation that Data concerning you is or is not processed and, if necessary, access to said Data as well as:
– the reasons for which we hold your Data;
– the categories of Data we hold;
– our use of your Data;
– who has access to your Data (and their location);
– where your Data is likely to be transferred;
– the duration for which we keep your Data;
– if you did not communicate your Data directly to us, how we obtained it;
– your rights under applicable laws and the ability to restrict processing;
– the possibility of lodging a complaint with the competent supervisory authority;

Right of rectification: You can request the rectification of inaccurate or incomplete information concerning you (for example an erroneous address).

Right of opposition: You can object at any time to an organization using some of your Data by putting forward reasons relating to your particular situation. You have the right to ask to exercise your right of opposition vis-a-vis the processing used for commercial prospecting purposes. In general, you can, at any time, object to the processing of your Data by AlphaDiscounters for commercial prospecting purposes or to the communication of your Data to selected AlphaDiscounters partners for commercial prospecting purposes, by sending an email to [email protected].

The right to withdraw consent: You may, at any time, withdraw your consent to the processing of your Data, by AlphaDiscounters, for commercial prospecting purposes or to the communication of your Data to selected AlphaDiscounters partners for prospecting purposes. commercial, by sending an email to [email protected].

In addition, AlphaDiscounters provides you with simple means of withdrawing your consent in the context of:

– Prospecting by email from AlphaDiscounters or our partners by transmitting your Data: by clicking on the hypertext links “Manage my subscriptions” or “Unsubscribe” present in each prospecting email or by going directly to your AlphaDiscounters customer account in the “My personal data” “My communications” section.
– Prospecting by SMS from AlphaDiscounters or our partners by transmitting your Data: by sending the words “STOP SMS” to +306936899858 or by going directly to your AlphaDiscounters customer account in the “My personal data” section. My communication”.

Right of deletion: you have the right to ask an organization to delete Data concerning you in the following cases:
– Your Data is used for prospecting purposes;
– The Data is no longer necessary for the purposes for which it was initially collected or processed;
– You withdraw your consent or you object to the processing of your Data;
– Your Data is subject to unlawful processing;
– Your Data was collected when you were a minor in the context of the information society (blog, forum, social network, website, etc.);
– Your Data must be erased to comply with a legal obligation. In the event of a request to delete your Data, AlphaDiscounters will nevertheless be required to keep them in the form of intermediate archiving, for the duration necessary to meet its legal, accounting and tax obligations. You can request the deletion of your Data, by logging into your customer account, in the “My personal data” “Right to deletion” section.

The right to portability: you can request the communication of part of the Data that you have provided to us in a format readable by a machine but also the transmission of this Data to a third party of your choice.

The right to complain: you can, at any time, lodge a complaint with the competent supervisory authority in Greece

The right to formulate post-mortem directives: you have the right to formulate post-mortem directives specific and general mortem concerning the storage, erasure and communication of your Data. In the absence of any directive, your heirs can contact AlphaDiscounters in order to:
– Access Data processing allowing “the organization and settlement of the estate of the deceased”
– And/or to proceed with the closure of your Account on the site and/or to oppose the continuation of the processing of your Data.

Right to limitation: you have the right to ask an organization to temporarily freeze the use of some of your Data, in particular during the examination of your request to exercise another right. It is important to note that this right only applies if:
– You dispute the accuracy of your Data for the period allowing us to verify the accuracy of the latter,
– You consider that we are unlawfully processing your Data and that you demand a limitation of their use rather than erasure,
– We no longer need your Data with regard to the purposes referred to in paragraph 2 but that these are still necessary for the recognition, exercise or defense of your legal rights,
– In the event of exercise of your right of opposition during the verification period relating to the point of knowing whether the legitimate reasons that we pursue prevail over yours.

5. Cookies

This section is dedicated to our cookie management policy on the site. It allows you to find out more about the origin and use of browsing information processed during your consultation of our website and about your rights.

5.1 What is a cookie?

A cookie is a small text file which asks permission to be placed on your computer’s hard drive by websites you visit. They are widely used to make websites work more efficiently. Some of these cookies are necessary for the operation of the site. Others have the function of identifying you and, depending on your navigation, helping our teams to improve the Site.

A cookie cannot provide access to information about you that you do not wish to share. A cookie has a limited lifespan and is deleted by your browser once it has expired. Only the company that places the cookie is likely to read or modify the information contained in this cookie.

5.2 Purposes and type of cookies

Different cookies are used for different purposes. The most common cookies are:

5.3 Managing the deposit of cookies

In accordance with Directive 2002/58/EC of July 12, 2002, AlphaDiscounters collects your prior consent to the deposit of cookies except for “essential” cookies and certain audience measurement cookies exempt from consent.

You can choose at any time to express and modify your wishes in terms of cookies, by the means described below.

Setting cookies with the tool offered by AlphaDiscounters

You are informed of the collection of this information when you first connect to www.alphadiscounters.com via the information banner relating to cookies. In order to comply with the regulations, AlphaDiscounters uses a tool allowing the Internet user to configure the deposit of cookies when connecting to the web site.

When you use our application, you can manage the deposit of cookies via the left menu of the application in the “Manage my cookies” section.

Tracers are deposited in the local storage of the site. The local storage works not subdomain. If you choose to delete certain trackers from local storage on a AlphaDiscounters subdomain, only the trackers of this subdomain will be deleted. To delete all the trackers from local storage, we advise you to do so using the tool offered by AlphaDiscounters.

• Settings of your browser

The configuration of each navigation software is different. It is generally described in the help menu of your navigation software. We therefore invite you to read it. You will thus be able to know how to modify your wishes in terms of cookies.

Internet Explorer
Firefox Google Chrome
Safari
Opera

Attention:
Any configuration that you can undertake on your navigation software concerning the acceptance or refusal of cookies will be likely to modify your Internet browsing and your conditions of access to certain services requiring the use of these same cookies. For example, by refusing certain essential cookies you may no longer be able to place an order on our site. If you choose to refuse the registration of cookies in your terminal or if you delete those registered there, we decline all responsibility for the consequences linked to the degraded functioning of our services resulting from the impossibility for us to register or consult the cookies necessary for their operation and that you have refused or deleted.

6. Profiling

As part of certain processing, we use your Data to perform profiling. The processing targeted by profiling is as follows:

– Management of contracts between AlphaDiscounters and you
– The fight against fraud
– Optimization and personalization of your navigation

Profiling consists of establishing an individualized profile based on an individual’s Data in order to access that person and predict their behavior, such as their preferences, lifestyle habits, etc. This profiling is based on the analysis of different variables such as the type of products or services ordered as well as the customer’s profile.

7. Why are cookies and/or similar technologies important to the Internet?

Cookies and/or similar technologies are central to the efficient functioning of the Internet, helping to generate a user-friendly browsing experience tailored to each user’s preferences and interests. Rejecting or disabling cookies may make some sites or parts of sites impossible to use.
Examples of important uses of cookies (which do not require the authentication of a user through an account):
Content and services tailored to user preferences – categories of products and services. Offers adapted to user interests.
Retention of passwords.
Retention of child protection filters regarding Internet content (family mode options, safe search functions).
Measuring, optimizing and adapting analytics features – such as confirming a certain level of traffic on a website, what type of content is viewed and how a user arrives at a website (eg: via search engines, directly, from other websites etc.). Websites run these analyzes regarding their use in order to improve their services for the benefit of users.

8. Security and Privacy Issues

In general, browsers have integrated privacy settings that provide different levels of cookie acceptance, validity period and automatic deletion after the user has visited a certain site. Other security aspects related to cookies:
• Customizing your browser’s cookie settings to reflect a level of cookie security that is comfortable for you.
• If you are the only person using the computer, you can optionally set long expiration periods for storing your browsing history and personal access data.
• If you share computer access, you may consider setting your browser to delete individual browsing data each time you close the browser. This is an option to access sites that place cookies and delete any visit information when you close your browsing session.

9. Links and additional useful information

The table below describes each cookie used on the website, including his role. We will not use these cookies in ways other than those indicated in this Cookie Policy.