Privacy Notice of Card holders of the EKO SMILE program
1. Object
The present notice describes our practices with respect to the collection and processing of your personal data, which are conducted within the framework of the organization of the EKO SMILE program. For this processing, the Data Controller for the needs of the present notice shall be the company of the Group “HELLENIC FUELS AND LUBRICANTS SINGLE MEMBER INDUSTRIAL AND COMMERCIAL S.A.”, seated in Marousi Attica, 8A Cheimarras Street, 15125 (hereinafter referred to for brevity as the “Company”).
The Company reserves the right to amend and to adjust the present notice whenever this is determined necessary, while the changes from time to time enter into force from their notification to you, either through the EKO SMILE application or through the webpage www.ekosmile.gr, or in any other manner, which the Company determines as appropriate.
2. Sources of data collection
Your personal data are collected in one of the following manners:
Through the EKO SMILE application (available for mobile telephones)
In order to receive an EKO SMILE card in digital form, the Company needs certain personal information of yours, which you provide to the Company yourselves through your complete registration in the EKO SMILE program by using the application.
Through the web page www.ekosmile.gr
In order to receive the EKO SMILE card in digital form, the Company needs certain personal information of yours, which you provide to the Company yourselves, by filling in the relative application on the web page of the EKO SMILE Program www.ekosmile.gr
By submitting your application for registration at the petrol stations, which bear the EKO sign
In order to receive the EKO SMILE card in physical form, the Company needs certain personal information of yours, which you provide to the Company yourselves, through the competent employee of the respective filling station that you are visiting, who proceeds to your full registration in the EKO SMILE program via the CLM application.
3. Data being collected
For your registration in the EKO SMILE program, an account is created in order to obtain the EKO SMILE card (in digital or physical form). For your registration in the EKO SMILE program and for the creation of your account, the Company mandatorily collects the following categories of your personal data:
• Contact data (e.g. mobile telephone, email)
• Relative data for the registration and the creation of an account (e.g. entry codes)
Moreover, the Company, for your registration in the EKO SMILE program and for the creation of your account, might collect the following categories of your personal data, if you choose to provide them (optional collection):
• OTP code
• Communication channel for the processing and the promotion of informative and promotional material (e.g. email, sms, viber, push notification)
• Physical address data (e.g. city, street, number, Postal Code, prefecture)
By your successful registration in the EKO SMILE program and the creation of your relative account, you have the possibility to fill in also addition data to your above personal data, in order to have a complete profile in your account. Therefore, the Company is likely to collect – in addition to the above – the following categories of your personal data, if you choose to provide them (optional collection):
• Vehicle data (e.g. car type or model)
• Filling station data (e.g. favorite filling station)
In any case and at any time, you have the possibility to update your above personal data.
For the execution of the EKO SMILE program through the use of the relative (digital or physical) card, the Company is collecting the following categories of your personal data:
• Orders’ data (e.g. kind and price of the provided product or / and service)
The Company collects your personal data, which are necessary for your registration in the EKO SMILE program, the creation of your relative account and the execution of the EKO SMILE program, on the basis of its terms of use (www.ekossmile\pages/terms-and-conditions). The Company in no case collects special categories of personal data or data pertaining to criminal convictions and offences.
4. Purposes and Legal Basis of the Processing
The Company collects and processes your personal data, which are mentioned above, for one or more of the following purposes:
• In order to create and maintain your relative account in the EKO SMILE application or on the web page www.ekosmile.gr
• For the conclusion of the contract between us within the framework of the EKO SMILE program and for obtaining your relative (digital or physical) card
• For the performance of its contractual obligations with respect to the EKO SMILE program, to wit for granting and redeeming points through the (digital or physical) EKO SMILE card, issuing coupons, rewarding you on the basis of the terms of use of the EKO SMILE program through the attribution of discounts, rewards or / and offers, for ordering and sending the gifts to which you are entitled, as well as for any other purpose regarding the execution, the management and the fulfillment of the EKO SMILE program.
• For contacting you with respect to the execution in general and the financial management of the EKO SMILE program, on the basis of its terms of use, as well as in the event of an amendment of the EKO SMILE program
For fulfilling the above purposes, the Company is collecting and processing your above personal data, based on the legal basis of the performance of its contractual obligations (article 6, paragraph 1(b) of the GDPR), within the framework of the management and execution of the EKO SMILE program.
Your participation in the EKO SMILE program is voluntary and it is realized solely following your registration in the EKO SMILE program, and the creation of your relative account and if you have accepted the relative terms of use of the EKO SMILE program (www.ekossmile\pages/terms-and-conditions). We inform you that, in the event that you do not accept the relative terms of the EKO SMILE program or / and you do not realize your registration to this through the creation of a relative account, the conclusion of the contract between us and obtaining the relative (digital or physical) card shall not be possible. In addition, in the event that you obtain the said card, but you do not use it or you do use it but you refuse to declare to us the data required for the execution of the EKO SMILE program (e.g. declaration of a physical address for sending a gift), we inform you that the performance of the contract between us shall not be possible (e.g. issuing redemption coupons, ordering and sending gifts to which you are entitled, executing and managing discounts, rewards, offers, etc.).
In addition, the Company collects and processes your personal data mentioned above for one or more of the following purposes:
• For the security of the EKO SMILE program and of your personal account in the EKO SMILE application and on the web page www.ekosmile.gr and of your personal (digital or physical) card
• For contacting, servicing and supporting you in matters of secure access to your personal account through the EKO SMILE application and the web page www.ekosmile.gr
• For sending informative and promotional material directly related to the provided product or / and service (direct marketing)
• For the Company’s legal support
For fulfilling the above purposes, the Company collects and processes your above personal data based on its legal interest (article 6, paragraph 1 (f) of the GDPR) for the unhampered operation and the faster execution of the EKO SMILE program, for its more efficient communication with you and for exercising, establishing or / and defending judicial claims against it.
Finally, the Company, if it receives your consent (article 6, paragraph 1 (a) of the GDPR) by positive action (opt in) collects and processes your personal data mentioned above, in order to send to you commercial communication messages, which match your preferences and your personal profile in the account that you have in the EKO SMILE application and on the web page www.ekosmile.gr.
Following your consent, the Company processes the personal data that you yourselves have selected to state to the company (optional collection personal data) in one of the manners that are indicated above (see section 2 collection source), with the purpose of the personalized commercial promotion to you, on the basis of your preferences, from your purchases by the use of the relative (digital or physical) EKO SMILE card from any point of sale that is cooperating with the EKOSMILE program, as well as for your personalized or general information for the manners of collection and redemption of points and other rewards (offers, rewards or / and discounts) of gifts, coupons and other promotional actions, for our products or / and services, for conducting contests, as well as for the use in general of your relative card within the framework of the EKOSMILE program’s operation.
You are able to select the communication channel for the above purposes of commercial communication (see section 3 data being collected) and to give us your consent separately for each one or for all of the afore-mentioned processing purposes. Moreover, you have always and at any time the right to revoke your consent for each one separately or for all of the above purposes, by communication at the e-mail DPO@helpe.gr, as well as by deletion at the respective link of the web page www.ekosmile.gr or in the EKOSMILE application In the event that you revoke your consent, conducting the processing that is based on this shall no longer be feasible. The revocation of the consent does not affect the legality of the processing that was based on your consent prior to its revocation.
5. Period of retention
The Company retains the personal data that you provide yourselves to the Company through your registration in the EKOSMILE program and the creation of your account, pursuant to the applicable provisions of the Law and solely for the time period that is required for the fulfillment of the purposes mentioned above, and in any case until 5 years from the termination of the EKOSMILE program in any manner.
The Company is likely to retain the above personal data for a greater time period for the Company’s defense against potential judicial actions for the pursuit of claims. In this case, the data are retained by the Company until the delivery of a final judgment.
6. Information Security
The procedure for the processing of your personal data by the Company is conducted in a manner that ensures its confidentiality. Specifically, it is conducted exclusively and solely by the Company’s personnel authorized for this purpose, while all the appropriate organizational and technical measures are being taken for the security of the data and for their protection from accidental or unlawful destruction, accidental loss, alteration, prohibited dissemination or access and from any other form of unlawful processing. In any case, their security in the environment of the application and of the web page is subject to reasons that go beyond the sphere of its influence, as well as reasons that are due to technical or other weakness of the network that is not being controlled by the Company.
7. Transmission to Third Parties
The Company provides access to or transfers your personal data to:
• Third party service providers, which perform various services on behalf of the Company, and specifically telephone support services and cloud services, as well as to external advisors, associates, lawyers, accountants, auditors, but also to providers of technical and support services, as well as to IT consultants.
The processing of your personal data by the above bodies cooperating with us is conducted under our control and solely according to our mandate and it is subject to the same privacy policy or to a policy of at least the same level of protection.
8. TRANSMISSION TO THIRD COUNTRIES (OUTSIDE THE EU / EEA)
9. With respect to your Rights
You have a series of rights with respect to your personal data, which are subject to processing by the Company. More specifically:
➢ manifestly unfounded or excessive / repeated requests, or
➢ additional copies of the same information.
As long as we have the legal right to refuse your request, we shall inform you on the specific reasons for the said refusal.
• Right of rectification: You have the right to request the correction of your personal data, if these are inaccurate or incomplete. Within this framework, you have the right to update also on your own your personal data, which you have stated yourselves in the EKOSMILE application or on the web page www.ekosmile.gr.
• Right of erasure (or right to be forgotten): You have the right to request the erasure of your personal data, when these are no longer necessary for the purpose for which they were collected or when there is no legal reason for continuing their processing. The right of erasure is not absolute to the extent that there is a special legal obligation or other legal cause for the retention of your personal data by the Company. Within this framework, you have the right at any time to also erase yourselves the personal account that you are maintaining through the EKOSMILE application or the web page www.ekosmile.gr, by clicking “Account Deletion” at the relative point or by calling the EKO Consumer Contact Line 18198 & 2107725555.
• Right to restriction of processing: In certain cases, you have the right to restrict or to discontinue the further processing of your personal data. In practice, this means that we can store your data, but we shall not have the possibility to further process them, unless this processing is realized with your consent or this processing is required either for establishing, exercising or defending the Company’s legal claims or for protecting the rights of another person or for reasons of public interest.
• Right to object: You can object to the processing of your personal data, primarily when the processing is realized for purposes of the Company’s legal interest. If the processing is realized for purposes of serving its legal interests, the Company shall comply with your objection and shall cease the specific processing, unless the Company can indicate compelling and legal reasons for the processing, which prevail over your interests, rights and freedoms or the said processing is being realized for establishing, exercising or supporting legal claims of the Company. Therefore, if the processing has at a significant degree as legal basis the performance of contractual obligations, the exercise of these rights may affect the fulfillment of the obligations that derive from our contractual relationship or, in extreme cases, these may render the performance of the contract impossible.
• Automated individual decision making, including the profile creation
You have the right not be subject to a decision that is taken exclusively on the basis of an automated processing, including the creation of a profile, which generates legal results that regard you or which significantly affects you in a similar manner. The Company proceeds to an automated individual decision making solely if it receives your consent, by creating your relative profile, by taking into consideration the data that you give to it and the data that result from the use of the EKOSMILE program, with the purpose to send you commercial communication messages, which match your preferences and your profile and to adapt its services and products being provided to your individual needs. The creation of a profile for the above purpose does not generate certain legal results, which regard you or which significantly affect you in a similar manner.
10. Filing a complaint
For further information and advice with respect to your rights or for filing a complaint, you can contact the Hellenic Data Protection Authority (DPA), tel: +30-210 6475600, web page: http://www.dpa.gr.
You can contact the Hellenic Data Protection Authority in the following manners:
Postal Address: Hellenic Data Protection Authority, Offices: 1-3 Kifisias Avenue, Postal Code 115 23, Athens
Telephone Center: +30-210 6475600
Fax: +30-210 6475628
12. Information of the Data Protection Officer of the Group HELPE
Telephone | +30 210 6302252 |
Εmail: | DPO@helpe.gr |
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