NOTICE ΟΝ PRIVACY AND PERSONAL DATA PROCESSING

Last updated: March 06, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to MAS SUPERMARKETS, the software program provided by the Company.
  • Appstore refers to the Apple AppStore or the Android Appstore
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to MAS SUPERMARKETS, 13 A Ermou Str, Industrial Area Idaliou Nicosia, 2548.

For the purposes of the GDPR, the Company is the Data Controller.

  • Country refers to: the Republic of Cyprus.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
  • GDPR refers to the European Union General Data Protection Regulation.
  • Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.

  • Service refers to the Application.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You, means and refers to the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

GENERAL TERMS

SYK Anemos Supermarkets Ltd (ΗΕ69266) and “MAS SUPERMARKETS” Group (hereinafter “the “Company”, or “we”), occasionally collects and processes personal data for the purpose of providing services to the public, customers, employees of the Company and “MAS” stores (hereinafter “you”, “your”), in the context of different types of competitions, promotions and related activities conducted by the Company at the stores or on the internet and various social media platforms (hereinafter “Competitions”), in the manner and for the purposes described herein.

This Privacy Notice contains all the information that the Company, being the data controller under the law and the General Data Protection Regulation, Regulation (EU) 2016/679 (“GDPR”), must provide to you, as the subject of the collected and processed data.

This Privacy Notice is attached to and forms an integral part of the Contract that our Company forms with you. By completing your entry form for each competition, you confirm that you have thoroughly read and fully understood and comprehended this Privacy Notice and its contents.

  1. The Personal Data We Collect and Process

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  1. Name and surname,
  2. Identity card or passport number,
  3. Address and Postal Code,
  4. Telephone number,
  5. Possibly photos you have posted or uploaded as profile pictures on various social networks.
  6. Usage Data (as explained below)
  7. Social Media Profiles
  1. Usage Data maybe collected automatically when using the Service.
  1. Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
  1. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
  1. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company and the Service may allow You to create an account and log in to use the Service through the following Third-party Social Media Services including but not limited to:

  • Google
  • Facebook
  • Twitter
  • LinkedIn

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

  1. Purpose of Data Collection

The purposes for which we collect and use your personal data are the following:

  • To fulfil our contractual obligations
  • To comply with our legal obligations
  • To safeguard our legitimate interest
  • To communicate with you about the outcome of the competition
  • To acknowledge the competition winner
  • To announce and promote the competition winners on social media or on our website, following your express consent.
  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to advertise on third party websites to You after You visited our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We neither collect nor process any of your personal data other than those explicitly mentioned above, and we do not use your personal data without your explicit consent unless you ask us to do so.

We do not use automated decision-making or profiling methods when processing your personal data.

Once you complete and sign the participation form in any competition of our company or our stores, you expressly agree and accept the collection and processing of the above-mentioned personal data by our company, as well as the provisions of this notice.

  1. Data Storage and Protection

We keep, store and process your personal data at the Company’s offices.

For the safekeeping and protection of your personal data, the Company takes all necessary technical and organizational measures to ensure that the processing is carried out in accordance with the law and the GDPR (controlled access, firewalls, antivirus, data encryption, etc.).

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

  1. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

  1. Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability
  1. 6. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

  1. 7.  Access to your Data

Within our Company, your personal data may be accessed only by those who need to have access to it, and who are bound to a duty of confidentiality and only for the purposes outlined in paragraph 2.

Outside our Company, recipients of your personal data may be third parties who provide services to our Company in the context of its business operation, such as technical service companies, IT services, software providers and maintenance companies. The choice of partners is made very carefully, after thorough checks and sufficient assurances on the implementation of appropriate technical and organizational measures in such manner that the processing is carried out in accordance with the GDPR and the relevant legislation, ensuring the protection of your rights.

External recipients of your personal data may include third parties who may have access to your data on our website and social networks, for the purposes mentioned in paragraph 2.

  1. 8.  Data Storage Period

In accordance with our Company’s policy, your data is kept only for as long as necessary to fulfil the purposes of the Contract and this Privacy Notice, or, where collection and processing is done with your consent, until your consent is withdrawn. In addition, we retain your personal data for as long as necessary to comply with tax law, to exercise our legal rights and to safeguard our legitimate interests.

After this period, your personal data will be irretrievably destroyed. Any data that may be held by us for the purposes of promoting our services will be held until you notify us that you no longer wish to receive this information.

  1. 9.  Data Transfer to Third Countries

In the case that your data is transferred to entities or other third parties that are based or have a personal data processing site in a country that is not a member of the European Union or the European Economic Area, before we transfer the data we ensure that, except where lawfully permitted in exceptional circumstances relating to the recipient, there is an appropriate level of data protection (e.g. through a European Commission adequacy decision, through appropriate assurance such as self-certification by the recipient for the EU-US Privacy Shield, or agreement through Standard Contractual Clauses between our Company and the recipient), or consent from you.

We can provide you with a list of recipients in third countries and a copy of the agreed regulations which ensure adequate data protection. To request and obtain these, please contact our Data Compliance Officer at [email protected]

  1. Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

  • Measure and analyze traffic and browsing activity on Our Service
  • Show advertisements for our products and/or services to You on third-party websites or apps
  • Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

  • Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

  • Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266

To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

  1. 11.  Your Rights

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/massupermarkets/, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

Children’s Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you believe that any of your personal data that we hold is incorrect or inaccurate, you may request to view it, have it corrected or deleted by contacting us at [email protected]  or by calling the following number: 00357 22 015964.

If you wish to make a complaint about the way we handle your personal data, you may contact us at the above email address and telephone number. We will look into your complaint and work with you to resolve it.

If you still believe that we have not handled your personal data in accordance with the law, you may submit your complaint to the office of the Data Protection Commissioner, 1 Iasonos street, 2nd Floor, 1082 Nicosia, tel. +357 22 818456, email-address: commissioner@dataprotection.gov.cy.

IN ANY CASE, YOU HAVE THE STATED RIGHT TO CONTACT US AT ANY TIME AND REQUEST THE IMMEDIATE DELETION, WITHDRAWAL AND REVOCATION OF THE PROCESSING OF YOUR PERSONAL DATA BY OUR COMPANY BY CONTACTING US AT THE E-MAIL ADDRESS [email protected].

DISCLAIMER:

BY PARTICIPATING IN ANY GIVEAWAY OR COMPETITION OR ACCEPTING THE PRIZE, THE WINNER GIVES HIS CONSENT TO THE COMPANY TO PUBLISH HIS NAME AND CITY OF RESIDENCE COLLECTED FROM THE COMPETITION, IN ANY MEDIA AND/OR SOCIAL MEDIA NETWORK. THIS RIGHT IS NOT LIMITED TO THE USE OF THE WINNERS’ NAMES BUT MAY INCLUDE THE USE OF A PHOTOGRAPH TAKEN OF THE WINNER AND THE PRIZE FOR USE VIA TELEVISION, PRINTED, ELECTRONIC OR WEB-BASED MEDIA. REFUSAL OF A WINNER TO INCLUDE HIS NAME AND PHOTOGRAPH GIVES THE COMPANY THE RIGHT TO REFUSE DELIVERY OF THE PRIZE.

THE SERVICES IS WHOLLY AND FULLY OPERATED BY OUR COMPANY AND AFFILIATES AND APPLE, ANDROID OR ANY OTHER PROVIDER USED TO DOWNLOAD THE APP OR THE SERVICE HAS NO CONTROL, LIABILITY OR RESPONSIBILITY AGAINST YOU OR REGARDING ANY PRIZES, COMPETITIONS OR GIVEAWAYS PROVIDED THROUGH THE APP AND THE SERVICE.

THIS SERVICE IS THE SOLE PROPERTY OF THE COMPANY AND ALL INTELLECTUAL PROPERTY RIGHTS ARE VESTED TO THE COMPANY. THE GIVEAWAYS, SWEEPSTAKES AND COMPETITIONS FEATURED OR AVAILABLE THROUGH THE SERVICE ARE THE SOLE PROPERTY AND RESPONSIBILITY OF THE COMPANY AND APPLE INC. (APPLE APPSTORE) OR GOOGLE INC. (GOOGLE PLAY STORE) STORE, DO NOT HAVE ANY LIABILITY, RESPONSIBILITY, OR EXPOSURE AS IT CONCERNS SUCH COMPETITIONS, GIVEAWAYS OR SWEEPSTAKES AND ARE NOT INVOLVED WHATSOEVER IN THEM.