General

This Privacy Statement sets out how EXCLUCY LTD will store and use information relating to you, and applies to the entire web site www.exclucy.com (“Website”), and stores.

Processing of your personal data is governed by these terms, by the relevant provisions of Cypriot and EU legal framework on data protection, including the General Data Protection Regulation (2016/679) and the relevant decisions, guidelines and regulation issued by the Hellenic Data Protection Authority.

Any changes to this Privacy Statement will be posted on the Website.

Our approach to privacy and security

EXCLUCY LTD is committed to protecting your privacy. Where you provide us with any information by which you can be identified, then we will only use it in accordance with this Privacy Statement.We have taken all the essential measures to make sure that any information you give us, including credit card details, remains private and secure and that your payment and registration information is processed with total confidentiality. When you place orders or access account information, we offer the use of a secure server. The secure server software (SSL) encrypts all information you input before it is sent to us. Furthermore, as required by the relevant legislation, we follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorised access. Our security procedures mean that we may occasionally require proof of identity before we are able to disclose sensitive or other information to you. If you have any further questions about our credit card security policies, please contact us.

What we collect

We collect the information that you provide to us via the Website or in any of our stores, which may include the following:

• where you order products, we will collect your name, contact details and billing information, transaction and credit card information.
• when you visit our Website, we may record the URL you came from, IP address, domain types like .gr and .com, your browser type, the country and telephone area code where your computer is located, the pages of our website that were viewed during your visit, the advertisements you clicked on, and any search terms that you entered on our website.
• when you register with us to receive our e-mails or details of offers or products, we will collect your e-mail address;
• when you register with Family Points via the Website or in store we will collect your e-mail address and personal details, some of which are sensitive details and you may opt not to provide us with them;
• we may ask you to you provide us with information about you and your family so that the details of offers and products we send you will be more suited to your circumstances;
• when you visit our Website, we use cookies, which are programs which collect additional information. We strongly advise you to read our Cookies Policy  in order to learn more about Cookies, how we use them and how you can control the use of Cookies.

How is your personal data collected?

We use different methods to collect data from and about you including:

Direct interactions. You may give us your identity, contact details and other data by filling in forms or by corresponding with us by email, phone or otherwise. This includes personal data you provide when you:

• buy our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• register for our Loyalty programme.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:

(a) analytics providers such as Google;

and

(b) search information providers such as;

What do we do with the information we gather?

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.
• Processing your orders.
• To analyse the use of the Website, for example: when you visit our Website, we may record when and how you interact with our Website. This information is retained and used to note your interest in our Website, improve customer journeys and personalize your experience where possible.
• We may use the information to improve our products and services.
• To contact you about leaving a review on a product once your order has been completed. If you do not wish to be contacted for this purpose, please click the unsubscribe button you will find on the review email.
• If  you provide us your consent we will send you survey and feedback requests to help improve our services. If you do not wish to be contacted for this purpose, please click the unsubscribe button you will find on the service review email.
• We collect information through cookies and other similar technologies (e.g. pixel tags or links), to remember you when you visit the Website so we can improve your online experience to suit your needs (see our cookie policy below for further details). These help us understand how you view our products and respond to our advertising, so we can enhance our overall offering.
• If you consent to send to you promotional e-mail about new products, special offers and services or other information from EXCLUCY LTD unless you have asked us not to do so when you registered as a user on this site and/or where you update your marketing and communication preferences. To manage your marketing and communication preferences, please go to the preferences section in your account.
• Your personal information may be disclosed to selected third party companies which will help us to process your order, to comply with our obligations, to manage and store data, to run our marketing campaigns and/or provide data analytics. These third parties will never contact you for marketing purposes. To see a list of the third parties we work with, please contact us on info@exclucy.com EXCLUCY LTD requires all such third parties to treat your personal information as fully confidential and to fully comply with all applicable Data Protection and consumer legislation and regulations in place.
• We will use the personal information we hold about you (as well as pseudonymised or anonymised information generated from your personal information) to carry out analysis and research, including: data analytics, whereby we combine information (such as personal information and/or sensitive personal information we have obtained through the use of Exclucy’s website or from your browsing history) we hold on a large scale in order:

1. a) to learn more about our customers and their preferences;
2. b) to identify patterns and trends amongst our customers;
3. c) enhance user experience on our websites;

• If you provide your consent to receive targeted advertising based on your preferences or customer segmentation, we will use automated means to process information you provide and the history of your transactions through our Website in order to send you news, special offers and promotional material that is relevant to your profile and preferences.
• For general research and statistical purposes;
• For aggregated reporting purposes within Exclucy;
• Develop new products and services;
• Monitor performance of our products and services and/or improve our technology;
• If you provide your consent we will be able to send you personalised marketing messages; and to display online ads to you.
• If we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your Personal Information and /or User Information, we are entitled do so.

Competitions

We regularly run competitions and prize draws and, in addition to your answer or entry, we will require you to send us certain information, such as your name and email address. We will only use this information to administer the competition prize and for any other purpose to which you consented when you entered.

This means that whenever you choose to enter into a prize draw or competition by completing a submission form, we will collect the following personal data from you:

• name (first name and surname); and
• email address
• cell number

If any Competition also needs other personal data to be provided about you, this will be made clear by the entry fields you need to complete to enter into the Competition. If you are a winner, we may also collect additional personal data from you that you provide to us to enable us to make any prize available to you.

 

How will we use the personal data about you:

We will use your personal data for each of the purposes set out here in this section:

• Entry into the Competition: where we gather the personal data, you provide to enter into the Competition and where you have consented to third parties to receive your data, we and/or the third party will process your entry into the Competition. As the Promoter, we may use third parties to assist us in providing the Competition. If this is the case the third party will be named in the Competition terms and conditions. In addition, where we do so, we will ensure there is a contract in place which covers their services to us, and which includes data protection requirements.
• On-going Communications in connection with the Competition: This personal data may also be used by us and/or third parties assisting with providing the Competition, to communicate with you on any matter relating to the Competition and to administer prizes.
• Publication of Entries: Your name may also be used by us with your consent in publication of Competition winners, social media channels, such use will be set out in any Competition terms and conditions.

You may unsubscribe from our contact list at any time by clicking “unsubscribe” in any email you receive, by e-mailing us at info@exclucy.com

International transfers of your personal data

Unless stated otherwise, we store and process your personal information in the European Union. There will, however, be occasions when we need to transfer your personal information outside of the European Economic Area (“EEA”) to a country which does not provide the same level of data protection as the country in which you normally use our products and/or services. In these circumstances we will take appropriate steps to ensure that your personal information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as us, so your data is adequately protected.

 

Online media channels

We may use information from online media sources such as websites, social media and information sharing platforms. This information may be used to help tailor and improve our services and communicate with you effectively. Where we use information from these sources, we will respect any permissions you have set about how you would like your information to be used. We recommend you routinely review the privacy notices and preference settings that are available to you on any online media channels, so these can be followed.

Your rights

• Right to access to your personal data: you have the right to obtain information as to whether or not your personal data is being processed, and, where that is the case, access to it. To access your personal data, please contact us at info@exclucy.com
• Right to rectification: you have the right to rectify inaccurate personal data concerning you. To request any rectification of your personal data, please contact us at info@exclucy.com
• Right to erasure: you have the right to request erasure of your personal data. To request erasure of your personal data, please contact us at info@exclucy.com
• Right to restriction of processing: you have the right to restrict the processing of your personal data, when you indicate that the data is inaccurate, or where you have requested the deletion of your data or when you have objected to the processing of your data. To request restriction of the processing of your personal data, please contact us at info@exclucy.com
• Right to data portability: you have the right to receive your personal data, in a structured, commonly used and machine-readable format and have the right to ask us to transmit that data to another controller. To request portability of your data, please contact us at info@exclucy.com
• Right to object: where we process your data based on our legitimate interest to do so, you have the right to object. To object, please contact us at info@exclucy.com
• Right to Obtain Human Intervention: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. To obtain human intervention, please contact us at info@exclucy.com
• Consent withdrawal: you have the right to withdraw at any time your consent to the processing of your personal data for marketing purposes and/or targeted advertising. In such case, their processing by us will be suspended, nevertheless this will not impact the legitimacy of any processing performed until the time of withdrawal. To withdraw your consent, please contact us at info@exclucy.com

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Links to other websites and services

Our websites may contain links to third party websites, and some of our services provide you with access to third party services.

We have no control over how third party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third party websites and services or their privacy practices. Please read the privacy statements of any third party websites or services that you access from our websites or services.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on info@exclucy.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and we will ensure that they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will retain your data for 5 years from the last incident of use of our services. Consequently, your data will be deleted. You can request that we stop communicating marketing material to you and/or that we delete your data at any time.

Contact us

If you have any questions about this Privacy Statement, please contact:

Rizokarpasou 13B Trachoni, P.C.4651 Limassol,Cyprus

EXCLUCY LTD

E-mail: info@exclucy.com