Privacy Policy – Personal Data Protection Policy

Last updated: 20 January 2026

1. INTRODUCTION

This Personal Data Protection Policy (“PDPP” or “Policy”) governs the access to and use of the website and e-shop thecaviarhouse.com (hereinafter, the “Website” and the “E-shop”), operated by the Greek company CAVIAR SINGLE MEMBER PC, based in Epano Vrysi, Mykonos PC 846 00, Greece (TIN: 801180240 / Tax Office of Mykonos / GCR No. 151171238000) (hereinafter referred to as the “Company”).

Any natural person visiting the Website or using its services is referred to as a “Personal Data Subject” or “Subject”.

The Company manages and protects your personal data in accordance with Greek law (Law 4624/2019 and other applicable provisions), EU law (Regulation (EU) 2016/679, GDPR), and relevant international law. Future changes in the regulatory framework will be incorporated into this Policy.

This Policy informs you about:

The purpose of processing your personal data
The categories of data collected
Your rights and how to exercise them

This Policy is an integral part of the General Terms of Use of the Website. By using the Website or E-shop after any amendments to this Policy, you are deemed to accept them unconditionally. If you do not agree, please stop using the Website and E-shop.

For clarification or legal inquiries regarding your data, contact our Customer Service or Data Protection Officer (DPO) at concierge@thecaviarhouse.com.

Data Controller:
CAVIAR SINGLE MEMBER PC
Epano Vrysi – Mykonos PC 846 00, Greece
TIN: 801180240 / Tax Office of Mykonos / GCR No. 151171238000
Email: concierge@thecaviarhouse.com

2. PERSONAL DATA PROTECTION POLICY

2.1 Definition of Personal Data

Personal data is any information relating to an identifiable natural person, including but not limited to:

Name, surname, address, email, phone number
Date of birth, gender
Account credentials (username, password)
IP address, browsing habits, and other usage data

2.2 Collection and Processing of Personal Data

Browsing the E-shop does not require personal data. Personal data is collected and processed only when necessary, for example:

(a) Orders: Name, surname, email, phone number, shipping/billing addresses, payment details (masked), invoice details.

(b) Newsletter Subscription: Email address for marketing communications. Email may be forwarded to Shopify International Ltd, our third-party processor.

(c) Customer Service: Name, surname, email, phone, order code. Calls may be recorded for service purposes.

(d) Account Registration: Name, surname, email, password.

(e) Third-party gift orders: If you provide data for third parties, you confirm they have consented to sharing their data for order processing.

2.3 Purpose of Collection and Processing

Data is processed for:

Completing purchase agreements, payment verification, shipping, refunds, and handling Gift Cards or third-party gifts.
Providing registered-user services.
Sending newsletters and promotional communications.
Customer service communications.
Improving products and services via statistical analysis and market research.

Processing is legal as it fulfills contractual obligations, provides requested services, or is based on consent.

2.4 Personal Data Retention

Data is retained:

For the duration of your contract with the Company
In accordance with Greek tax and accounting law (e.g., invoices retained for 10 years)
Marketing data until withdrawal of consent
Recorded calls and communications as required for service purposes

2.5 Personal Data Receivers and Forwarding

Your data may be forwarded only to:

Courier companies for product delivery
Payment processors: Stripe, PayPal, credit card providers
Third-party marketing and promotion services
Technical service providers (hosting, IT support)
Shopify International Ltd, for email marketing

Non-EU transfers are carried out with appropriate safeguards (e.g., Standard Contractual Clauses). The Company does not sell or share data with third parties except under legal obligation.

2.6 Consent of the Data Subject

By using the Website or E-shop, you confirm that:

You are 16 years or older.
You consent to processing of your personal data as described in this Policy.

Specific scenarios:

2.6.1 Sign Up / Account Creation: Consent to use data to complete transactions.

2.6.2 Order Completion: Consent for processing required to fulfill orders and refunds.

2.6.3 Gift Orders / Third-Party Data: You confirm consent of the third party.

2.6.4 Marketing / Newsletter: You consent to receive promotional communications. You may withdraw consent anytime by contacting concierge@thecaviarhouse.com or using the unsubscribe links.

2.6.5 Fraud Prevention: Data may be used to prevent or detect illegal or fraudulent activity.

2.6.6 Legal Requests: Data may be shared with competent authorities when required by law.

2.7 Transfer and Storage of Data

Data transfer between your browser and the Website is encrypted via HTTPS. Data is stored on secure servers with appropriate technical and organizational measures (GDPR Art. 32).

2.8 Rights of the Data Subject

You have the following rights, subject to applicable conditions:

Right to information – what data is processed and why
Right of access – confirmation and copy of your personal data
Right to rectification – correct inaccurate or incomplete data
Right to erasure – request deletion of data
Right to restriction of processing – under specific conditions
Right to object – withdraw consent or object to processing
Right not to be subject to automated decision-making – including profiling
Right to data portability – receive data in machine-readable format or forward it to another provider

You may exercise these rights by contacting concierge@thecaviarhouse.com. Requests are processed free of charge within 1 month (extendable by 2 months for complex cases).

You also have the right to lodge a complaint with the Hellenic Data Protection Authority: https://www.dpa.gr/.

2.9 Legislative References

EU GDPR – Regulation (EU) 2016/679
Greek Law 4624/2019 – Protection of Personal Data
Greek Law 3471/2006 – ePrivacy & cookies

3. COOKIES

Please refer to the Cookie Policy of the Website. Non-essential cookies require your consent and may be managed via the cookie banner.

4. FINAL NOTES

The Company may update this Policy at any time. Material changes will be communicated via prominent notice or email.
Continuing to use the Website or E-shop after updates constitutes acceptance of the changes.

Thank you for trusting TheCaviarHouse.com.

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