Privacy policy

Privacy Policy - Personal Data Protection Policy

1. INTRODUCTION

This Personal Data Protection Policy governs the access to and use of the Website and the E-shop thecaviarhouse.com.

Thecaviarhouse.com is the "Website" and the "E-shop" for the exhibition and distribution of products (caviar) via the Internet, managed and maintained by the Greek company under the name "CAVIAR SINGLE MEMBER PC", based in MYKONOS (EPANO VRYSI - MYKONOS PC 846 00), in Greece (TIN: 801180240/Tax Office of MYKONOS/GCR No. 151171238000) (hereinafter referred to as the "Company").

Any natural person visiting the website pages or using the services shall be herein referred to as “Personal Data Subject” or “Subject” for the sake of brevity.

Management and protection of your personal data is governed by the terms of this announcement and the relevant provisions of both the Greek and the EU and international law regarding the protection of the individual against the processing of personal data and the Decisions of the Hellenic Data Protection Authority. Any future change in the above regulatory framework will be included in this Policy.

This Personal Data Protection Policy (hereafter the “Data Policy” or “PDPP”) aims at informing you on the policy of the Company as regards your personal data, which you share with us, so that you are aware of the purpose of its processing by us, the category of receivers and the procedures that you can follow to exercise your legal rights.

This Policy constitutes an integral part of the General Terms of Use of thecaviarhouse.com and a whole together with them. The Company acting as a Data Controller can occasionally amend its Terms and Policies, including the “PDPP”, in whole or in part, at its sole discretion. Any amendment hereto shall take effect as soon as the amended Policy is posted on the Website. Hence, we advise you to regularly check its content.

In any event, as long as you continue to use our Website and its services and the services of our E-shop thecaviarhouse.com after amendments have been made according to the above, you will be deemed to unconditionally accept such amendments. If you do not agree with the terms of this Policy, as may be amended, you must stop using the Website and our E-shop.

Your confidentiality as well as the safety and protection of your personal data are very important for the Company. For this reason, we collect and manage your personal data with the utmost care, with responsibility and we take special measures to protect it with safety. In order for you to have detailed information on how the Company manages your personal data, we invite you to read the following Data Policy, where you will find all the essential information on the processing of your personal data by the Company, regarding your thecaviarhouse.com browsing and using the services offered.

We also urge you to read the "Cookie Policy" and "General Terms of Use" of thecaviarhouse.com, which contain detailed information on the conditions regarding the services we provide to you. Some services may be subject to certain legal conditions and regulations. In these cases, we will make sure that you will be provided with all the necessary information.

The Company shall not be responsible in any way for the Personal Data Protection and Management Terms of other websites which you may access through links of this website.

For any clarification, question or legal requirement on your privacy and the processing of your personal data, you may contact us at any time by sending a request to the Customer Service Department stating the request as “confidential” via an email to concierge@thecaviarhouse.com. If you wish so, you can also contact the Data Protection Officer (DPO) by sending an email to concierge@thecaviarhouse.com or a letter through the post office to the “Data Protection Officer”.

 

Data Controller:

"CAVIAR SINGLE MEMBER PC CAVIAR RETAIL TRADE"

EPANO VRYSI - MYKONOS PC 846 00

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 shall mean any information relating to the data subject, that is any information relating to the natural person to whom the data is related and who is identified or identifiable. Such data, as defined by the Law and the relative European provisions, is, for example, the name, the address, the date of birth and the sex of the member, the mobile number, the email address as well as any usage data, such as the username, the password and the IP address.

2.2. COLLECTION AND PROCESSING OF PERSONAL DATA

To simply browse our E-shop you do not need to provide any personal information of yours to the Company. However, while you browse or use the services offered by thecaviarhouse.com, the Company collects and processes browsing data through cookies that relate solely to your shopping habits.

The categories of personal data that the Company collects and processes when you visit/browse the Website and the E-shop thecaviarhouse.com are the following:

(a) we collect the necessary Personal Data which, in accordance with the Law and the General Terms of Use, is deemed necessary in order for us to complete, execute and ship your order. These include, but are not limited to, Name and Surname, Email Address, Contact Phone Number (fixed and mobile), Product Shipment Address (street, city, postal code, country), Order Billing Address and Payment Details such as Credit/Debit Card Mask, and the Document Type you want us to issue (Receipt or Invoice). In case you request the issue of an invoice, you will be asked for your company details such as Company Name, Vat Number, Tax Office, Activity, Registered Office Address and Contact Phone Numbers (fixed and mobile).

(b) we collect your email address when you sign up for our Newsletters, for the purpose of sending you newsletters about the Company, thecaviarhouse.com, its products/services, any offers, gift card.  If you choose to participate in our email newsletter, the email address that you share with us may be forwarded to the company Shopify International Ltd, which provides us with email marketing services. We consider that Shopify International Ltd  is a third-party data processor (Paragraph 2.5 below). Your email address will also remain in the database of Shopify International Ltd for as long as we continue using the services of Shopify International Ltd  for the email marketing services or until you explicitly request to unsubscribe from the list. You can do this by using the unsubscribe links that are included in all email newsletters that we send you. For as long as your email address remains in the Shopify International Ltd database, you will be regularly receiving email newsletters from us.

(c) we collect and process Personal Data, such as your Name, Surname, Email Address, Telephone Number and Order Code that you provide to us when you contact our Customer Service, to ensure that we will be able to contact you in order to help you with your current orders as well as to inform you on new products/services. For this purpose your calls will be recorded. If you choose to contact us using the Contact Form on the “Contact Us” page, none of the data you provide will be stored by this Website or transmitted/processed by any of the third-party data processors set forth in Paragraph 2.5. Instead, the data will be sorted into an email so that we can reply to you.

(d) we collect your Name and Surname, e-mail address, Password, when you register as a Member in thecaviarhouse.com and open an Account, in order to complete your purchases from our E-shop.

(e) in case you provide us with the personal data of a third-party (such as Name, Surname, Address, Telephone number) on thecaviarhouse.com (e.g. in the event you purchase a gift for a Third Party), thecaviarhouse.com will protect the Third-Party Personal Data in accordance with this Personal Data Protection Policy. If you provide us with personal data of third parties, you confirm that you have informed that third party of the purpose and manner in which we must process their personal data.

2.3 PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL DATA

The personal information you provide when you visit/browse the pages and services of thecaviarhouse.com website is intended and processed solely for the following purposes:

• for the conclusion and execution of the purchase agreement regarding the products offered by thecaviarhouse.com. Upon completion of your purchase, you will be required to provide the necessary Personal Data to ensure the performance of the contract, such as payment, necessary anti-fraud checks (in cases of credit/debit card payment), billing, product shipping and management of any return, for Gift Cards or gift orders when you provide personal data of third parties. The User who will nominate a third party for the dispatch of the Gift Card and gift orders bears the responsibility for the correctness of the information they declare to us and has received explicit consent from the third party for that purpose.
• for the provision of thecaviarhouse.com services, through your registration on the Website and the use of services intended only for Registered Users/Members. Registration on the Website is possible through the entry of specific Personal Information, necessary for the verification of the Identity of the Data Subject and the provision of the offered services to the registered users. For this purpose, the Company may collect, with respect to each service and its characteristics, the necessary Personal Data for the provision of the service requested by the Data Subject;
• for the sending of newsletters of the Company and thecaviarhouse.com, for commercial communication regarding our products and services, to inform you on the innovations, new arrivals, exclusive products and offers;
• for the communication between us and for managing your requests through the Customer Service Department;
• for the improvement of the provided services. Always with your consent, we can use your contact data within a market research and general researches on detecting satisfaction, in order to enhance our services and the relation with our users.
• for the purposes of statistical surveys and aggregated data analysis to understand how users interact with and use the thecaviarhouse.com Website, by improving our products and services.

In the above cases, the processing of your Personal Data is considered legal as it aims at executing an agreement between you and us or providing a specific service that you have requested.

This data cannot be used by any third party without complying with the provisions in force.

2.4 PERSONAL DATA RETENTION PERIOD

The Company processes your personal data during the period that every contract is in force and, after expiry or termination of the latter in any way, for as long as it is laid down in the applicable legal framework from time to time.

More specifically, your personal data, which is processed by the Company, shall be retained mandatorily during the period required by the purpose of processing, for which it is subject to such processing and/or the applicable legal framework from time to time.

Upon the expiry of this period, the data is retained in accordance with the applicable legal framework for as long as it is provided from the termination of the business relationship or for as long as it is required for the defense of the rights of the Company before a Court or other competent Authority.

Recorded conversations shall be retained mandatorily during the period required by the purpose of processing, for which it is subject to such processing and/or the applicable legal framework from time to time.

2.5 PERSONAL DATA RECEIVERS AND PURPOSE OF ITS FORWARDING

Your Personal Data is subject to processing by the Company which acts as a Data Controller.

For organization and operation requirements related to the provision of products and services by thecaviarhouse.com, the Company can forward your personal data to its representatives and/or subcontractors in order to support, promote and execute your transaction with them, but always under conditions that completely ensure that your personal data is not subject to any illegal processing, that is, other than the purpose of the forwarding according to the above.

The Company reserves the right to forward your Personal Data:

• to the Courier companies with which it cooperates, as mentioned in the General Terms of Use, in order to ensure the shipment of the products you selected from the E-shop thecaviarhouse.com to you;
• to credit card providers for them to process payment made by you, in order to ensure that the products you selected from the E-shop thecaviarhouse.com are shipped to you;
• to third parties, natural or legal persons, that may provide on behalf of the Company promotion and marketing services both of the Company and its products or services;
• or to third-party collaborators of us, who provide technical services, such as host and technical support services;
• to the company Shopify International Ltd which is a third-party data processor.

All collaborators, representatives and/or subcontractors have been assessed and selected by the Company for their proved trustworthiness and ability and all comply with the law laid down in the above paragraphs. In case some of them are based in countries which are not members of the European Union, forwarding of your Personal Data shall be carried out with the guarantees laid down by the Law.

The Company and thecaviarhouse.com will not sell or in any other way forward to or share the personal data of the Subjects of its Website with third parties, apart from the above-mentioned ones, without the consent of the Subject, except for the implementation of relative legal obligations and only as regards the Competent Authorities. Retained data of the file may be shared with the Competent Judicial, Police and other Administrative Authorities upon their legal request and in accordance with the applicable legal provisions from time to time.

Also, in case of a legal provision, service order or official preliminary examination, thecaviarhouse.com and the Company reserve the right to put the relative data at the disposal of the corresponding authority.

2.6 CONSENT OF THE SUBJECT

By conducting any of your transactions and using any Service at thecaviarhouse.com, you agree to declare, in accordance with the General Terms of Use of thecaviarhouse.com, that you are over 1 years old and to accept and consent to this Personal Data Protection Policy and in particular:

2.6.1 Sign Up as a Member - Create an Account

When you sign up as a Member, if you enter into your Member Account your Personal Data, you agree that thecaviarhouse.com can use this data for all necessary purposes in order to successfully complete its transaction with you.

2.6.2 Completion of order

Upon completion of your order, if you enter your Personal Data, then you agree that thecaviarhouse.com can use this data for all necessary purposes to successfully complete its transaction with you. Furthermore, you agree that thecaviarhouse.com will use these data for any refunds to you in the event of you exercising the Right of Withdrawal in accordance with the General Terms of Use and the Law.

2.6.3 Gift Cards or gift orders when you provide personal data of third parties

If you enter Personal Data on behalf of third parties, by filling in the special form that you will find on the Website, for gift orders or Gift Cards, you agree that thecaviarhouse.com can use this data for all necessary purposes to successfully complete its transaction with you. The User who will nominate an other person for the dispatch of the Gift Card and gift orders bears the responsibility for the correctness of the information they declare to us and has received explicit consent from the third party for that purpose. 

2.6.4 Marketing and Advertisement Actions

By subscribing to the newsletter service at thecaviarhouse.com you agree that thecaviarhouse.com will process and use your personal information for advertising activities, e.g. sending emails containing general information or of advertising nature (newsletters) regarding the Company, its products and services.

If you wish so, thecaviarhouse.com will waive its right to use your Personal Data for advertising purposes under the condition, however, that you will request or follow the corresponding procedures to unsubscribe from the list of the registered members who receive the newsletters of thecaviarhouse.com. You may, at any time, send an email to concierge@thecaviarhouse.com or customize accordingly your newsletter settings or unsubscribe from newsletters in your Member Account by following the procedures set forth in each email newsletter you receive from us.

2.6.5 Processing as regards deceptive practices

By completing a transaction at thecaviarhouse.com you agree that, in case there are reasonable data and if required by the specific circumstances, thecaviarhouse.com will have the right to collect, process and use all the data necessary for the disclosure, as well as for the termination of offers created for fraudulent purposes, as well as the details of any other illegal or unconventional use of thecaviarhouse.com.

In addition, according to the Law, the Company must report to the Hellenic Data Protection Authority any illegal violation of the Personal Database of the Website or of the database of any third party of data processing to any and all relevant persons and authorities within 72 hours from the violation, if it is evident that the personal data that is saved in an identifiable form has been violated.

2.6.6 Forwarding to Legal Services in case and/or in the absence of a Legal Provision

Since forwarding of data is not allowed according to Law, you consent to the forwarding of your personal data to prosecution and supervisory authorities for the necessary protection from risks to state and public security as well as for the prosecution of criminal offenses.

2.7 TRANSFER AND STORAGE OF PERSONAL DATA

The transfer of Personal Data between the thecaviarhouse.com Website and your browser is carried out by encryption and is delivered via HTTPS.

Your data is stored on our servers in a secure location.

2.8 INFORMATION AND ERASURE RIGHTS OF THE SUBJECT

Provision of your Personal Data is a contractual obligation. You are free to choose whether you will share with us or not your Personal Data, but in the absence of the required data the conclusion or execution of the Sales Agreement and the satisfaction of your requests by our Company will not be possible.

In the event of a Product Sales Agreement through thecaviarhouse.com, the processing of the Subject's data will be performed solely for the purpose of enabling the Company to fulfill its legal obligations and comply with the tax provisions and applicable law to which it is subject.

You are free to decide whether you will enter into a Sales Agreement with us and whether or not you will disclose your data. If, however, you enter into a Sales Agreement, your Personal Data will be necessary and processed to fulfill these legal obligations to which the Company is subject.

The Company carries out the following processing of personal data only in case the Personal Data Subject has explicitly consented to it:

• marketing activity, polling and market research;
  
• analysis of browsing and consumption habits in the environment using the Profile of the Personal Data Subject, with the sole purpose of creating a better and personalized shopping experience on our Website.

Provision of your Personal Data for these activities is absolutely optional. You are free to provide us with your Personal Data or not for this purpose, but in their absence the Company will not be able to carry out marketing and advertising activities, polling and market researches or analysis of your habits.

After verifying your identity as Personal Data Subjects you have the following rights:

Right to information	The COMPANY must inform you on the processing to which your data is subject, such as which data is processed, for what purpose, for how long it retains it, using clear and simple wording.
Right of access	You have the right to receive from the COMPANY a confirmation as to whether or not your personal data is processed and, if this is happening, you have the right to access this data.
Right to rectification	You have the right to demand from the COMPANY to rectify any inaccurate personal data of yours and to complete any incomplete data.
Right to erasure	You have the right to request from the COMPANY to erase your personal data, which can be satisfied provided some specific conditions are met.

Right to restriction of processing	You have the right to ensure that the COMPANY will restrict processing provided some specific conditions are met.
Right to object	You have the right to object, at any time, to the processing of your personal data. The COMPANY, in this case, must stop processing, except if it proves urgent and legal reasons which outweigh your interests, rights and freedoms as data subject or for the establishment, exercise or defense of legal claims.
Right to human intervention in the framework of a decision through an automated procedure	You have the right to request from the COMPANY that you do not undergo, if that is the case, a procedure of decision making solely according to an automated processing, including profiling, which produces legal effects that concern you or affect you significantly in a similar way.
Right to portability	You have the right to request from the COMPANY to receive your personal data, which you have provided, in a structured, commonly used and machine-readable format, or to be forwarded by the COMPANY to another provider.

 

In order to facilitate the exercise of these rights, the COMPANY shall ensure that internal procedures are developed so that it can respond in time and effectively to your requests.

At any time you reserve the right to information or objection to further processing of your data in accordance with the relevant Law on Personal Data Protection. For this purpose, any request of yours should be addressed in writing to the Company and thecaviarhouse.com either by sending the relevant e-mail to concierge@thecaviarhouse.com, or by phone to the Customer Service Department by calling 211 1088 555 on weekdays from 10:00 a.m. until 5:00 p.m.

If you think that your Personal Data has been retained illegally, you can submit a request to one of the Supervisory Authorities that are competent for compliance with the Personal Data Protection Rules.

We respond to your Requests free of charge, without any delay and in any case within (1) one month from the day we receive your request. However, if your Request is complicated or there is a large number of Requests from you, we will inform you within a month if we will need to extend the deadline for (2) two more months within which we will respond. If your Requests are clearly unfounded or excessive, especially due to their recurrence, the Company can impose the payment of a reasonable tariff, taking into consideration the administrative cost for the provision of information or the execution of the requested action or it can refuse to continue with the Request.

This text may be amended with time; hence we advise you to regularly check its content.

2.9 LEGISLATIVE REFERENCES AND USEFUL LINKS

The processing of the Personal Data of Users/Customers of thecaviarhouse.com is done by the Company, which also uses a Personal Data Protection Officer, based in the EU and subject to the terms of the General Data Protection Regulation (EU) 2016/679

and the European and Greek regulations for the processing of Greek personal data and audits of the competent Greek Audit Authority.

EU General Data Protection Regulation 2018 (GDPR)

THANK YOU FOR SHOPPING AT THECAVIARHOUSE.COM

Last update 31 March, 2021