This Privacy Policy is intended to help you understand why we collect your personal data and how we use it. We hope that everyone will take the time to read it carefully.

This policy applies to any of you who purchase and use our products or services through our points of sale (physical stores), by phone, apps or via our website.

Your own safety

When you make a purchase from us or use the services we offer, you are entrusting us with your data. This is why we put you first, listen to you and take your opinions and wishes into account, so that we understand your expectations and ensure that these are reflected in our business decisions. We are committed to maintaining your trust.

Our Company’s Privacy Policy provides detailed information about when and why we collect your personal data, how we use and process it, for how long we keep it and finally, under what conditions we may share it with others.

Data collection

When you visit one of our points of sale (e.g. stores, websites, social media), we request that you provide us with some information about yourself.

Such information may include:

• Personal data such as name, address, e-mail address, telephone number and other contact details. This data is collected when you purchase a product from our stores or when you first register with our online services, e.g. when you complete a purchase survey, make a comment on our social media pages (Facebook, Twitter, YouTube), participate in one of our contests, etc.
• Account information, such as your username and other identifiers or credentials used to access our online services.
• Information about you when considering your application for insurance and loans offered by our selected third party partners, such as employment details, financial status, information derived from identification documents such as your identity card, passport or driving license.
• IP address and Cookies data.
• Location.

Situations in which we ask you to provide us with your personal data:

• When you buy products through our call center.
• When you register to use our online services.
• When you request to receive updates on marketing promotions.
• When you enter one of our contests or complete one of our customer surveys.
• When you enroll in our rewards programs.
• When you submit requests.

How we process your personal data

We process your personal data when we intend to enter into a contract with you or for specific purposes, including but not limited to:

• Processing orders and payments for products and services you have purchased, or for refunds.
• Promotions relating to our products and services, or services offered by our partners that we believe may be of interest to you, in the event that we have obtained your consent to contact you.

We may use and process your personal data if you have given us your consent to do the following:

• Notify you when a product becomes available again.
• Contact you via e-mail or text message about our products and services, contests, offers, promotions or special events.
• To reward you for participating in the Company’s loyalty programs.

Legitimate interest

We may use and process your personal data where necessary based on our legitimate interests as a business for the following purposes:

• To provide support to our customers, to respond and communicate with you regarding your requests.
• To respond to questions, complaints, demands and comments.
• To contact you about your orders, purchases or accounts.
• To provide you with material which interests you and enable you to navigate our websites.
• To inform you about promotional activities (for which we rely on your consent), e.g. to customize communications or send targeted messages via social media and third party platforms.
• To conduct some data analysis, including consumer research, trend analysis and economic analysis.
• To help us understand more about you as customers, the products and services you consume, how you consume and shop, so that we can serve you better.
• To run, evaluate and improve our operations, including developing new products and services, determine the effectiveness of our sales, marketing and advertising efforts, analyze and improve products, offerings, promotions and online services and other technologies.
• To comply with your requests relating to the exercise of your rights (for example, when you ask us not to contact you for marketing purposes, we will keep this record on our opt-out lists so that we can comply with your request).
• To use or disclose your personal data (for example in connection with an investigation by a public authority), in cases where we have a legal right or duty to do so.
  To reserve the right to contact you regarding overdue debts either directly or through third party partners.
• If you have one of our insurance products.
• To protect against, detect and prevent fraud and other criminal acts, claims and other liabilities.
• For network and information security, in order to take steps to protect your information from loss, damage, theft or unauthorized access.

Compliance with legal obligations

We will use your personal data to comply with our legal obligations, such as:

• To locate you when you contact us.
• To verify the accuracy of the data we hold about you.
• To assist a public authority, e.g. the police.

For your own “benefit”

We will use your personal data for your own “benefit”, for example:

We may need to contact you if there is a potential risk to your safety from a product you have purchased or to recall it.

We use automated information for purposes such as:

• Personalizing the experience of our visitors to our online services.
• Providing material (including advertising) tailored to your interests and the way you browse our online services.
• Proper management of our business.

We use this information to help diagnose technical and service-related problems, administer the online (internet) services, track users of our services on the internet, target advertising and gather demographic information about you. We use automated information to determine usage patterns and how we can tailor our services to better meet your needs.

We may use the information we obtain about you in other ways, which we inform you of at the time your data is collected, so that we can tailor our services to better meet your needs.

Our service providers

We work with providers, suppliers, insurers and organizations that may process your personal data on our behalf, but only provided that they comply with data protection security rules. We only share information that allows them to provide their services to us or to facilitate the provision of their services to you. For example, some of our service providers display advertisements for our products and services as well as the products of our partners, our suppliers and third parties. Provided that you have given your consent and agree to be informed about our promotions, you may see online advertising that we have posted on the websites you visit or interactive services you use.

Other organizations and individuals

In certain cases, we may transfer your personal data to other organizations. For example:

• When you apply for credit or purchase an insurance product, we will forward your information to our partners. We are acting as a credit broker and insurance services are offered by a participating insurance company.
• If we are requested, for example, by a public or regulatory authority such as the police or the Ministry of Labor to do so, then we are obliged by codes of conduct to transfer your personal data.

International transfers of your personal data

From time to time we may transfer your personal data to suppliers or service providers located outside the European Economic Area (EEA). Your personal data will continue to be subject to appropriate safeguards provided by law. If we transfer information to our representatives or consultants outside the EEA, we will ensure that it is protected in the same way as it would be protected within the EEA.

How we use your information to make automated decisions

Sometimes we use systems to make automated decisions based on personal information we have (or are permitted to collect from others) about you or your business. This helps us to ensure that our decisions are quick, fair, efficient and correct, based on what we know.

Marketing

When you register with us, we use the information you provide for various purposes:

• To inform you about our latest products, services or offers.
• To contact you if we need to receive or provide you with additional information
• To check every now and then that you are satisfied with our products and services.

We may use your personal data to send you marketing messages if we have your consent or for a specific reason, e.g. to inform you of the recall of a product you have purchased. Hence, if you have consented to this, it can be done via post, e-mail, text messages, social media. We can also promote products or services using notifications and advertisements through apps. This applies when we have a business or commercial reason to use your information even though we will always provide you with the opportunity to object to the marketing. We may ask you to confirm or update your personal data if you purchase new products or services in the future. We will also ask you to do this if there are changes in legislation, regulation or the structure of our business. We collect statistics on e-mail opens and clicks using industrial technologies in order for you to help us monitor and improve our e-newsletters. You can unsubscribe from general mailings at any time by clicking on the unsubscribe link at the bottom of any of our e-mails.

Please note that if you opt out of receiving marketing messages from us, we may continue to contact you about transactions, your account, customer surveys and contests you may have expressed interest in.

Your Rights

In accordance with the law on the protection of natural persons with regard to the processing of personal data and on the free movement of data, you can exercise the following rights:

Access and Information

You have the right to obtain information about what data we have collected, for what purpose we have collected it and how long we will keep it.

Rectification

You have the right to ask us to rectify any inaccurate information about you or even to provide additional information about you.

Restriction and opposition to processing

You have the right to ask us to restrict or block the processing of your personal data if you question the accuracy of the information we hold about you, if you become aware that we are processing your data unlawfully or if you no longer wish to receive promotional messages about our products and services.

Portability

You have the right to ask us to transfer your personal data to another organization on your behalf.

Deletion

Finally, you have the right to ask us in writing to delete your personal information when it is no longer necessary in relation to the purpose for which it was collected, if you wish to withdraw your consent to its processing and if your data is processed unlawfully in violation of the Personal Data Protection Regulation.

If you wish to exercise these rights, please contact us:

• By sending an e-mail to: info@ephie.gr.

Please make sure that you include all the necessary documents in your request. Your request will be processed within 30 days from the date of receipt of the request; however, this may be extended up to two months when a request is complex or there are multiple requests.

Note: Please note that submission of a request is made free of charge. However, a “reasonable fee” may be applied when a request is manifestly unfounded or excessive, in particular if it is repetitive.

How long do we keep your personal data

We will keep your personal data for as long as you are a customer of Ephie. After you stop being a customer, we may retain your data for up to 10 years after your last purchase for which we used your personal data. However, we may keep your data for more than 10 years if we are unable to delete it for legal, tax or technical reasons. We may also retain it to inform you of any product recalls. In this case, we will ensure that your privacy is protected and it will be used only for these purposes. In addition, we do not retain personal data in an identifiable form any longer than necessary. Finally, we will retain your data for as long as we have active consent for the reasons it has been provided.

Links to other websites

Our websites may contain links to other websites run by other organizations, over which we have no control. If you are redirected through our website to a third website, we encourage you to read their privacy policy.

Social media

We use social media such as Facebook, Google, YouTube, Instragram and Twitter. In this way data can be collected. If you are connected to one of these, the network can match your visit to the website with your user account. If you are a user of a social network and do not want the data collected from your visit to our websites to be matched, you must first log out of your social network before accessing these.

Contact us

If you have a question or a complaint about this policy, the way we handle your personal data, please contact us:

• Via e-mail at: info@ephie.gr.

Complaints to the Personal Data Protection Authority

You have the right to submit a complaint or a claim either to the Hellenic Data Protection Authority regarding the processing of your personal data and your respective rights regarding its protection (address: 1-3 Kifissias Ave., P.C. 115 23, Athens, tel. (+30) 210 6475600, e-mail: contact@dpa.gr) or to the relevant competent authority in the United Kingdom, the ICO (Information Commissioner’s Office), based on the headquarters of the Group of Companies to which our Company belongs, at ico.org.uk/make-a-complaint/.

Changes to the policy

We may revise this policy by posting an updated version on our website or by contacting you via e-mail. This policy has been revised on 23/05/2018.