Respect for your privacy and the management, protection and security of your personal data are a priority for Naeniam (or “Company”, “we”, “us”). The Company has established this Data Protection Policy, which also includes the Cookies Policy as a single text and an integral part thereof (hereinafter the “Data Policy” or the “Policy”), in order to inform you who visit or purchase from www.naeniam.gr (hereinafter “e-shop”, “Online Store” or “Website” or “ Naeniam ”), or become our member or subscribe to our Newsletter recipients list, or in any other capacity use Naeniam ’s services or participate in its promotional or other actions, or use Naeniam ’s social media (Social Media), or otherwise, (hereinafter “you”, “your”),

1. about the type of data it collects or generates about you and,

2. the purpose of collecting and processing your data and,

3. the way in which this data is processed and,

4. their recipients and the purpose of processing on their behalf,

5. about your rights and choices regarding your personal data and,

6. how to contact us for any issue that may concern you in relation to your personal data.

1. Modifications:

This version was updated on 15/12/2020. This Policy replaces all previous disclosures that we may have provided in the past regarding our information practices. This Data Protection Policy is governed by both the relevant provisions of Greek and Community law regarding the protection of individuals from the processing of personal data. Any possible future change to the above regulatory framework will be the subject of this. Therefore, we reserve the right to change this statement and to implement any change to your data and our practices regarding the collection and processing thereof, in accordance with the provisions of the law, and/or to modify or replace all and/or part of this Policy at our absolute discretion.

If there are material changes to this Policy or our practices regarding your data change in the future, we will notify you by posting the changes on our Website. However, if you would like any clarification or information regarding the changes, or have any disagreement, reservation or question regarding them (changes), you can contact us at the details mentioned in the Section below. Please note that any information/clarification provided to you in accordance with the above, regarding any changes to this Policy, does not constitute a replacement, substitution or any amendment to this Policy.

Your continued navigation on our Website, or use of our Services and/or purchase through our Online Store, implies your automatic and unreserved acceptance of the amended terms of this policy. In case you do not agree with the amendments, you must not proceed with any action or use of the Website or purchase, much less provide personal data, and you are entitled to terminate the contracts between us and request deletion of your Account and your data. In any case, for any information or clarification, you can contact us, while you retain your rights regarding your personal data, as they are analyzed and described in the Section below.

This Data Protection Policy includes:

• Information about the Controller of your personal data as well as the contact details of the Data Protection Coordinator (DPC), for any matter related to your data.

• The type of data we collect about you and the collection methods.

• The purpose of collecting and processing your personal data and the legal basis for the processing.

• The security measures we take to protect your personal data.

• The retention period of your personal data.

• Your rights and how to access them, as well as your choices regarding the collection and processing of your data.

• The protection and storage of your data.

II. DATA PROCESSING OFFICER & PERSONAL DATA PROTECTION COORDINATOR

• 1. Who is the Data Controller?

The Data Controller of your personal data is the company with the name "STERGIOU MARIETA GEORGIOS|| NAENIAM BOUTIQUE " and the distinctive title " Naeniam Boutique ", based in Glyfada, Attica, at 40A Laodikis Street, in the Municipality of Glyfada, Postal Code 16674, in Greece (Tax Identification Number: 133619965, GLYFADA TAX OFFICE), with GEMI number 147936601000, tel. 211-4076779, email naeniamboutique @ gmail .

• 2. Contacting the Company's Privacy Coordinator

You can contact the Company's Data Protection Coordinator (DPC) at the email address dpo @ naeniam . gr and at the telephone number 211-4076779.

• 3. Questions and Comments

You can contact us at the contact details listed above and submit your comments, questions, observations or any complaints regarding this Policy and the general collection and processing of your personal data. You have the right to submit any complaint regarding your personal data protection issues that may arise from the processing of your personal data by the Company, to the Hellenic Data Protection Authority, which is the supervisory Authority in our country. Relevant details can be found at the following link www.dpa.gr . However, we consider it our obligation and duty to manage any concerns you may have regarding your personal data that we process, so we will be happy to hear from you.

III. DATA COLLECTION AND PROCESSING

Personal data or personal information means any information relating to an identified or identifiable natural person ("data subject"), an identifiable natural person being one who can be identified, directly or indirectly. Such data does not include data which is anonymous.

1. WHAT data do we collect about you and HOW do we collect it:

When you browse our Online Store or Naeniam Social Media, place an order, open an Account, subscribe to our Newsletter or become a member of Naeniam 's loyalty program, participate in Naeniam 's promotional activities such as competitions, interact on Social Media (e.g. comments, Likes, etc.) or otherwise, we collect various types of personal data about you, either directly from you, or from third parties, or which we collect or create ourselves (including automated means).

We collect the following personal data for you:

• Identity Data: (name, username, member code or other similar identifier) ​​that you provide to us when submitting your order or when registering as a Naeniam Member by opening an Account, participating in competitions, etc.

• Contact Data: (landline or mobile phone number, email address and other contact information) that you provide to us when submitting an order, opening an Account or in the context of receiving commercial communication from our Company, or in the context of your participation in various activities of our Company (e.g. competitions, etc.).

• Delivery Data: Postal Address (street, number, ZIP code, city, country)

• Financial data: (bank account, transaction value, credit, refunds, debit or credit card details, billing address, etc.) that you provide to us when paying by electronic means, in the event of a refund, that we collect from your purchases, etc. The registration of the card details, their confirmation, the blocking of the amount and the final charge, are made in a secure environment (SSL) of Eurobank. Our website does not know, handle or store your card details under any circumstances.

• Transaction/Purchase Data: (type of products purchased, transaction value, place of delivery, time of purchase, purchase history, complaints, payment method, information required in cases of changes or account re-crediting such as bank account, beneficiary name, IBAN, banking institution, etc.) that we collect regarding your purchase and/or from your Account.

• Consumer Behavior Data: Consumer preferences during your browsing of the Online Store, i.e. the items you view, your shopping cart, Wishlist, your interaction on Social Media (e.g. which products you Like), gift redemption, purchase frequency, method, time of purchase, type of purchase, etc., based on the products purchased, comments or any responses you may have to surveys we conduct.

• Technical data such as the channel – source of origin, internet protocol (IP) address, time zone and location, login details, browser type and version, operating system and platform and other technology on the devices you use to access our Website, etc. For more details about the information we collect through cookies, please refer to our policy below.

• Login Data to your Account or loyalty program membership, which is the username (which corresponds to your email or mobile phone number) and password.

• Profile Data As part of your participation in the Naeniam loyalty program, we collect data regarding your interests and consumer preferences, the collection and redemption of your reward points, your participation in competitions or events and your general interaction as a member with Naeniam .

• Demographic Data: age, gender, place of residence, which are collected directly from the subject on a case-by-case basis or inferred from the subjects' transactions in our Online Store, etc.

• Data via Cookies: Browser, IP address, products that you have placed in the cart and have not completed the purchase, the country of origin of your order, the products you are looking at in the Online Store, the Wishlist with your favorites, your origin from other websites.

• Marketing Data: which includes your preferences regarding receiving promotional materials from us and third parties and your preferences for communicating with us, provided we have your consent, your opinion regarding products you purchased from us.

We do not knowingly collect any information from any person under the age of 15. Our services are intended exclusively for people who are at least 15 years of age or older. If you are under 1 year of age, do not use or provide any information to us, do not register as a Member or on our newsletter recipient list, do not make any purchases, and do not provide any information about yourself to us, including your name, address, or contact information (telephone, email, etc.). If we determine that we have collected or received personal data from a person under the age of 15, we will delete it immediately unless consent has been given by a parent or guardian. If you believe that we may have information from or about a person under the age of 15, please contact us.

Learn more…

Your obligation to inform us of changes to your personal data.

It is important that the personal data we hold about you is up-to-date and accurate. Please inform us as soon as possible of any changes to your personal data for the duration of your business relationship with us.

We collect the following personal data DIRECTLY FROM YOU:

• When submitting your order , whether online or by phone, you must provide us with your name, shipping address, email, contact number (mobile) and payment details (credit/debit card, etc.). The registration of card details, their confirmation, the blocking of the amount and the final charge are made in a secure environment (SSL) of Eurobank. The Naeniam website does not know, handle or store your card details under any circumstances.

• When registering as a Member at Naeniam , either through our website or through our store, through the relevant form you fill out, you must provide us with your mobile phone number, your full name, your date of birth, as well as a password. Optionally and if you wish, you can also provide us with your email, the date of your name day and your residential address.

• When you subscribe to the Company's newsletter list, you provide us with your email address.

• When registering for competitions that our Company conducts from time to time, you provide us with your personal information, which is specified on a case-by-case basis.

When communicating with us on our Company's social media (Facebook, Instagram) and with our customer service department (except in cases of telephone orders), you provide us with your personal information such as identity, contact, or transaction data, which we use on a case-by-case basis exclusively to service your request.

We collect the following data and information about you by AUTOMATED MEANS.

• By using cookies and other similar technologies, we collect and/or create data about your preferences, such as the products you visit, the duration and frequency you observe certain products, the types of newsletters you open or not, their content and your interaction with us after each newsletter is sent, your Wishlist, the types of products you purchase, the search terms you have entered or the links you clicked on within the Online Store, the products you place in the cart and do not complete their purchase, the country of origin, language, etc.

• From your Account, we create the history of your orders and purchases, and from these we deduce your preferences, the frequency of your purchases by type, the value of the products you purchase or that interest you, the season during which you purchase, your area of ​​residence, etc.

• Data about the devices through which you visit our Website, such as for example your internet protocol (IP) address, login details, browser type and version, operating system and platform and other technology on the devices used to access our Website, etc.

• Data about the page you logged in from and the page you went to when you left,

• We collect the following data and information about you from third parties :

• We may receive your personal information such as your name and email address from a third-party friend of yours, who has registered you in order to receive a gift certificate from us or to send you a gift they have selected for you.

• If you register for our service through a social networking platform, we may collect the above personal data directly from the information you have provided to the platform (provided that the social networking platform has the relevant right to share your personal data with us).

• Your personal data may be shared with us by third-party independent organizations when there is a legal basis for processing and they have the relevant right to do so. In these cases, you should be informed about the processing of your personal data from the relevant Data Protection Statement of these third-party organizations. These organizations may include social media such as Facebook, Instagram.

2. HOW we use your personal data:

All of your above personal data, which as mentioned, you either provide to us on a mandatory or voluntary basis, or we collect from third parties or are generated by automated means, we use for the following lawful purposes. Please note that in the event that Community or national law restricts or prohibits certain actions of the Company for which we use your data, we will cease using the information concerning you for these purposes.

In particular, your personal data is used by us for the following purposes :

• To receive your orders, process them, and ship the products to you.

• Communicating with you on issues related to the sale of our products to you.

• To manage, process and process your payments including the security of our financial transaction.

• To serve you as a Member at Naeniam by opening your Account with us.

• To create, store and maintain a database with our clientele and analyze it.

• To send you commercial communication via Newsletter, SMS, or other multimedia (VIBER) regarding our Company's news, products, offers and promotional activities.

• To analyze your behavior and understand your preferences.

• To understand and analyze the results of our advertising and promotional activities.

• To process your requests such as withdrawal, product replacement, etc.,

• To satisfy your rights regarding your personal data.

• For the security of transactions.

• For business analysis and improvements, such as for the marketing and optimization of our products, for the optimization of your experience and service from us within our Online Store, as well as for the customization of your experiences in our Online Store.

• For market research, statistical analyses, to develop marketing strategies and manage marketing campaigns and to inform you or our partners about possible opportunities to participate in Naeniam 's marketing or product promotion initiatives.

• For other purposes that we will notify you of, or that will be identified where applicable, at the point where the information about you is initially collected

3. WITH WHAT RIGHT DO WE USE YOUR PERSONAL DATA:

The Legal Basis for using information about you is one of the following (we provide more detailed explanations in the “ Learn More ” section):

• The performance of a contract to which you are a party.

For communication either at a pre-contractual stage or regarding issues concerning your transactional relationship with the Company, such as when purchasing one of our products in order to inform you of any unavailability of the product, for notification of order execution, for communication regarding the shipment of the product, to inform you of changes to our terms of use or to the Privacy Statement and other policies adopted by the Company.

In order to fulfill our obligations arising from the Sales Contract, such as our payment, the issuance of invoices, the proper delivery of the products to you, etc., the Company may process your personal data, such as your address and contact details.

To participate in a competition or raffle as part of our promotional activities, provided that you accept the terms of participation.

In particular, the Company may process your personal data such as your email and password for the purpose of securing your transactions (e.g. identifying you when logging into your Account), your email or your telephone number for contacting you in the event of a problem with your Account, your telephone number for contacting you in the event of a problem/stuck during the execution of your order.

• the legitimate business interest overridden by your interests in protecting the information.

To operate and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and record keeping).

To prevent and address cases of fraud and other illegal activities for the purpose of protecting the public and the safety of personnel, including the video surveillance system.

Provide you with access to your personalized account, where you can track your transactions (your previous and pending purchases with us), products that interest you, wish lists that you have created, complete your purchases faster, etc. The information and content of the user profile are visible to you at all times.

To offer you services that are useful, user-friendly and enjoyable, including personalized communication with you in the manner you desire and have declared, and products that interest you and are to your benefit, depending on your preferences.

To better understand our customer base so that we can improve our services, products and promotions and to manage and improve services relating to registered users on Naeniam .

To better understand your purchasing habits so that we can develop and improve our products and services and tailor the content of the website to your needs and preferences.

To measure the effectiveness of the Company's presentation and promotion on third-party websites.

To analyze the effectiveness of our sales promotions and help promote more relevant messages, information and offers to you and other customers.

For the purposes of market research, evaluation and analysis of your opinion on our products and our commercial policy, the reputation, recognition of our trademarks and other distinctive features.

To collect and recover monies owed to us.

To use data analysis tools to improve our website, products/services, and customer relationships.

When we rely on the Company's legitimate interests as a lawful basis for processing the collection and retention of your personal data (including in cases of automated decision-making and profiling), we must assess whether your interests, fundamental rights or freedoms that require the protection of your personal data prevail over such processing.

We have taken these issues into account and where we consider that there is a risk that any of your interests, fundamental rights or freedoms may be affected, we will not process your personal data, unless we rely on another lawful basis for processing.

• compliance with a legal obligation to which we are bound,

Within the framework of its activities, the Company is obliged to process your personal data in order to comply with its obligations arising from the law, such as for example maintaining financial data of transactions for tax reasons, using your email to send you confirmation of the execution of your order, etc.

• if none of the above applies, your consent (which we will ask for before processing the information).

Your free and informed consent constitutes the legal basis for the use of your email and/or mobile phone to send you direct commercial communication in the form of a Newsletter to your email, or updates on Naeniam 's news and offers via SMS/VIBER messages to your mobile phone, when you are not, for example, our customer or wherever else it applies.

Your email or mobile phone for the purpose of commercial communication via informative emails, SMS, VIBER, etc. within the framework of our customer relationship if you purchase from us, for the development of our business activity, the optimization of commercial and technical systems, statistical analysis for product improvement, optimal customer service, etc.

To inform you about events, special offers, promotions and other relevant matters concerning the Company and our products and services, according to the means of communication you have declared.

To inform you about offers or promotions from third parties collaborating with us, provided that you have given us your consent, according to the means of communication you have stated.

To advertise our company and products on social media to you and other people who may also be interested in what we offer.

Additionally, based on your consent, we process the following:

Learn more…

Processing Purposes:

Existing Customers until Tuesday, December 15, 2020

We process your data for the purpose of:

• Give you access to your account information.

• View the history of your orders and purchases.

• To use the services/functions of your Account Wishlist, favorites, address management, etc.

Member Registration – Account Creation – Account Management at Naeniam (after 15.12.2020):

We process your data for:

• To identify you each time you request access to your Account.

• To give you access to the functions and services of the Member Account.

• View the history of your orders and purchases.

• Make use of the services/functions of your Account: Wishlist, favorites, address management, etc.

• Managing subscription to the Naeniam Newsletter recipient list .

• Sending general newsletters and newsletters based on your behavior and preferences, as recorded through the Cookies mechanism as well as your transaction history.

• Sending direct commercial communication via email, SMS, Viber or other multimedia, push notifications, etc.

• Conducting promotional activities, e.g. organizing competitions.

• Investigating the degree of customer satisfaction with the products and services provided by Naeniam .

Receiving, Managing and Executing your order via Naeniam 's e-shop or by phone:

• customer order submission

• order placement

• product pricing

• payment, fee and charge management

• delivery of products to the customer

• withdrawal or return of product for another reason

• processing and general management of orders

• Contacting the customer for updates, notifications regarding the order

• Activation of mechanisms to prevent fraud against you or against us.

• To ensure your use of gift certificates, etc.

Customer service and management before or after the sale, which includes:

• Communication from the customer through the Company's communication means (conventional means, email or call center, or through multimedia communication e.g. viber or through another means e.g. Social Media)

• Contact by the Company upon request of the customer using the information provided by the customer.

• Customer service in general for issues related to the company, the e-shop, the products, the services, their order, their Account, or the competitions it implements, any guarantees it provides, the company's social media.

• Complaints or clarifications

• Exercise of rights

• General management and optimization of the user experience and service in the e-shop

Advertising & Marketing

• Management of subscription to the Naeniam Newsletter recipient list .

• Sending general newsletters and newsletters based on behavior and preferences, as recorded through the Cookies mechanism.

• Sending direct commercial communication via email, sms, viber or other multimedia, push notifications, etc.

• Conducting promotional activities, e.g. organizing competitions

• Investigation of the degree of customer satisfaction with the products and services provided by Naeniam .

Business analyses and improvements for:

• Uninterrupted operation of the e-shop

• technical excellence and security of transactions

• optimization of technical systems

• addressing technical issues

• report writing and data maintenance

Statistical analysis to evaluate and improve the e-shop's services and processes, which includes:

• Evaluation and improvement of business processes

• Better e-shop responsiveness and management

• Research and/or analysis to better understand the needs of e-shop customers

• Research and evaluation to improve existing products and/or services and develop new ones

• Evaluation for the creation of new programs, offers, etc.

• Adoption of new commercial and business models, programs and partnerships.

• Promotion of the Company, our products and our services.

• Distribution and marketing of our products in other countries.

• Marketing and sales of new products and services.

• Advertising and promotion of our Company.

• Improving your experiences

• Delivery of relevant content

• Quality surveys

• Statistical analyses

4. Who do we SHARE your personal data with and WHY:

In the context of operating the e-shop, fulfilling our contractual obligations and providing you with better service, our Company reserves the right to collaborate with third-party service providers, who provide us with support and gain access only to your data that is absolutely necessary for the service they offer us (e.g. your registration in the e-shop and the management of your account, the execution of the purchase and sale contract between us and the general provision of our services to you, the operational and computerized organization of our website, the optimization of our products and services, etc.). These third-party service providers are contractually bound not to use your information in any other way than to help us provide you with the products and services we agree upon.

In particular, our Company collaborates with:

(a) With a third party company which, as a data processor on behalf of and under the instruction of our Company, hosts and manages our e-shop.

(b) With a third party company which, as a processor on behalf of and on behalf of our Company, has developed, maintains and manages the Naeniam platform.

(c) With a third party Call Center company, which acts on behalf of and on behalf of the Company's customer service services, as the processor, having undertaken the receipt of your telephone orders and in addition the management of our communication for reasons related to your participation in the e-shop.

(d) With third-party courier companies which, as processors on behalf of our Company, manage and process the shipments of your orders and collect the money on our behalf in the event that you pay by cash on delivery. They also carry out the collection and delivery to you of products that you return due to withdrawal or refund.

(e) With third party email marketing companies who act in our name and on our behalf to send you newsletters .

(f) With advertising and marketing companies

(g) With data analysis companies

(h) Research companies

(i) Financial Institutions for the collection of the purchase price and Fraud Detection and Prevention Organizations,

(j) Information systems supply and support companies.

We reserve the right to share your personal data with a third party to whom we reserve the right to choose to transfer all or part of our business. Furthermore, in the event of a merger or acquisition, or other change in our business, the new owners, shareholders, managers, etc. have the right to use your personal data in the same manner as set out in this privacy statement.

Your data may be disclosed to the competent judicial, police and other administrative authorities upon their lawful request and in accordance with the applicable legal provisions. Furthermore, in the event of a legal order, official order or official preliminary examination, the Company has the right without any further obligation to make the relevant data available to the relevant service.

5. TRANSFER of your personal data to THIRD COUNTRIES

The Company generally stores your personal data within the European Economic Area. In the event that data is to be transferred to third countries outside the European Economic Area for which there is no adequacy decision of the European Commission or to International Organizations, all appropriate guarantees provided for in the applicable legislation for the protection of personal data regarding transfers to third countries will be taken and the relevant information will be posted on the company's website, at www . naeniam . gr .

What happens if you do not provide us with the personal data we request or ask us to stop processing your personal data?

In order for you to register or continue to enjoy the benefits of Naeniam, we need to keep at a minimum your mobile phone number, your full name and your date of birth. However, if you voluntarily provide us with more personal data, we will be able to provide you with improved services and serve you better. As mentioned above for your participation in the loyalty program, we collect information about your transactions with us.

If you ask us to stop processing your personal data then we will not be able to provide you with the benefits of Naeniam .

Automated individual decision-making, including profiling

We use software to track your consumer behavior if you have registered as a member of the Naeniam loyalty program, when you browse our online store or for purchases you make in our network stores in this capacity. This technology helps us create a profile for you based on your preferences in our products. Our customer profile helps us send you targeted offers and gifts according to your previous transactions. If you do not agree to the profiling of you, you can in any case exercise your rights and oppose automated processing or restrict it (For more information, see below).

The legal basis for processing for automated individual decision-making, including profiling, is our legitimate interests, taking into account whether your fundamental rights and freedoms are infringed by such processing. For more information on the legal bases for processing, see above.

6. PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA

SECURITY of your personal data

• appropriate technical and organizational measures to protect the personal information we maintain from unauthorized disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can help secure the information you provide. We also require our service providers to comply with strict requirements for the protection and security of personal data.

Learn more…

In particular, the data you submit to the Company is managed exclusively by specially authorized personnel of the Company who are under our control and only at our request. To carry out the processing, the Company selects persons or third-party partners with corresponding professional qualifications who provide sufficient guarantees in terms of technical knowledge and personal integrity for the maintenance of confidentiality. The Company, through the corresponding contractual commitments and its partners, takes all necessary security measures to protect and ensure the privacy, confidentiality and integrity of personal data. In any case, the security of these in the platform environment is subject to reasons beyond its sphere of influence, as well as reasons due to technical or other weakness of the network that is not controlled by the Company or reasons of force majeure or fortuitous events.

You must not disclose the details/codes you have provided for the opening of your Account, which are personal and non-transferable. Our Company carries out regular quality and security checks on the systems and algorithms it uses, in order to correct factors that lead to inaccuracies in the data.

1. 1. 3. 4. RETENTION time of your personal data

We will retain your personal data for as long as you continue to interact with us (e.g. you maintain an Account on Naeniam , you are registered to receive commercial communication from us, you make a purchase from our online store, you participate in a competition, etc.). At the same time, we retain your personal data for purposes of legitimate interest, which consists of our legal coverage in the event of any dispute regarding the sales contract, the maintenance of your Account, our commercial policy or other transaction between us, for the period during which liability could arise from the processing, in accordance with the applicable legislation. Our Company may retain your Financial Data within the framework of its legal obligation to comply with its tax obligations. We retain your other data until you ask us to delete it, or what we retain and process within the framework of your consent, until you withdraw it, or until you object to our processing of it, which we base on our legitimate interest.

To determine the retention period of your personal data, we take into account the nature of your data, its quantity, the purpose of its processing, its security, etc. You have the right to request that we delete your data. To exercise your right, please visit the relevant Section in this Policy.

We reserve the right in some cases to anonymize your data for research or statistical purposes, where it is no longer associated with an identifiable person, therefore we reserve the right to use this information indefinitely. In any case, your data is stored securely.

Learn more…

Purpose of processing	Retention Time
Member Registration / Managing your Account	Until your Member Account is deleted, or up to 3 years from your last login. If you attempt to create an Account, but do not complete the process, any data you may have submitted will not be retained.
Shopping – Order receipt, order fulfillment	If you purchase products, we will retain your transaction details for as long as necessary to complete the sale and to comply with any legal obligations (for example, for tax and accounting purposes). We will process your data for as long as necessary to manage the purchase of the products you have acquired, including any returns, cancellations, complaints or claims related to the purchase of that product or service.
Send Newsletter/ SMS/ VIBER	If you have given us your consent, until its withdrawal or up to 2 years from the last time you opened a Newsletter/SMS/VIBER respectively, whichever occurs first. In case the sending of our direct marketing is based on legitimate interest, the processing of your data for this purpose continues until you object to the sending of such messages or up to 2 years from the last time you opened a Newsletter/SMS/VIBER respectively, whichever occurs first.
Customer service	If you contact customer service, a record will be created (including details of your query and our response) and we will retain it for as long as your request remains open and in any case for up to 12 months. Temporary files may not be useful until more permanent records are in place and will only be retained on a temporary basis.
Usability and quality analysis	We will process your data for the period during which we take an action or a specific quality survey or until we anonymize your browsing data.
	Certain elements of your Account that we process for statistical or other analysis and research purposes, we process until and at which time we delete them. If we have no communication with you for a long period of time (then we will stop sending you promotional communications and delete the history of your relevant responses. This will happen, for example, if you never click on our Newsletters, if you never log in to a digital touchpoint or if you never contact us or make a purchase, or contact customer service during that period. The reason is that, in these cases, we assume that you prefer not to receive communications.

IV . YOUR RIGHTS AND CHOICES

With regard to your personal data that we have at our disposal and that we process, you have the following rights:

• ask us to access them to confirm that we are processing them in accordance with the law and/or your instructions and preferences,

• to ask us to correct incomplete, outdated or inaccurate data we hold about you. Of course, we also reserve the right to ask you to update your information at regular intervals.

• ask us to delete them, provided of course the law does not oblige us to the contrary.

• ask us to restrict their use, under certain circumstances,

• to object to their use, under certain circumstances,

• withdraw your consent to their use,

• have the right to data portability, under certain conditions,

• file a complaint with the country's supervisory authority.

• not to be subject to a decision based solely on automated processing, including profiling, under certain circumstances.

We offer you easy ways to exercise these rights, such as "unsubscribe" links, or via our customer service hotline, at 211-4076779 and e-mail naeniamboutique @ gmail .com , or by sending a letter to our company headquarters. Telephone calls are subject to city charges and the service hours we have stated in the Terms of Use Section.

Some mobile applications we offer may also send you unsolicited messages about, for example, new products or services. You can turn off these messages through the settings on your phone or in the application.

You have the ability, through your Account, to configure your personal choices regarding our processing of your data for our commercial communication, that is, to declare in which media you want us to communicate our news and promotional activities, as well as your preferences for Cookies.

We may, for the security of your information, request certain information about you for the purpose of identifying you. Your right is exercised free of charge, however, when you exercise your right abusively, we may request a fee from you, in accordance with the conditions set by law. In any case, we respond to your requests within one month from the date of receipt of the request, except in exceptional cases where our response time to a request may be longer.

Learn more:

Right	Illustration
Access	You can ask us to: confirm whether we are processing your personal data. to give you access to any data that you do not have at your disposal provide you with other information about your personal data, such as what data we have, why we use it, to whom we disclose it, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can file a complaint, where we got your data to the extent that information has not already been provided in this Policy.
Correction	You can ask us to correct inaccurate personal data. We may seek to verify the accuracy of data before correcting it.
Deletion	You can ask us to delete your personal data: at any time when they are no longer needed for the purposes for which they were collected or when you delete yourself from the eshop (which will be deleted immediately anyway) or have been illegally processed We are not required to comply with your request to delete your personal data if the processing of your personal data is necessary: to comply with a legal obligation for the fulfillment of another legitimate purpose or other legal basis or for the establishment, exercise or defense of legal claims.
Restriction	You can ask us to restrict (i.e. retain but not use) your personal data when: their accuracy is disputed (see Correction), so that we can verify their accuracy or the processing is unlawful, but you do not want it to be deleted or is no longer necessary for the purposes for which it was collected, but we still need it for the establishment, exercise or defence of legal claims or there is another legitimate purpose for processing or another legal basis
Portability	Where processing is based on consent and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format or you may request that they be transmitted directly to another controller. However, this right, under the law, only concerns data that have been provided by the data subject and not data that are inferred by the controller on the basis of data provided by the data subject.
Opposition	You can object at any time to any processing of your personal data, which has as a legitimizing basis the legitimate interest of the Company or the fulfillment of a task carried out in the public interest.
Withdrawal of consent (opt-out)	You have the right to withdraw your consent, where the processing is based on consent. The withdrawal is for the future. However, this right does not affect the lawfulness of the processing of your personal data based on your consent until its withdrawal.
Rights in relation to automated individual decision-making, including profiling	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 which significantly affects you in a similar way. This right of yours does not apply if the decision in question is necessary for entering into or performing a contract between us or is based on your explicit consent.
Supervisory authority	You have the right to lodge a complaint with the local supervisory authority regarding the processing of your personal data. In Greece, the supervisory authority for data protection is the Personal Data Protection Authority – ΑΠΔΠΧ ( www.dpa.gr ). Postal Address: 1-3 Kifissias Avenue, P.C. 115 23, Athens Call Center: +30 210 6475600 Fax: +30 210 6475628 Email: contact@dpa.gr
Identity	We take the confidentiality of all files containing personal data seriously and reserve the right to ask you for proof of your identity if you make a request regarding such files.
Cost	We will not charge you any costs for exercising your rights in relation to your personal data, unless, as required by law, your request for access to information is unfounded or excessive, in which case we may charge a reasonable fee under the circumstances. We will inform you of any charges before we complete your request.
Timetables	We aim to respond to any valid requests no later than one (1) month from receipt, unless it is particularly complex or you have submitted several requests, in which case we aim to respond within three months. We will inform you if it is going to take longer than one (1) month for the reasons listed above. We may ask you if you can tell us exactly what you want to receive or what exactly your concern is. This will help us to act on your request more quickly. In any case, you must provide specific and true information and/or facts in order for us to be able to respond and/or satisfy your request accurately, otherwise we reserve the right to make any errors that are beyond our control. Our Company may also reject requests that are unfounded or excessive or abusive or in bad faith or generally illegal, within the framework of the provisions of the law.

• 5. Changes to the Data Protection Policy

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we process your personal data, we will update this Policy to include new services or products and the processing of your data related to them, as well as changes to the existing processing of your personal data. In addition, we may amend this Policy in response to changes in the legal and regulatory framework and in order to comply with relevant requirements.

You undertake to visit our website for any changes to this statement that may apply to you. In any case, if you continue to use our Website and its services and the services of our Online Store after amendments have been made in accordance with the above, you will be deemed to have accepted these amendments. If you do not agree to the terms of this Policy, as it may be amended, either in whole or in part, you must cease using our services provided to you.

Any changes to this Policy will be posted here immediately.