Security Manager: Iphigenia Kotsianou
11 Vasileos Irakliou str., 54625 Thessaloniki, Greece
Tel. +30 6948 48 58 88, Email: firstname.lastname@example.org
5. Information We Collect
- Information from your use of the Service: We may receive information about how and when you use our Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. An IP address is a number that is automatically assigned to your computer every time you browse the Internet. When users request a page from our site, our servers log the user’s current IP address. We use IP addresses to help diagnose problems. This type of information helps us to improve our Services for both you and for all of our users. We do not link IP addresses to anything personally identifiable. Thus, each user session is anonymous.
- Web beacons: We use web beacons on our Website and in our emails. When we send emails to Members, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of Members. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how your email campaign performed and what actions your Subscribers took. Reports are also available to us when we send email to you, so we may collect and review that information.
- Information from other sources: From time to time we may obtain information about you or your Subscribers from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media website, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services. For example, we use this information to develop Social Profiles, a tool that helps you learn about your Subscribers and allows you to send them more relevant content.
6. Use and Disclosure of Personal Information
We may use and disclose Personal Information only for the following purposes:
- To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
- To bill and collect money owed to us by our Members. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
- To communicate with our Members about their account and provide customer support.
- To protect the rights and safety of our Members and third parties, as well as our own.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support, and improve the Services we offer. This includes our use of the data that our Members provide us in order to enable our Members to use the Services to communicate with their Subscribers. This also includes, for example, aggregating information from your use of the Services or visit our Website and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Subscribers with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
7. Public Information and Third Party Website
- Blog. We have blog(s) on our Website. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.
- Social media platforms and widgets. Our Website includes social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, Pinterest and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
8. Third Parties
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
- Service Providers. Sometimes, we share your information with our third-party Service Providers, who help us provide and support our Services. Just like with the other third parties we work with, these third-party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include payment processors, Booking Platforms (like Booking.Com, TripAdvisor, Airbnb, etc.) and content delivery services.
9. Contests and Sweepstakes
We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Website or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.
10. Content of Email Campaigns
When you send an email marketing campaign, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for confidential information. Please do not use SMARTSTUDIO GROUP Website to send confidential information.
When SMARTSTUDIO GROUP asks you for personal data when making a reservation or purchasing a gift certificate, including your name, address and credit card data, it is transferred over a Secured Sockets Layer (SSL) line provided you are using an SSL enabled browser such as Safari, Google Chrome, Microsoft Internet Explorer, etc. This ensures that your information is encrypted as it travels over the Internet. This secure mode is enabled before any such information is transmitted from your computer. You will know you are in secure mode when the padlock icon in the lower right-hand corner of the computer screen appears in the locked position. In addition, when accessing a secure server, the first characters of the site address will change from “http” to “https”. If a security breach causes an unauthorized intrusion into our system that materially affects you, then SMARTSTUDIO GROUP will notify you as soon as possible and later report the action we took in response.
12. Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. After information reaches us it is stored on a secure server that resides behind a firewall that is designed to block access from outside the Company. Our credit card processing vendor uses security measures to protect your information both during the transaction and after it is complete. Our vendor is certified as compliant with card association security initiatives, including the Visa Cardholder Information Security and Compliance (CISP), MasterCard® (SDP), and Discovery Information Security and Compliance (DISC). We also perform annual SOC II audits. If you have any questions about the security of your Personal Information, you may contact us. SMARTSTUDIO GROUP accounts may require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Please, have in mind that we cannot resend forgotten passwords either. We will only reset them.
Our offices are located in Greece, so your information may be transferred to, stored, or processed in Greece. While the data protection, privacy, and other laws of Greek Democracy might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering a data processing addendum. By using our Website, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in Greece and those third parties with whom we share it as described in this policy.
14. Accuracy and Retention of Data
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
We will give an individual, either you or a Subscriber, access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete the information we hold about them by contacting us here. Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a Subscriber, from our servers at your or their request. There is no charge for an individual to access or update their Personal Information.
16. Do Not Track Disclosure
“Do Not Track” is a standard that is currently under development. Because it is not yet finalized, SMARTSTUDIO GROUP adheres to the standards in this policy and does not monitor or follow any Do Not Track browser requests. That said, some of our features may have the ability to monitor or follow Do Not Track browser requests.
Your privacy concerns are important to us. We hope this privacy statement has been helpful to you. If you have any questions about this privacy statement or privacy concerns please contact us.
Last update: October 26, 2019