Privacy

PREAMBLE

This Privacy Policy shall be in effect from the 25th of May of the year 2018 and shall incorporate each and all of the terms and conditions stipulated and/or dictated within the parameters of the General Data Protection Regulation (EC Regulation No. 679/16).

This Privacy Policy shall be updated and/or amended from time to time to effect and be in line with all and any amendments of the relevant legislation and/or EC regulations.

D & TH TOUMBA LTD is a long standing and duly registered and incorporated Company under the Laws and Regulations of the Republic of Cyprus, which operates according to strict business ethics and fully abides to the provisions of the Laws and Regulations of the Republic of Cyprus and the European Community Regulations and Directives, as these are incorporated by the Parliament of the Republic of Cyprus and amended from time to time.

Our officers are obliged to collect and process under strict confidence and in full compliance with the GDPR, all and any of the following personal information of our customers.

Please read thoroughly and fully this PRIVACY POLICY.

By reading this PRIVACY POLICY and by signing the forms available, you hereby agree and affirm that you have provided your full and express consent to us and/or our officers authorised by the Group to collect, reserve and process your personal data.

By reading this PRIVACY POLICY and by signing any form available, you hereby agree, affirm and acknowledge your rights and obligations regarding the provision and processing of your personal data and your exclusive right to withdraw the aforementioned consent at any time provided that you inform our officers in writing.

Introduction
Which Personal Data do we collect
Why do we process any of our customers’ Personal Data – Personal information?
For which purposes do we process your personal data?
Communication and marketing
Customer’s Personal Data
Right to data portability
Right to lodge a complaint
Cookies and similar technologies
Security of your personal information
Who will you share my personal data with?
If you communicate with us through social media
How long do we retain your data
Changes to this Privacy Policy
Customer Choices & Obligations

Introduction

This privacy policy provides information regarding the processing of your personal data when using services and/or purchasing products from our stores which are located in most cities of the Republic of Cyprus or on behalf of a company or companies within our group of companies (“The Group” or “we”) whether as:

a retail customer;
a member of any the Group’s loyalty programme (Members Loyalty Card or “Members Loyalty Programme”);
a visitor to our website (“Website”);

As well as this privacy policy, supplementary notices and/or amendments to this policy may be introduced from time to time and may contain further information in order to reflect local practices and applicable legal requirements and/or contain further contact details regarding the processing of personal data by our officers.

This privacy policy, explains what personal data is collected and processed, for which purposes do we process such data, how long we hold the personal data for, how to access and update your personal data, the options you have regarding your personal data and where to go for further information.

Special Notice – if you are under 18 years old.

(a) The statutory age of adulthood in the Republic of Cyprus is 18th year of age of each individual.
(b) Any person younger than 18 years of age is considered by law to be a minor.
(c) We do not intentionally collect and/or process any personal data of those under 18 years of age.
(d) If any of the viewers of this Website are under 18 years age, please do not send us your any of your personal data (for example, your name, address and email address).
(e) No one under the age of 18 years shall be entitled to be registered as a member of our bonus and/or loyalty program.

1. Which Personal Data do we collect?

(a) Should any of our customers be registered as a member, by signing any of the forms available, he/she will be request to provide us with certain personal data and/or personal information.

(b) Our officers may also collect personal data about of customers visiting this Website.

1.1 Personal Data and/or Information provided to us by any customer registering with us.

(a) When each customer applies to be registered, we will ask for his/her full name, date of birth, and email address, physical and/or correspondence address and mobile phone number.

(b) We may also request further personal data necessary for the performance of such services and/or the completion of questionnaires and surveys regarding our services and your satisfaction with our products.

(c) We may also collect information about each customer’s participation in any of our programs, provided that the particular customer has registered. This may include any data regarding (i) the type and description of the award you have chosen, (ii) the method by which we can contact you regarding offers, marketing and awards, and (iii) delivery method used to deliver your award (if any).

1.2 Personal Data and/or Information that we obtain through the customers use of our services and/or through each customer’s purchases.

(a) We may collect information about how and where each customer purchases any of our products.

(b) Such information may include electronic device information, IP addresses, log-in information, browser type and preferences (should any of the purchases be online or through any of our websites and/or affiliates and/or associate website and online order points), location information, online identifiers to enable ‘cookies’ and similar technologies.

(c) Each customer’s purchase history may be collected and reserved and may include data regarding (i) specific products you buy, (ii) the total amount of your purchases per transaction, (iii) the time and place of the purchases you make and (iv) the payment method you use.

2. Why do we process any of our customers’ Personal Data – Personal information?

The personal data covered by this Privacy Policy is only processed:

with your express and explicit consent; or
where it is necessary to conclude a transaction with you (such as payment information); or
where it is necessary for any of our officers to comply with a legal obligation.

Where the processing of any of the customers’ personal data is based on his/her express and explicit consent provided by completing and signing any form available, you have the right to withdraw your consent at any time by notifying us in writing by any of the following methods:

(a) By completing and signing any of our “Withdrawal Consent” forms.
(b) By emailing us at office@toumbas.com and/or sales@toumbas.com.

Your withdrawal shall not affect the validity of any of the processing prior to the withdrawal of your express consent.

Where you choose not to provide us with information set out above for the purposes of participating in any programme, the only consequence is that it will affect your ability to fully interact with and/or to participate in any programme.

3. For which purposes do we process your personal data?

Any customer registering with us by completing and signing our forms, is providing us with his/her express and explicit consent to process all and any of his/her personal data and/or personal information given.

We process your personal data for the following purposes:

maintaining and promoting contact and relationship with you;
account management including account verification (that is, ensuring that only you or someone you have authorized can access your account and information);
customer service and development;
performance of and analysis of market surveys and marketing strategies;
promotions and contests offered to our customers, including offering you digital rewards to recognise you as a valued customer; (or for a secondary purpose where it is closely related, for example such as storing or deleting it).

4. Communication and marketing.

(a) If you have consented to receive any communications from us either by email or by SMS by ticking any of the available boxes provided on our forms, you may receive offers that are tailored towards your preferences based on your product purchases history, your participation in our promotions, surveys and your use of our websites. Please Note that any such communication from our part shall effectively stop as soon as we have received your withdrawal of consent as it is mentioned above.

(b) We may send you service updates and notifications without your advance consent only where you are an existing registered user.

(c) You may receive pertinent offers and communications by different channels and you may update your communication preferences at any time by amending the member form that you have completed and signed at any time or by contacting us by email at the email addresses indicated above.

(d) We may also process the information that you have provided to us, as well as the information that we obtain through your purchases of our products in order to offer to you digital awards and rewards and recognise you as our valued customer.

5. Customer’s Personal Data.

(a) We aim to keep and safeguard your personal data and/or personal information as accurate as possible.

(b) You can access your personal data at any time, request correction or deletion of all or of any part of your personal data provided to us (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction) or request that the processing of the personal data is restricted.

(c) Such amendments can be carried out at any time by amending the forms you had completed and signed upon your registration with us by emailing us at the email addresses indicated above.

6. Right to data portability

You have the right to receive any of the personal data that concerns you and which you have provided to us, in a structured, digital form and transmit such data to another party, if this is technically feasible. Please contact us at 22815600 or office@toumbas.com and sales@toumbas.com in this respect.

7. Right to lodge a complaint

If you have any issues, queries or complaints regarding the processing of your personal data, please contact us at 22815600 or office@toumbas.com and sales@toumbas.com for further information or for submitting such requests.

8. Cookies and similar technologies

Our websites use “cookies” and similar digital and HTML technologies that collect and store information when you visit any of our websites. This is to enable us to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we can improve your experience when visiting our website(s).You can control and set your cookies preferences by setting your browser settings.

9. Security of your personal information

(a) Our Group is using and has implemented technology and policies with the objective of protecting your private and personal data and information provided to us and kept at our premises.

(b) Your personal data and/or personal information is filed and stored using an encryption in our servers and all hard copies are stores in a secured and locked location at our premises in Nicosia.

10. Who will you share my personal data with?

(a) Your personal data is exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

Other companies within our Group of Companies;
Authorised agents, licensees, service providers and/or subcontractors of our group of Companies;
Any competent public authority, government, regulatory or fiscal agency where it is necessary to comply with any legal or regulatory obligation to which are subject to or as permitted by applicable local law;
Any person to whom we may presently and/or in the future transfer any of its rights and/or duties.

(b) Except as set out in this Privacy Policy, we will not disclose any personal data without your permission unless we are legally entitled or required to do so or if we believe that such action is necessary to protect and/or defend our rights, property or personal safety and those of our customers or other individuals. Only if we are required to do so by law, will your personal data be provided to supervisory agencies, fiscal authorities and investigative agencies.

11. If you communicate with us through social media

(a) If you choose to interact with us or our products and services through social media such as LinkedIn, Facebook and/or Twitter, your personal data (such as your name and the fact that you are interested in our Companies and/or our products) may also be visible to all the visitors of your personal webpage on LinkedIn, Facebook and/or Twitter, according to your privacy settings on the social media services.

We are NOT responsible for the processing of such personal data or the privacy policy of such social media websites.

(b) When you communicate with us through social media (for example, when you post a comment, upload media, send a personal message or become a fan of us and/or any of our social media pages by clicking the "Like" button, we may indirectly receive personal data and/or personal information about you (such as your (user) name, profile photo, your hometown, your email address and your gender). We will use the data received from social media in accordance with this Privacy Policy.

12. How long do we retain your data.

(a) Any Personal data and/or personal information collected and processed by us and/or our officers, shall be processed according to this Privacy Policy and shall be deleted or rendered anonymous (such that it will no longer be possible to identify you) on the following instances:

Immediately upon receiving your proper withdrawal of consent in writing and in accordance to the provisions of this Privacy Policy OR
If we don’t receive any such notice of withdrawal from you, within 36 months from the date of your last recorded purchase of our products using your loyalty card.
In relation to your financial transactions your personal data may be held for a period of 10 years from the transaction and/or as we are legally obliged by any tax or other authorities of the Republic of Cyprus.

13. Changes to this Privacy Policy

(a) This Privacy Policy may be changed and/or amended and or replaced from time to time.

(b) If there is any inconsistency between the English version and the Greek version of this Privacy Notice, the English version shall prevail.

(c) You are advised to regularly review this Privacy Policy for possible changes but if the changes are significant, we will provide you with an appropriate notice, including e-mail or an SMS notification if necessary.

14. Customer Choices & Obligations

Regarding any personal data that we are processing as aforementioned:

Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you) by contacting us at 22815600 or office@toumbas.com and sales@toumbas.com.
Change or Correct Data: You can edit and/or ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate and/or if any of your personal data has been altered and/or amended.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).