Privacy Policy

Privacy Policy (Personal Data Protection Policy)

The protection of your personal data is important to us. This Personal Data Protection Policy (hereinafter the “Policy”) describes the practices of the company under the name “TScommerce Single Member S.A.”, with the distinctive title “Twill”, headquartered in Athens, at 210 A Eleftheriou Venizelou Str., 17563, Palaio Faliro, Tel: +30 2109802659, VAT Reg. No.: 802758955, General Commercial Registry (G.E.MH) No.: 182244201000, Tax Office (KEFODE) of Attica, email address: twill@tscommerce.eu and e-shop customer service line: +30 210-9802659 (hereinafter “We”, “us”, “Us”, “our” or the “Company”) regarding the collection, use, storage, and disclosure of Personal Data (as defined below) provided by you to the Company through its website (hereinafter the “Website”). Furthermore, this Policy describes the type of products and services provided through the website (hereinafter the “Services”).

When you visit our website or provide us with information through it, you acknowledge that you have read, understood, and unconditionally accepted the terms set out in this Policy. This Policy constitutes an integral part of the Terms of Use, which are incorporated by reference. Any capitalized term used but not defined in this Policy shall have the meaning assigned to it in the Terms of Use. The date of the last update of the Policy appears at the end of this document. Please check the content of the website regularly for any changes. In case of disagreement, you must not use the website and its content.

Please note that this Policy applies only to the website https://www.twill.gr and not to other websites to which we may be linked or which are linked to us.

The Company acts as the Data Controller for your Personal Data and, in this capacity, undertakes to make every effort to ensure the confidentiality of your personal data and the unimpeded exercise of the rights granted to you by the Applicable Data Protection Law. The Company recognizes that protection against the processing of your personal data is important to you and wishes to ensure that every experience of using its Website is safe and reliable. In pursuit of this goal, the Company has developed this Policy to explain its practices regarding the collection, use, disclosure, and storage of your personal data and information.

1. Personal Data and Applicable Law

For the purposes of this Policy, “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We collect, use, disclose, and store your Personal Data in accordance with this Policy and applicable data protection law (Applicable Data Protection Law).

The Applicable Data Protection Law consists of the current national and EU legislation on the collection, use, and disclosure of your personal data, including, among others, Regulation (EU) 2016/679 of the European Parliament and of the Council (adopted on 27 April 2016 and applicable from 25 May 2018) (hereinafter the “Regulation” or “GDPR”), Law 4624/2019 “on the protection of the individual from the processing of personal data”, as applicable, as well as the directives of the Hellenic Data Protection Authority.

2. Special Note for Minors

Minors under the age of eighteen (18) and persons who do not have full legal capacity according to the jurisdiction applicable to them are prohibited from disclosing their personal data to Us through the Website, by telephone, or in any other way, without the prior consent of the person or persons exercising parental responsibility for them. We ask these persons not to submit information to Us. In the event that website users are under eighteen (18) years of age and continue to disclose their personal data to us through the website, it will be considered by Us that these persons have obtained the prior consent of the person or persons exercising parental responsibility for them.

3. Personal Data and Method of Processing :

• If you wish to proceed with the creation of a personal account by registering on the Website: You will be asked for some of your personal information, such as your first and last name, your email address, as well as the creation of a personal password.
• When you use our Services: You may be asked for certain personal details, such as your postal address, payment method details when you order from our online store, and your email address when you subscribe to one of our competitions or newsletters.
• If you contact (in writing or orally) the Company’s Customer Service Department: We may store/record your relevant correspondence/communication, as well as any data requested from you that is necessary for your better service and/or proof of our transactional relationship (e.g., in case you place a telephone order for products).

4. Information We Receive Automatically When You Visit the Website or Use the Services

Website: We may collect information from the website and how you use it. When you visit the website, the web browser sends data to our servers. With this information, we can optimize our services by customizing and improving your experience when using the website (via computer, mobile phone, or other portable device). This information may include the following items:

• Your IP address,
• The date and time of your visit to the Website,
• The referral URL (i.e., the website from which the user came),
• The pages you have visited on our website,
• Information about the device you are using and your web browser (browser type and version, operating system, etc.).

Location Information: When you visit the website from your computer, mobile, or portable device, we may collect and process information about your actual location, based on, for example, GPS signals emitted by the device. We may also use various other technologies to determine your location, such as sensor data from your device that may, for example, provide us with information on nearby Wi-Fi access points, or Near Field Communication (NFC) and/or GSM towers. Note that we will inform you when we are about to use information regarding your location, and usually, you can disallow or disable the sending of your location information through your device settings or your web browser.

Cookies and Other Identifiers: We and our partners use various technologies to collect and store information when you visit our website, and this may include sending one or more cookies or other identifiers to your device. More information on how we use cookies and identifiers and how they can be disabled can be found below in Article 11.

5. Links to Other Websites – Advertising via Third Parties

It is possible that on our website we provide links to third-party websites, as we have and will have future collaborations with third parties. When you connect via third-party links or otherwise visit, participate in, or use the services or websites of other parties, regardless of whether they contain our brand name, trademarks, and other intellectual property rights along with those of the third party operating the respective website, you should be aware and conscious that third-party websites operate according to their own terms of use and privacy policies. In no case do we control the business practices of these parties.

We allow third-party companies to display advertisements and/or collect certain anonymous information when you visit the website. These companies may use anonymous, non-personally identifiable information during your visits to the website or other websites in order to provide advertisements for goods and services that may be of interest to you. These companies usually use a third-party cookie or web beacon to collect this information. More information about cookies can be found below in Articles 11 and 12.

6. Purposes of Processing Your Personal Data

We use your personal data for the purposes briefly described below:

• Management of the order placed via the website or by telephone: We use information such as your name, address, and payment details to process and deliver your orders, as well as to inform you about the status of your order. We may also use the information to assess your creditworthiness, and for this purpose, we may use the services of third parties.
• Customer Service Department: If you contact our Customer Service department (by phone or in writing) (or vice versa), we use your order information as well as our communication history to respond to your requests, manage your order, facilitate the exercise of your rights, and generally provide you with the best possible service.
• Marketing/Promotion: To send you messages (emails) with news and updates regarding the website and our services, to provide and send you information tailored to your interests (such as electronic banners and offers), obtaining in each case your prior consent to use your personal data for the above purposes.
• Use of the Website: To improve and customize the content of the website and product offers, as well as to analyze how the website is used.
• Other Company Services: We may also use your personal data to provide you with information about products and services provided by third parties, provided you have given your consent. Furthermore, we may use your personal data to forward messages from other members or users to you, thus facilitating your communication with other members or users of the website.
• Dispute Resolution: We may also use your personal data to resolve disputes, troubleshoot problems, and enforce any policies and rules governing the use of the website, and to inform you of changes in the use of the website, its Terms of Use, and this Policy.
• Other Purposes: To the extent required by law, we will ask for your consent when we wish to use your data for purposes other than those listed above.

The provision of your personal data by you is voluntary. However, in some cases, if you do not provide us with your personal data, the Company will not be able to provide you with access to all or some of its services.

7. Access to Personal Data

We do not sell your personal data to third parties, nor do we grant licenses to third parties to use them for their own account. However, to the extent necessary to achieve the processing purposes mentioned above in Article 6, we may share some of your personal data with:

• A limited number of our staff and employees in the marketing, sales, customer service, and technical departments, who are appropriately informed and trained regarding the Regulation and other aforementioned legislation to the extent necessary to provide you with the Services and to achieve the processing purposes mentioned above.
• Our authorized third-party partners acting on our behalf in accordance with this Policy (as specifically defined below), or as permitted or required by applicable Personal Data protection laws, with whom we have Confidentiality Agreements.

You may request the full list of data processors acting on our behalf by sending a written request to the address mentioned at the beginning of this Policy.

7.1 Transfer of Personal Data

We may use third-party service providers (e.g., web hosting providers, data management providers) to manage one or more aspects of our business activities, including the processing or delivery of personal information on our behalf. When we use an external company or partner, we use contractual commitments or other appropriate means to ensure that your personal data is used in a manner consistent with this Policy and applicable legislation on the protection of personal data processing.

7.2 Social Media

7.2.1 Our website offers you the possibility to register via connection (plug-ins) with your existing account on various social media (e.g., Facebook, Twitter, Google+, etc.). If you choose to interact with a social medium (for example, when creating/connecting your account on the Website), then your activity on the website will also become available to the social media you have chosen to use (e.g., Facebook, Twitter, etc.).

7.2.2 If you are logged into a social medium during your visit to our website, then the social medium may add this information to your respective profile. If you use a social plug-in, then this information will be transferred to the respective social medium. If you do not want such data transfer to occur, please log out of the relevant social medium before connecting to our website.

7.2.3 More specifically, we offer you the ability to create an account on our website using the account you already have on the social medium of your choice (e.g., Facebook). This will save you time in creating an account on our website because your login details will be transferred and automatically imported to our website from your social media account. Note that when you use this “social login” feature, we receive certain information from the social medium, such as your name, age, location, preferences, profession, as well as other elements of your public profile, and we may possibly have access to your photos or friend lists on the relevant social medium. This information is not requested by our Company but is provided by the social medium, utilizing the aforementioned social login capability. When you use this feature, our Company will import solely the data required to create your account with us; any other supplementary information we receive from the social medium will be discarded. After your account is created, you will have the ability to add any information you wish to share with us.

7.2.4 Please read the privacy policies of the relevant social media to be informed in detail about the collection and transfer of personal data, your rights, and how you can achieve satisfactory settings for the protection of your privacy.

7.3 Disclosure According to Law We may disclose your personal data as permitted or required by law. For example, we may be required to disclose and announce your personal data pursuant to a court decision, prosecutor’s order, or order or decision of another person or administrative body with legal authority to compel the disclosure of such information.

8. Rights of Data Subjects

8.1 Regarding your personal data, you retain the following rights:

8.2 Right of access, modification, rectification, or update of your personal data as well as objection to the processing of your data, which you can exercise by following the steps that will be mentioned each time in the message you receive via the relevant communication medium (such as email or SMS messages).

8.3 Right to withdraw your consent for the processing of your personal data: If you wish to withdraw your consent from all our newsletters as well as your consent for the use of your Personal Data for marketing purposes, product promotion, and/or services, you can use the ‘unsubscribe’ link as stated in the messages you have received. Alternatively, you can contact our Customer Service department via email at twill@tscommerce.eu or by phone at +30 210-5711475. Please note that we may need to ask you to verify your identity before proceeding with your request.

8.4 Right to erasure (Right to be forgotten): You may at any time request that your personal data kept in our files be permanently deleted, by contacting our Customer Service department via email at twill@tscommerce.eu or by phone at +30 210-9802659. We, on our part, will respond within one month from the receipt of your request. In case our response is not considered satisfactory by you, you have the right to appeal to the Data Protection Authority and request the examination of our response or our failure to act.

In case of a deletion request by you:

a) We will cease using and making available your personal data (unless otherwise provided or required by law).

b) We will delete all your personal data from our databases, except for those contained in emails, correspondence, or other documents that we may keep to prove the terms of our contractual relationship with you or as otherwise provided by applicable law and for a period not exceeding the limits of their legal retention.

c) Taking into account available technology and the cost of implementation, we will take reasonable technical and organizational measures to inform other data processors who process your personal data on our behalf as specifically mentioned above, that you have requested the deletion by them (the processors) of any links to such data or copies or replications of such personal data. Please note that we may need to ask you to verify your identity before proceeding with the above request.

8.5 Right to receive a copy: Upon your request, the Company provides you with an electronic or other copy of the personal data it holds about you.

8.6 Right to portability: Upon your request, the Company transmits your personal data for processing by a third party and subsequently deletes them permanently from its files. In such a case, the Company bears no responsibility for the processing of data by the new data controller to whom your Personal Data will be sent, nor for the quality of the data to be transferred, beyond what is required under the Regulation. The Company, as Data Controller, must verify your identity before proceeding with the above.

8.7 Finally, you have the Right to lodge a complaint with the Hellenic Data Protection Authority by submitting a relevant complaint to this authority (www.dpa.gr), Kifissias Avenue 1-3, Athens, Postal Code 11523, telephone: +30 210 6475600, fax: +30 210 6475628, email: contact@dpa.gr.

9. Principles Governing the Processing of Personal Data

Within the framework of respecting your private/personal life, we strive to ensure that your personal data is kept in accordance with the Applicable Data Protection Law, as well as in accordance with any other applicable relevant legislation. In this context, we guarantee that your personal data will:

(a) Be subject to lawful processing.

(b) Be collected only for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.

(c) Be relevant, appropriate, and not excessive in relation to the purposes of the processing. We will collect and maintain your personal data only insofar as it is necessary for the fulfillment of operational and administrative requirements or for our compliance with any legal obligation.

(d) Be kept in a form which permits identification of you for no longer than is necessary for the purposes for which they were collected or for which they were subsequently processed. Specifically, we retain your personal data for a limited period of two (2) years, starting from the time of your last communication with us, unless there is an obligation to retain the information for a shorter/longer period by law, or if this is required in the context of legal action or to fulfill our transactional relationship or for purely administrative purposes of the Company.

(e) Be subject to appropriate technical and organizational measures against unauthorized or unlawful processing of your Personal Data and against accidental loss or destruction or damage thereto within the framework of the Company’s activity.

(f) Not be transferred by Us to countries outside the European Union unless you have given your consent and only if an adequate level of protection of the rights and freedoms of Personal Data subjects regarding the management of the exported data has been established and implemented.

10. Contact

If at any time you have questions or queries regarding this Policy or believe that we have violated or mishandled your personal data, please send an email to twill@tscommerce.eu or alternatively contact the Customer Service Department at tel. +30 210-9802659, and we will attempt to resolve any problem or question you may have.

11. Cookies

11.1 To better serve you and for ease of use of the Website, we use “cookies”, a technology that, through alphanumeric codes, installs a small amount of information on a website user’s computer to enable the website to recognize future visits by the user using the same computer/device. For example, information provided through cookies is used to recognize you as a previous user of the website, to offer personalized content on the website and information about its use, and to facilitate your experience on it. You can choose to reject cookies during your first visit to the website and subsequently by selecting the corresponding link at the bottom of the Website; however, this may affect the use of the website and your ability to access certain functions and transactions. More information on deleting or controlling cookies is available at www.aboutcookies.org.

11.2 Types of cookies we use

Below we present a brief overview of the types of cookies we use and the functions they perform.

11.2.1. STRICTLY NECESSARY COOKIES

These are technically necessary for the operation of the website, which is why you cannot reject them. They help you navigate the Website and see certain features or use its basic functions.

11.2.2. SESSION COOKIES

Session cookies are stored temporarily on your computer or device during a browser session and are deleted upon termination of the browser session.

11.2.3. PERFORMANCE COOKIES (Analytics cookies)

These are used directly by the website administrator to collect aggregate information regarding user activities performed on the Website, collected anonymously and solely for statistical purposes. They help us understand how you navigate the website as well as your purchasing behavior, so that we can improve the website and make the purchasing process easier and more enjoyable for you.

11.2.4. TARGETING COOKIES

These cookies aim to create user profiles and store your preferences regarding our products. These cookies allow us to share your preferences with our advertisers. They are used to measure the effectiveness of an advertising campaign as well as to send advertising messages according to your preferences while browsing the Website; e.g., if you visit Google’s website, the advertisement you see will be more relevant to your preferences.

11.3 If you do not wish to accept cookies

Regarding non-strictly necessary cookies, you have the following options:

• Change your browser settings to delete or prevent cookies from being stored on your computer or mobile device without your explicit consent. The “help” section in your browser will provide you with information on how to manage your cookie settings.
• Change the cookie settings in relation to the Website by following the link titled “Cookies” at the bottom of the Website.

12. Tracking Information

We may use web beacons or pixel tags to track information and specifically to record our users and gather data and information regarding the demographic characteristics of website users, website traffic, usage statistics, etc. Subsequently, and provided we have obtained your consent as above, we may provide this data to advertisers and other partners to improve our Services or to provide other collateral services. None of this data can be linked to the identity or other personal data of individual users. Since web beacons work like any other request for content on the website, you can make them ineffective either by opting out of cookies or by changing the cookie settings in your browser. Also for our own research/statistical purposes, we may link tracking information via web beacons with personal data provided voluntarily by website users. When such a link is made, the entire set of linked information is treated as personal data, which will therefore be used, processed, and disclosed in accordance with this Policy.

13. How will you be informed of any amendments to this Policy?

We update this Policy whenever necessary. If there are significant changes to the Policy or the way we use your personal data, we will publish the update of this Policy on our website before the changes take effect and will notify you by any appropriate means.