Reflections, Summer 2021

PRIVACY UPDATE (Privacy Notice)

To get visitor/user access to our Website www.wengkomole.com (“Website”) and some of the services it offers, first you must notify us of personal data or information that identify or may identify you and which are considered “personal data”. The Website is owned by WENGKO MOLE (the “Company”). We collect, keep, store, organise, adapt, use, process, etc., personal data files which you provide while using/visiting our Website (“Processing”) and we are a “Data Controller” for such data. The Processing of your personal data is limited to what is strictly necessary for the purpose of processing and is performed as per the provisions of legislation in effect.

We respect the privacy of our Website visitors/users and we acknowledge that when you choose to provide us with information relating to you, you trust that we process your personal data in utmost responsibility and integrity. This Privacy Update (Privacy Notice) contains important information concerning the way in which we process your personal data. By choosing to use our Website after accepting its terms of use, you accept the provisions of this Privacy Policy.  In case you do not agree with this Policy, please do not use the Website. We reserve the right to modify this Policy, whenever we deem it necessary, and we ask that you check it regularly so that are informed of any changes of content, as well as the way in which your personal data may be used.

What personal data do we collect and how?

We collect the following data about you, according to the consent you have provided us with, and exclusively for the following processing purposes; if we need more data in relation to these purposes, we will contact you.

• Personal contact information by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and preferences or photograph.
• Internet Protocol Address (IP address). When you visit our site, we may automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform. We may also collect information about your visit, including the full Uniform Resource Locators (URL) clickstream, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• We may also receive information about you from third party we are working closely with including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies.

We do not collect special personal data (as, indicatively, data relating to your racial or national origin, trade union membership, health data or data relating to your sex life or sex orientation). Even in such cases, we have taken the necessary technical and organizational measures for secure keeping and processing of your personal data belonging to the said special categories. Neither do we seek nor collect personal data from people under eighteen (18) years of age. If we find out that, by way of error or having been misled, we have collected personal data from people under eighteen (18) years of age, we shall delete such data the soonest possible.

What purposes do we collect your personal data and how do we use them?

We collect, use and process your personal data which you have provided/notified us from time to time, only to the degree necessary in order to meet the specific objectives on which you have agreed, and which are the following:

• to provide you with a personalized browsing experience when using our site;
• to fulfil any contractual agreements between you and us (for example, when you place an order through our site);
• to send you details (including by post, phone, e-mail or SMS) of other products and services which we think may interest you, unless you inform us in writing that you do not want to receive these details.
• to manage any account that you hold with us;
• to comply with legal and regulatory requirements.

The processing of your personal data for each of the aforementioned processing purposes is performed in accordance with the consent you have provided for such purpose, which consent you may revoke at any time, without such revocation harming the legality of processing already performed based on such consent up to the time of its revocation. The revocation may be submitted electronically at [email protected].

In addition, we (or third parties acting on our behalf) may also store or process information that we collect about you in countries outside the European Economic Area, which may have lower standards of data protection. We may also disclose your information to third parties in connection with the sale, transfer or disposal of our business, provided that they continue to use your information substantially in accordance with the terms of this Privacy and Cookie Policy.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected].

We have put in place technical and organizational security measures designed to prevent the loss or unauthorized access of your personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet.

Do we transmit your personal data to third parties?

We shall share your personal data with third parties to meet the processing purpose(s) in the following cases and after taking all measures necessary for the protection thereof.

• Partner Companies
  Our Company cooperates with DIGITUP with registered base in Greece, which has undertaken IT, administrative and financial support of our Company.
• Compliance with legal provisions

We shall disclose your personal data in case the law obligates us to do so (adherence to a legal provision), to the degree and the extent necessary for us to meet such obligation of ours or if, as per our discretion in good faith, such disclosure is reasonably necessary for our compliance with legal procedures or response to similar requests.

How long do we store/keep your personal data for?

We store your personal data for as long as it is strictly necessary to meet the processing purposes as well as our response to any of your requests.

What are cookies? 

Our Website uses "cookies” technology. Cookies are information which a website may store in the visitor’s browsing application and, then, recover such information so that the visitor is identified next time they visit the Website. We may also use them for web errors, safe gif and similar technologies collecting data similar to those collected by a cookie. A cookie file may contain various types of information, including a user ID used by the website to track the pages visited. The Website cookies are stored in your computer or device and remain there unless you have adjusted the related settings so that cookies are not accepted for the Website. By changing your browser settings, you may be updated each time a cookie is stored in your computer or device. However, if you set your browser so that it does not accept cookies from the Website, you may not have the option of access and use of all Website features.

What cookies do we use? 

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.

Analytical / performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

The table below lists the cookies we collect and what information they store.

Acceptance or non-acceptance of cookies

At your first visit to the Website, you will be informed about the operation of cookies and your option not to accept the installation thereof in your computer or device. If you want to delete cookies that may be installed already, refer to the file management software to locate the file or directory saving cookies. Also, if you want to stop storing cookies in future, refer to the instructions of the browser developer, by clicking “Help” in the browser menu. More cookie related information is available at www.allaboutcookies.org. By deleting existing cookies or disabling future cookies, you may not have access to some parts or features of the Website, possibly leading to an adverse impact on its functionality as well as the ability to receive information or services from us.

Links to third party websites (Hyperlinks)

The Website may contain a hyperlink (link) to third party websites, which have full control over the posted content; therefore, they also have full responsibility for the security, validity of content as well as the manner of collection, storage and processing of personal data and information they collect. We recommend that you carefully review privacy policies of these websites, before using them, so that you ensure that you are satisfied with their manner of collection and use of your information.

How do we protect your personal data?

We are absolutely committed to the safety of your data and, in order to achieve this, we implement all contemporary technical (indicatively, encryption, anonymization) and organizational (indicatively, privacy by design, establishment of policies and procedures) which are suitable for the purposes of Processing; we regularly review the adequacy and response of such measures. Please note that these means of protection do not relate to personal data you choose to share in public domains, such as, for example community websites.

What are your rights?

As a personal data subject, you reserve the following rights:

(a) learning which of your personal data we process, why, the recipients to who such data have been disclosed or are to be disclosed, the time period of storage and, if this is not possible, the criteria establishing such time period (article 15 of the GDPR);

(b) correcting your personal data (e.g., due to omissions or inaccuracies), deleting them from our files (provided the processing thereof is no longer necessary), limiting the processing thereof, your objection to such processing (articles 6-17-18 GDPR);

(c) revocation of tour consent to the processing of your personal data (which does not cover processing retrospectively);

(d) exclusion from the receipt of personalized and customized information, if you have consented to the same through the Website; and  

(e) submission of a complaint to the Data Protection Authority 1-3 Kifisias Ave., PC 11523, Athens tel: +30 210 6475600 email: [email protected]).

Method for exercising your rights?

You may exercise your rights by e-mailing at [email protected] or sending a registered letter to the Company (38, Nikis str., Marousi, Attica, 15123, Greece) or by sending a fax (+30 210 6843529) free of charge, unless such requests are repeated often and create administrative cost for us, in which case you shall be charged the related reasonable cost. If you exercise any of your rights, we shall take all possible measures to satisfy the same, within a month from the receipt of your request, and we will update you accordingly (unless otherwise provided for in effective provisions), unless the complexity of the request requires an extension of this time period for two more months; we shall duly inform you about such extension and the reasons for the delay. Also, we shall announce any correction or deletion of your personal data to all recipients of the disclosure thereof, unless this is disproportionate or impossible, and we shall notify you accordingly upon your request.

Legislation - Effective provisions on personal data security and protection.

Any reference in this Policy to effective provisions on personal data security and protection means Greek LAW 4624/2019 and REGULATION 2016/679 OF THE EUROPEAN PARLIAMENT AND THE COUNCIL of 27 April 2016 “on the protection of individuals with regard to the processing of personal data and on the free movement of such data” or GDPR as more widely known, the related implementing law and the related decisions of the competent organs and authorities, as currently in effect. 

How to contact us?

For any question or comment relating to this Policy or the practices for the collection of personal data that we implement, and for the submission of any related request, please contact us either by emailing email [email protected] in attention of Mrs. Christina Pistofidou or the Data Protection Officer of the Company and you shall receive a response the soonest possible.