We, Harbor Lab S.A., are dedicated to safeguard the security and privacy of your personal data and to comply with the applicable national and European legal and regulatory framework for their protection.
In this context, and in particular, in accordance with the principle of transparency, as provided for by the General Data Protection Regulation and the law 4624/2019 as in force (together the “Data Protection Law”), this privacy policy (hereinafter the “Privacy Policy”) and any other documents referred to in it, sets out the basis on which we collect and process your personal data when you use our website or services, as well as your rights for their protection.
DATA CONTROLLER
For the purposes of Data Protection Law Harbor Lab S.A. acts as a data controller. Please see below our contact details.
LEGAL BASIS FOR PROCESSING
We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
- To fulfill our contractual obligations to you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To comply with a legal obligation.
To the extent we process your personal data for any other purposes, we shall inform you in advance or require that our partners do the same.
PERSONAL DATA WE MAY COLLECT ABOUT YOU
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We process your personal data for the following purposes and, as long as there is at least one of the legal processing bases provided for in the law.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Legal basis for processing |
|---|---|---|
| To register you as a new customer | a. Identity b. Contact Details (Email) |
Performance of a contract with you |
| To process and deliver services such as managing payments, fees, and charges | a. Identity b. Contact Details (Email) c. Financial d. Usage data |
Performance of a contract with you |
| To manage our relationship with you which will include: a. Notifying you about changes to our terms or Privacy Policy b. Asking you to leave a review or take a survey |
a. Identity b. Contact Details (Email) c. Profile data d. Usage data |
a. Performance of a contract with you b. Necessary to comply with a legal obligation c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | a. Identity b. Contact Details (Email) c. Profile d. Usage e. Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | a. Technical b. Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
We may collect and process personal data about you. Personal data, or personally identifiable information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data: includes billing address, delivery address, email address and telephone numbers, company name, website.
- Financial Data: includes bank account number (IBAN), bank account letters, VAT number.
- Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
- Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or our services.
- Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data: includes information about how you use our website and services, including the full Uniform Resource Locators (URL) clickstream to, through and from our website and our services (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.
- Aggregated Data: We also collect, use and share statistical or demographic data for any purpose. This Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
- Special Category Data: We do not collect, store and/or use special category data about you. This means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
HOW IS PERSONAL DATA COLLECTED
The abovementioned data is collected directly from you in the following way:
- Direct Interaction. You may give us your Identity, Contact and Financial Data (e.g. Bank account Information) when you sign in the platform and create an account/registration or correspond with us by phone, email or otherwise. This includes personal data you provide when you register to use our website or to receive our newsletter, subscribe to use our services, create an account to use our website or services, search for a product or place an order on our website, participate in discussion boards or other social media functions on our website, give us feedback or contact us and when you report a problem with our website or services.
PERSONAL DATA WE RECEIVE FROM OTHER SOURCES
We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers) and may receive the following personal data about you from them:
- Technical Data: from analytics providers, advertising networks and search information providers.
- Contact, Transaction and Financial Data: from providers of technical, payment and delivery services.
- Identity and Contact Data: from providers of chat/communication services with customers including via email.
- Identity and Contact Data: from providers of chat/communication services with customers including via email.
- Financial Data: from CRM service providers who manage contacts and keep a record of communications/ interactions with customers.
- Contact Data and Financial Data: from our cloud accounting system that stores email and names of persons sent invoices by email.
DISCLOSURE OF YOUR PERSONAL DATA
Personal data we share with third parties
We may share your personal data with third parties (as referred above). Below is a summary of the types of third parties used:
- Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you to provide services such as IT and system administration services, email communications, hosting services, backup services, credit card processing, research, development, marketing and customer support
- Professional advisors acting as service providers to us in relation to the website or services — including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Tax authorities, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Analytics and search engine providers that assist us in the improvement and optimisation of our website and services.
Personal data we disclose to third parties
We may disclose your personal data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or a member of our group of companies or substantially all of their assets are acquired by a third party, in which case personal data held by them about their customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions, terms of use and/or any other legal agreements; or to protect our rights, property, safety, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- We may share Aggregated Data in the normal course of operating our business; for example, with other website or services users, our customers or publicly to show trends or benchmark the general use of our website and services.
TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES
We may transfer your Financial Data to our payment providers for the execution of payments in the United Kingdom which is a country currently benefitting from an adequacy decision pursuant to Article 45 of Regulation (EU) 2016/679. In the event that such status changes in the future and/or if we wish to transfer any of your personal data to other countries outside the European Economic Area (“EEA”), we shall inform you accordingly.
DATA SECURITY
We have put in place appropriate technical and organizational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For example, all information you provide to us is stored on our secure servers. Any bank account information or payment transactions will be encrypted in-transit using TLS encryption. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the website or services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavor to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website or the services. Any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.
YOUR RIGHTS
You have the following rights under Data Protection Law, free of charge, to protect your personal data:
- Right of access: to access to your personal data.
- Right to rectification: to rectify or delete your personal data.
- Right to erasure: to request the removal or erasure of your personal data.
- Right to restriction of processing: to request the restriction on the processing of your personal data.
- Right to object: to object to the processing of your personal data.
- Right to data portability: to request the transfer of your personal data in a structured, machine- readable and commonly used format to other controllers.
- Withdraw your consent to us processing your personal data, at any time.
For more information about your rights, you may access the following link on the Hellenic Data Protection Authority’s website: https://www.dpa.gr/en/individuals/rights-of-individuals
lf you wish to exercise any of the above rights, please contact us as set out at the end of this Privacy Policy. We will respond to such queries within 30 days and deal with requests we receive from you, in accordance with the provisions of the Data Protection Law. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
DATA RETENTION
We retain personal data for as long as reasonably necessary to fulfill the purposes for which it was provided or collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfill your request to “unsubscribe” from further messages from us.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
This will be for as long as we provide access to the website or services to you, your account with us remains open or any period set out in any relevant contract you have with us. After you have closed your account or ceased using the services for a period of at least 60 days, we usually delete personal data.
We will retain some anonymised information after your account has been closed and we may use this for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the website or services. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
COMPLAINTS
If you have any complaints about our use of your personal data, please contact us as set out at the end of this Privacy Policy.
If you believe that your rights are infringed in any way, you have the right to file a complaint with the Hellenic Data Protection Authority through the following methods: (a) Postal address: 1-3 Kifissias Avenue, PC 115 23, Athens, Greece (b) Telephone: +30-210 6475600, (c) E-mail: contact@dpa.gr
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.
The updated version replaces any other Privacy Policy previously applicable from the updated date.
YOUR RIGHT AND CHOICES
Harbor Lab respects your right to privacy: it is important that you are able to control your personal data.
You have the following rights: CLICK HERE.
To deal with your request, we may require proof of your identity.
CONTACT
If you have any questions, comments or requests regarding our privacy practices or about this Privacy Policy please contact us as follows:
- Address: 278 Kifisias Avenue, 15232, Athens Greece
- By email:operations@harborlab.com