Privacy Policy

Privacy Policy

Introduction

The privacy of visitors to our website, https://frattisauctions.gr/ (the “Website”), is very important to us, and we are committed to protecting it. This Privacy Policy explains how we collect, use and protect your personal data. The company under the name “FRATTIS STAVROS KAI SIA O.E.” (hereinafter the “Company”) acts as the Data Controller of your personal data collected through your use of the Website. For further information regarding the processing of your personal data, you may contact us using any of the following methods:

by email at info@frattisauctions.gr, or
by post at: 3 Lambovou Street, Sepolia, Athens 104 43, Greece.

Your consent to the use of cookies, in accordance with the terms of our Cookies Policy, during your first visit to the Website, allows us to use cookies each time you visit the Website. For more information regarding the use of cookies, please refer to our relevant Cookies Policy here.

Definitions

The following definitions are necessary for the interpretation of this Privacy Policy and are intended to avoid lengthy and repetitive wording.

“GDPR”: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
“Personal Data” or “Data”: 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.
“Processing”: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Pseudonymisation”: the processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.
“Data Controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data; where the purposes and means of such Processing are determined by Union or Member State law, the Data Controller or the specific criteria for its designation may be provided for by Union or Member State law.
“Consent” of the Data Subject: any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.
“Personal Data Breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed.
“Profiling”: any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Collection of Personal Data, Purposes and Legal Bases for Processing

The following types/categories of Personal Data may be collected, stored, used and otherwise Processed when you browse the Website or use the services provided through it or the Company’s services. Depending on the manner in which the Personal Data are collected, the purposes and legal bases for their Processing are determined accordingly.

A. Data Collected and Processed During Your Browsing of the Website

The following categories of Personal Data may be collected:

information relating to your computer, including your IP address, estimated geographical location, browser type and version, and operating system; and
information relating to your visits to and use of the Website, including the referral source, length of visit, page views and Website navigation paths.

We Process the above Personal Data for the following purposes:

ensuring the proper and secure operation of the Website; and
providing technical administration and support for our systems (e.g., diagnosing technical issues and analysing traffic on the Website).

The legal bases for Processing the above Personal Data are:

your explicit Consent, where required, in accordance with Article 6(1)(a) of the GDPR; and
the Company’s legitimate interests in maintaining and operating the Website as part of its business activities, as well as ensuring its proper, secure and efficient operation, in accordance with Article 6(1)(f) of the GDPR.

B. Data Collected and Processed When You Register/Create an Account on the Website

The following categories of Personal Data may be collected:

information that you provide when creating your account on the Website, such as your first name, last name, username, email address and mobile phone number; and
information relating to your purchases, the services you use, your order history, participation in auctions and transactions carried out through the Website, including your name, delivery address, telephone number (optional), as well as any other information that you voluntarily provide while using your account on the Website.

We Process the above Personal Data for the following purposes:

providing and administering your Website account, handling any requests you submit and responding to your communications;
verifying your identity in order to enable you to participate in online auctions conducted through the Website;
performing and administering our contractual relationship with you, where such relationship arises through your account, including, without limitation, when you purchase products through the Website’s online store (e-shop), are declared the successful bidder, or otherwise participate in online auctions, as well as providing post-sale services, such as handling complaints, processing product returns, or returns of a movable item or a set of movable items offered for auction as a single lot (the “Lot”), and similar services;
sending newsletters and informational or promotional/marketing communications (where you have provided your Consent);
complying with the Company’s legal obligations (including, without limitation, tax obligations); and
protecting the Company’s legitimate business interests, including Processing that is strictly necessary for fraud prevention and system security, as well as supporting and defending the Company before administrative or judicial authorities.

The legal bases for Processing the above Personal Data are:

your explicit Consent when creating your account, in accordance with Article 6(1)(a) of the GDPR;
the performance of a contract between you and the Company where you purchase a product through the Website’s online store or buy, sell or otherwise participate in an online auction conducted through the Website, in accordance with Article 6(1)(b) of the GDPR;
compliance with the Company’s legal obligations (including tax obligations), in accordance with Article 6(1)(c) of the GDPR; and
the Company’s legitimate interests in providing its services through the Website, facilitating our communications with you, and establishing, exercising or defending its legal rights before any administrative, judicial or other competent authority, in accordance with Article 6(1)(f) of the GDPR.

C. Data Collected and Processed When You Make Purchases Through the Website’s Online Store (E-shop) Without Creating an Account

The following categories of Personal Data may be collected:

information required to complete your order and arrange its delivery, such as your full name, delivery address, email address and Tax Identification Number (TIN), where you operate as a sole proprietor and request the issuance of an invoice; and
any other information that you voluntarily provide during the completion of your purchase, such as your telephone number.

We Process the above Personal Data for the following purposes:

managing and delivering your order, communicating with you in relation to your purchase, and providing after-sales services, including the handling of complaints, returns and similar requests;
complying with the Company’s legal obligations (including, without limitation, tax obligations); and
protecting the Company’s legitimate business interests, including Processing that is strictly necessary for fraud prevention and system security, as well as supporting and defending the Company before administrative or judicial authorities.

The legal bases for Processing the above Personal Data are:

the performance of the sales contract concluded between you and the Company through the Website’s online store (e-shop), in accordance with Article 6(1)(b) of the GDPR;
compliance with the Company’s legal obligations (including tax obligations), in accordance with Article 6(1)(c) of the GDPR; and
the Company’s legitimate interests in providing its services through the Website, facilitating our communications with you, and establishing, exercising or defending its legal rights before any administrative, judicial or other competent authority, in accordance with Article 6(1)(f) of the GDPR.

D. Data Collected and Processed When You Participate in an Online Auction Conducted Through the Website

The following categories of Personal Data may be collected:

the Personal Data collected for the creation of your account (see Section B above);
information relating to your participation in the auction, including the submission of bids; and
your delivery address, where this has not already been provided during account registration, if you are declared the successful bidder.

We Process the above Personal Data for the following purposes:

verifying your identity and enabling your participation in online auctions, as participation is not possible without creating an account;
administering the auction process, including the recording and management of bids; and
managing and delivering the Lot for which you are declared the successful bidder, as well as communicating with you regarding the relevant transaction.

The legal bases for Processing the above Personal Data are:

the performance of the contract governing your participation in the online auction, in accordance with Article 6(1)(b) of the GDPR;
compliance with the Company’s legal obligations (including tax obligations), in accordance with Article 6(1)(c) of the GDPR; and
the Company’s legitimate interests in communicating with you, handling your requests, ensuring the security of the Website, preventing fraud, safeguarding the integrity, transparency and reliability of the auction process, and establishing, exercising or defending its legal rights before any administrative, judicial or other competent authority, in accordance with Article 6(1)(f) of the GDPR.

E. Data Collected and Processed When You Participate in In-Person Auctions

The following categories of Personal Data may be collected:

identification and registration information required for your participation in an in-person auction, including, without limitation, your full name and contact details (email address and telephone number);
information relating to your participation in the auction process, including the bids you submit during the auction, the outcome of your participation (whether or not you are declared the successful bidder), as well as any information you provide in the course of communications with the Company before, during or after the auction; and
transaction-related information where a Lot is awarded to you, including billing, payment and delivery details.

We Process the above Personal Data for the following purposes:

organising, conducting and administering the in-person auction, including recording and monitoring bids;
verifying your identity and managing your participation in the auction process, including where you are the successful bidder;
completing the transaction where you are declared the successful bidder, including invoicing, payment processing and delivery of the Lot;
communicating with you regarding the auction;
complying with the Company’s legal obligations, including, without limitation, tax and accounting obligations; and
establishing, exercising or defending the Company’s legal claims before judicial, administrative or other competent authorities.

The legal bases for Processing the above Personal Data are:

the performance of a contract between you and the Company, or the taking of steps at your request prior to entering into such contract, in accordance with Article 6(1)(b) of the GDPR;
compliance with the Company’s legal obligations, in accordance with Article 6(1)(c) of the GDPR; and
the Company’s legitimate interests in ensuring the proper and secure conduct of auctions, preventing fraud and abusive practices, and establishing, exercising or defending its legal rights before any competent authority, in accordance with Article 6(1)(f) of the GDPR.

F. Data Collected and Processed During Your Visit to and Purchases from the Company’s Physical Store

The following categories of Personal Data may be collected:

identification and contact information that you provide when making purchases or carrying out transactions at our physical store, where you do not collect the purchased products directly from the store and instead request delivery by post or courier, including, without limitation, your full name, billing address (where required), email address and telephone number;
information relating to your transactions at the physical store, including the products or services you purchase, the value of the transaction, payment details (without storing full payment card details where payment is made through a POS terminal or payment service provider), and information required for the issuance of an invoice, where applicable;
customer service and communication information, including requests, enquiries or complaints submitted during or following your visit to the store; and
any other information voluntarily provided by you during your visit to the store, to the extent necessary for the provision of our services.

We Process the above Personal Data for the following purposes:

completing your transactions at the physical store, including the sale of products or services, issuing receipts or invoices and processing payments;
providing customer support and assistance before and after the sale;
managing the Company’s accounting, tax and other legal obligations;
handling requests, complaints or disputes arising from transactions carried out at the physical store; and
protecting the Company’s legitimate interests, including fraud prevention and ensuring the proper operation of commercial transactions.

The legal bases for Processing the above Personal Data are:

the performance of the contract for the sale of products, or the taking of steps at your request prior to entering into such contract, in accordance with Article 6(1)(b) of the GDPR;
compliance with the Company’s legal obligations, in accordance with Article 6(1)(c) of the GDPR; and
the Company’s legitimate interests in ensuring the proper operation of the physical store, managing commercial transactions, preventing fraudulent or abusive conduct, and establishing, exercising or defending its legal rights before any competent authority, in accordance with Article 6(1)(f) of the GDPR.

G. Data Collected and Processed When You Contact Us by Email at info@frattisauctions.gr or eshop@frattisauctions.gr

The following categories of Personal Data may be collected:

your email address, as well as any information that you voluntarily provide (including, without limitation, your full name, telephone number, etc.) in any email correspondence with us; and
information relating to our communications, including the date and time of sending and receiving email messages, as well as the content of such correspondence.

We Process the above Personal Data for the following purposes:

managing and responding to your requests or enquiries;
facilitating our communications with you and providing information regarding the Company’s services or business activities; and
protecting the Company’s rights and legitimate interests, including the establishment, exercise or defence of legal claims.

The legal bases for Processing the above Personal Data are:

taking steps at your request prior to entering into a contract and/or the performance of a contract between you and the Company, where your communication relates to the Company’s services or transactions, in accordance with Article 6(1)(b) of the GDPR;
compliance with the Company’s legal obligations, in accordance with Article 6(1)(c) of the GDPR; and
the Company’s legitimate interests in managing communications with third parties, ensuring the proper operation and security of its services, and establishing, exercising or defending its legal rights before administrative, judicial or other competent authorities, in accordance with Article 6(1)(f) of the GDPR.

H. Data Collected and Processed When You Subscribe to the Company’s Newsletter

The following category of Personal Data may be collected:

your email address.

We Process the above Personal Data for the following purpose:

sending newsletters and promotional or informational content relating to the Company’s business activities, products and services.

The legal bases for Processing the above Personal Data are:

your explicit Consent to subscribe to and receive the newsletter, in accordance with Article 6(1)(a) of the GDPR; and
the Company’s legitimate interests in promoting its products, services and auctions in the ordinary course of its business activities, in accordance with Article 6(1)(f) of the GDPR.

I. Collection of Data Through CCTV Systems

Please note that the Company operates CCTV systems in the following areas. Accordingly, when you enter and remain in these areas, your Personal Data are collected and Processed:

the physical store;
the auction premises (without audio recording of the auctions); and
the area designated for the receipt and inspection of Lots.

The Personal Data collected and Processed consist of your image and movement data.

We Process the above Personal Data for the following purposes:

ensuring the protection and security of persons and property within the above premises, including in the event of attempted criminal acts by third parties against the Company’s employees, the products sold in the Company’s physical store, persons participating in in-person auctions and/or the products auctioned therein, as well as persons and the Lot during the receipt and inspection process;
ensuring the transparency and reliability of the auction process and verifying auction results, as well as the integrity of the receipt and inspection process for Lots; and
protecting the Company’s rights and legitimate interests, including the establishment, exercise or defence of legal claims.

The legal basis for Processing the above Personal Data is the Company’s legitimate interests in protecting its property, ensuring the safety and security of persons and property, safeguarding the transparency of the auction process and the receipt and inspection of Lots, and establishing, exercising or defending its legal rights before administrative, judicial or other competent authorities, in accordance with Article 6(1)(f) of the GDPR.

J. Profiling

Please note that, to the extent that we maintain a customer database based on information collected when you make purchases or carry out transactions with the Company—whether through our physical or online stores, or where you are the successful bidder in an online or in-person auction—we may create a customer profile reflecting your purchasing preferences. Profiling is not carried out solely by automated means but involves human intervention.

We may use the following categories of Personal Data for profiling purposes:

identification data, including your name and contact details;
transaction data, including your purchase history; and
preference data, including your preferred methods of interacting with the Company, whether through the Website, the online or physical store, or online or in-person auctions.

We Process the above Personal Data for the following purposes:

Customer relationship management and customer insight: by maintaining a history of your purchases and transactions, we are able to manage our relationship with you, personalise our services and better understand your preferences; and
Direct marketing (as recognised in Recital 47 of the GDPR): based on your purchase and transaction history, we may send you information regarding new products available in our stores, upcoming auctions, promotions and special offers that we believe may be of interest to you.

The legal basis for Profiling is the Company’s legitimate interests, pursuant to Article 6(1)(f) of the GDPR, namely:

maintaining effective commercial relationships with customers, understanding their preferences and improving the products and services we offer; and
promoting our products and services to customers who, based on their purchasing history, are likely to be interested in our offerings.

You have the following rights in relation to Profiling:

Right to Object
You may object, at any time and free of charge, to the Processing of your Personal Data for Profiling purposes.
Right of Access
You have the right to obtain access to information relating to any Profiling carried out concerning you, including the Personal Data used for such Profiling.
Right to Rectification
If you believe that the Personal Data used for Profiling are inaccurate or incomplete, you have the right to request that they be corrected.
Right to Erasure
You have the right to request the deletion of any customer profile maintained by the Company. Please note that deleting your profile does not necessarily result in the deletion of the Personal Data that we Process in accordance with Sections A to I of this Privacy Policy. Furthermore, your profile may also be deleted where you exercise your right to object to such Processing.
Right to Restriction of Processing
You may request the restriction of the Processing of your Personal Data for Profiling purposes.
Right to Lodge a Complaint
You have the right to lodge a complaint with the Hellenic Data Protection Authority (postal address: 1-3 Kifisias Avenue, Athens 115 23, Greece; telephone: +30 210 6475600; email: contact@dpa.gr) if you believe that this Processing infringes the applicable data protection legislation.

Please also note that:

we do not request, collect or Process any special categories of Personal Data (also referred to as “sensitive Personal Data“);
where the Processing of your Personal Data is based on the Company’s legitimate interests, we carefully balance those interests against your rights and freedoms to ensure that our legitimate interests do not unjustifiably override your rights and freedoms;
where the legal basis for Processing your Personal Data is the performance of a contract between you and the Company or compliance with the Company’s legal obligations, the provision of the relevant Personal Data is mandatory. Without such information, we may be unable to perform the contract or comply with our legal obligations, as applicable;
where payments are made through the Website, the Company does not collect, Process, access or store any payment details (such as payment card numbers, CVC codes or similar information). Payments are completed by redirecting you to the secure payment environment of the cooperating banking institution or payment provider. The Company receives only confirmation as to whether the transaction has been successfully completed. We recommend that you carefully review the privacy policy available on the relevant payment provider’s website. The Company neither has access to nor exercises control over the Processing of Personal Data carried out through the payment provider’s website;
we do not knowingly collect or Process the Personal Data of individuals under the age of 18 and make reasonable efforts to prevent registration or the submission of Personal Data by minors. If we become aware that such Personal Data have been collected, we will promptly contact the parent, legal guardian or other person exercising legal custody and, where appropriate, delete the Personal Data without undue delay, unless retention is required for the establishment, exercise or defence of the Company’s legal claims;
we do not request or knowingly collect the Personal Data of third parties. Before disclosing the Personal Data of another individual to us, you must ensure that you have obtained that person’s consent to such disclosure and Processing in accordance with this Privacy Policy. The Company shall not be liable where you provide us with the Personal Data of third parties without obtaining the necessary consent or without informing those individuals accordingly; and
the username selected by you when creating your account (which may be changed up to one (1) day before the end of each auction upon request to the Company) will be published together with the history and results of online auctions. Where the username contains Personal Data, such publication is carried out for the purposes of ensuring the transparency of the auction process and enabling verification of auction results, in pursuit of the Company’s legitimate interests in maintaining the transparency and reliability of its auctions and in establishing, exercising or defending its legal rights before any competent authority, in accordance with Article 6(1)(f) of the GDPR. We therefore recommend that your chosen username does not contain Personal Data.

The privacy settings available for your account may be used to limit the visibility of your information on the Website and can be configured through the privacy controls provided on the Website.

Recipients of Personal Data

We may disclose your Personal Data for the purposes described in this Privacy Policy:

to any of our employees, officers, insurers, professional advisers, representatives, suppliers or subcontractors, where such disclosure is necessary for the purposes set out in this Privacy Policy;
where required by law or in connection with any current or prospective legal proceedings;
for the purpose of establishing, exercising or defending our legal rights (including, among other things, providing information to third parties for the purposes of fraud prevention and reducing credit risk);
in connection with any corporate restructuring, sale or transfer of assets of the Company; and
where required or requested by a court, judicial authority or any other competent authority.

International Data Transfers

We do not transfer Personal Data to third countries. Should such transfers become

necessary in the future, we will update this Privacy Policy accordingly and ensure that the level of protection of natural persons guaranteed by the GDPR is not undermined.

Data published on the Website in connection with the history and results of auctions may be accessible from any geographical location worldwide where the Website is available. We cannot prevent the use or misuse of such information by third parties.

Retention and Storage of Personal Data

This section sets out the Company’s policy and procedures regarding the retention of Personal Data.

Personal Data that we Process for any purpose shall not be retained for longer than is necessary for the fulfilment of that purpose.

More specifically:

Personal Data collected during your browsing of the Website shall be retained for a maximum period of one (1) year from the date of collection;
Personal Data collected when you create an account on the Website shall be retained for as long as your account remains active and shall be deleted within one (1) year from the date on which you delete your account, unless a longer retention period is required for the performance of our contractual obligations or for compliance with our legal obligations;
Personal Data collected when you make purchases through the Website’s online store (e-shop) without creating an account and/or when you make purchases at the Company’s physical store shall be retained for as long as necessary for the performance of our obligations arising from the relevant sales contract or for compliance with our legal obligations;
Personal Data collected when you participate in an online auction conducted through the Website or in an in-person auction shall be retained for a period of one (1) year from your participation, unless you are declared the successful bidder, in which case such data shall be retained for a longer period, namely for as long as necessary for the performance of our contractual obligations or for compliance with our legal obligations;
Personal Data collected when you contact us by sending an email to info@frattisauctions.gr or eshop@frattisauctions.gr shall be retained for as long as necessary to complete our communication with you. Where such communication results in the conclusion of a contract between you and the Company, the relevant Personal Data shall be retained for as long as necessary for the performance of our contractual obligations or for compliance with our legal obligations. Personal Data collected when you subscribe to the Company’s newsletter shall be retained until you unsubscribe from the newsletter;
Personal Data collected through CCTV systems shall be retained for a period of up to fifteen (15) days. In the event of an incident affecting persons or property of the Company, recordings relating to such incident shall be retained in a separate file for thirty (30) days. Where the incident concerns a third party, such recordings shall be retained for three (3) months; and
Personal Data collected for the creation and development of customer profiles shall be retained for as long as you remain a customer of the Company, including where you maintain an account on the Website, and for up to two (2) years following your last transaction, as well as until you object to Profiling and/or request deletion of your profile. Following the expiry of the above period, or where you exercise your rights to object or request deletion, we shall delete the relevant Personal Data and cease maintaining your profile.

In any event, where your Personal Data are related to any ongoing legal proceedings and are required for the establishment, exercise or defence of our legal rights (including, without limitation, providing information to third parties for the purposes of fraud prevention and reducing credit risk), we shall retain such Personal Data for as long as necessary to support and protect the Company’s rights.

Your Rights

As a Data Subject, you have the right to exercise your rights at any time, as provided for under applicable data protection legislation. In particular, you have the right to request:

access to the Personal Data concerning you that we retain. You may request a copy of your Personal Data, which we will provide to you free of charge;
the rectification of any inaccurate Personal Data concerning you and, taking into account the purposes of the Processing, the completion of any incomplete Personal Data. In any event, when you provide us with your Personal Data, you declare and warrant that such information is true and accurate and you are responsible for informing us of any changes or amendments, which we will promptly update;
the erasure of your Personal Data, where such data are no longer necessary for the purposes for which they were collected and Processed, as described above, or where they are no longer required for our compliance with legal obligations or where we are otherwise no longer legally permitted to Process them;
the restriction of the Processing of your Personal Data;
to object to the Processing of your Personal Data;
the portability of your Personal Data;
to withdraw your Consent at any time, where Consent constitutes the legal basis for the Processing, without affecting the lawfulness of Processing carried out prior to such withdrawal. Please note that, in such case, we may continue to Process your Personal Data where another lawful basis for Processing exists; and
to lodge a complaint with the Hellenic Data Protection Authority (postal address: 1-3 Kifisias Avenue, Athens 115 23, Greece; telephone: +30 210 6475600; email: contact@dpa.gr), if you consider that the Processing of your Personal Data infringes the applicable national and regulatory framework on data protection.

Where you exercise any of the above rights, the Company shall take all reasonable measures to satisfy your request within one (1) month from its submission. Please note that, in order for the exercise of the above rights to be considered valid, we may require verification of your identity in order to ensure that the Personal Data in relation to which the requested action is sought actually relates to you. If, however, your request is complex or we receive a large number of requests, we will inform you within the above-mentioned one-month period if we need to extend the response period by an additional two (2) months, within which we will fulfil your request. In particular, where you exercise your right of access to Personal Data collected through CCTV systems, we will provide you, within fifteen (15) days from the submission of your request, with a copy of the relevant part of the video recording in which you appear or with a printed sequence of still images from the recorded footage. Alternatively, within the same period, we will inform you in writing either that you do not appear in the recordings or that the relevant part of the recording has been deleted.

To exercise your rights (including rights relating to Profiling), you may contact the Company at: info@frattisauctions.gr. Please note that the Company may refuse, in whole or in part, to satisfy your request for restriction of Processing or erasure of your Personal Data where the Processing or retention of such Personal Data is necessary for the establishment, exercise or defence of the Company’s legal rights or for compliance with its legal obligations.

If your request is manifestly unfounded or excessive, in particular due to its repetitive nature, the Company may charge a reasonable fee, taking into account the administrative costs involved in providing the information or carrying out the requested action, or may refuse to act on the request.

Security of Your Personal Data

We implement appropriate technical and organisational measures to prevent any breach of the security of your Personal Data and review and update such measures whenever deemed necessary.

All Personal Data you provide to us will be stored on secure servers protected by passwords and firewalls.

You acknowledge that the transmission of information over the internet is inherently insecure and that we cannot guarantee the security of data transmitted over the internet.

You are responsible for keeping confidential any password you use. We will not ask you for your password (except when you log in to the Website).

Amendments

We may update this Privacy Policy from time to time by publishing a new version on the Website. We recommend that you check the Website periodically to ensure that you are aware of any changes to this Privacy Policy.

We may notify you of changes to this Privacy Policy by email.

The latest update of this Privacy Policy is dated 04/08/2026.

Third-Party Websites

The Website may contain hyperlinks to, and information from, third-party websites. We cannot control and are not responsible for the privacy policies and practices of third parties. We recommend that you carefully review the privacy policies of such third-party websites.