PRIVACY POLICY

Last Updated: May 2019

Wifins, a Greek Company registered in Rafina, Attika (1 Fleming Str.), represents the sole administrator of the Wifins platform (hereinafter “the Service”) and is deemed as a Data Processor in relation to the use of the Service to Wifins Wi-Fi spots and as a Data Controller with respect to the processing of personal data for own purposes. Any information which could directly or indirectly identify you falls under the definition of personal data. Protecting your privacy is very important to us, thus we have taken all appropriate measures in order to safeguard the security and confidentiality οf users' personal data.

The terms of the present Privacy Policy refer to the use of the Service, as described in the Terms of Use. The present Policy does not apply to websites of third parties, in case the Service displays links thereto, and Wifins bares no responsibility of their privacy practices and website content whatsoever. The use of the Service declares full acceptance, consent and agreement to the Terms of Use by the Users

The present Policy is deemed as a notification of the data subjects under the articles 13-14 of the General Data Protection Regulation (EU) 679/2016 and its acceptance entails your consent to the collection and processing of your personal data as described herein. We kindly ask you to read the present policy carefully, so as to be properly informed of how we collect, process and protect your personal data, as well as of your data privacy rights throughout your use of the Service. Please note that you may freely withdraw your consent to the processing of your personal data by Wifins, by contacting our Data Protection Officer at dpo@wifins.com. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

PERSONAL DATA COLLECTED THOUGH THE USE OF THE SERVICE

1. Information you directly provide to us

1.1. Personal data of anonymous users of the Service

For the anonymous use of the Service, personal data may be collected by Wifins such as:

  • Location data
  • The duration of the use of the Service in a Wifins Wi-Fi spot.
1.2. Personal data of identified Users of the Service

If the Wifins Wi-Fi spot requires the identified use of the Service, Wifins may collect and process the following personal data:

  • Ε-mail
  • Public data of the User's Facebook profile (name, email, age group, sex), upon consent of the user
  • Location data
  • The duration of the use of the Service in a Wifins Wi-Fi spot.

2. Personal data collected automatically through the use of the Service:

Wifins may automatically collect the following data of Users, throughout the use of the service:

  • The User's IP address
  • The device's mac address
  • The domain name server
  • The type of the device accessing the Service (P/C, mobile device)
  • The type of the web browser used to access the Service
  • The operating system of the device
  • The web browser's language
  • The source or URL which directed the User to the Service

This data help us understand the functionality of our Service, correct technical problems and generally improve our Service

3. Minors

When you directly provide information to us, we make all reasonable efforts to clarify which information refers to minors. In any case, if it comes to our knowledge, that the collection of personal data of minors below the age of 16 years takes place without verifiable parental consent, pursuant to the provisions of article 8 of the General Data Protection Regulation (EU) 679/2016, we will delete said data without undue delay. Should you believe we have collected personal data of minors below the age of 16, please contact our Data Protection Officer at: dpo@wifins.com.

HOW WE USE PERSONAL DATA WE COLLECT

Wifins uses personal data collected by users of the Service for the following purposes:

  • For the provision of free and interactive W-fi Internet access to the Users of the Wifins service.
  • For the performance of marketing and advertising campaigns when users access the Service in a Wifins Wi-Fi spot (general advertising content).
  • For the provision of personalized advertising content to Users upon their explicit consent, either when connecting to a Wifins Wi-Fi spot, or when using the same device to access the Web elsewhere.
  • For the execution of our contractual obligations as Data Processors towards our clients.

CONSENT

Notwithstanding legal provisions of consent for unsolicited communications, the use of our Service entails the provision of your consent to the processing of your personal data as described herein above, including consent to receiving general advertising content when connecting to a Wifins Wi-Fi spot. You may freely withdraw all consents provided to Wifins Wi-Fi spots by visiting the hyperlink my settings, while connected to a Wifins Wi-Fi spot. You may also withdraw consents by contacting our Data Protection Officer at: dpo@wifins.com. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You must refrain from using the Service, should you wish the information automatically collected therefrom not to be collected and processed in any way.

EXCHANGE OF INFORMATION

Wifins respects your right to privacy and uses your personal data solely for the purposes described herein above. We may only make information accessible to other companies, applications or persons under the following circumstances:

  • We may disclose aggregated information which do not directly identify you to third parties, in order to be able to develop the content and quality of our Service. Please note that we do not in any way disclose your contact details to third parties.
  • We may use third parties (currently or in the future), for the provision of services in relation to our Service, such as technical support thereof, collection of analytical data, marketing activities, mass mailing of newsletters etc. Those third parties will only access the information absolutely necessary for the execution of their duties and only under explicit contractual terms for the protection of your privacy and your personal data.
  • We may disclose information about you in case Wifins is acquired or merged or within the framework of a similar business transaction. This being the case, Wifins will inform you by placing a banner on the Service's splash-page or via email, prior to the transfer of your personal data and their submission under the terms of a different Privacy Policy.
  • We may disclose personal data in order to investigate, prevent or act in relation to an illegal activity against the rights and legal interests of any natural person or legal entity, in breach of the Terms of Use of our Service or if required by law, as well as in any case deemed necessary under the principle of good faith.
  • We may disclose personal data to abide by Court orders, research warrants, judicial procedures and other orders of the competent Regulatory Authorities, including the Greek Data Protection Authority, other Supervisory Authorities of EU Member States, as well as in order to defend our lawful interests from claims raised against us.
  • Kindly be informed that third parties might independently collect personal data about you, including your IP address and information about Websites and links you visit, through the use of cookies, as described in the Section ”Cookies” of this Policy.

RETENTION PERIOD

Wifins will retain the personal data collected for the time absolutely necessary to serve the purposes of processing and to comply with its legal obligations and defend its lawful interests before the Courts.

Personal data of Users will be retained for a maximum period of twelve (12) months from the provision of (each) consent, unless the User recalls consent prior to the expiration of above 12-month period.

TRANSFER OF PERSONAL DATA

Wifins does not sell personal data of users and does not disclose it to third parties, unless such disclosure is necessary for the fulfillment of the processing purposes and upon implementing all necessary contractual and security measures, in order to safeguard the security and confidentiality of personal data processed by third parties. Wifins does not transfer personal data outside the EEA.

INFORMATION SECURITY

Wifins is committed to safeguard the security of your personal data from accidental or non- accidental destruction, loss, unauthorized amendment, disclosure or access and any other unlawful action, by implementing all necessary technical and organizational measures. Nevertheless, despite all of our efforts to retain personal data of users in a safe and private IT environment, please note that Wifins cannot fully guarantee than no accidental disclosure of personal data will occur. Users are kindly requested to inform our Data Protection Officer at dpo@wifins.com, in case loss, theft or unauthorized use of personal data occurs.

DATA SUBJECT RIGHTS

You may exercise the following data subject rights:

  • Right of access, so as to be informed of the personal data we process, the purpose of processing and the recipient of data.
  • Right to rectification, for the correction of any inaccurate information about you.
  • Right to erasure (right to be forgotten), so as to ensure the erasure of your personal data from our files, so long as its processing is no longer necessary or obligatory for the compliance with a legal obligation of Wifins or the defense of a lawful interest before the Court.
  • Right to restriction of processing, in case the accuracy of your personal data is disputed.
  • Right to data portability, so as to receive your personal data in a structured, commonly used and machine-readable format.
  • Right to object, if you no longer wish your personal data to be processed for direct marketing purposes, including objection to profiling.

To exercise those rights, please contact our Data Protection Officer at: dpo@wifins.com.

Wifins will make all reasonable efforts to address your request within a period of one month from receipt of the request. However, if it is impossible to meet this deadline due to the complexity of your request or the number of simultaneous requests, Wifins will timely inform you within same deadline for the reasons of the delay and will make all reasonable efforts to address your request without undue delay and, in any case, within a period of two more months.

Wifins reserves the right not to satisfy your request, if manifestly unfounded or excessive, and will notify you accordingly.

Nevertheless, you have the right to file a complaint before the Data Protection Authority (http://www.dpa.gr).

COOKIES

Why we use cookies?

Cookies, pixel tags and similar technologies (collectively 'cookies') are files containing small amounts of information which are downloaded to any internet enabled device – such as your computer, smartphone or tablet – when you visit a website.

Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies perform lots of different and useful operations, such as remembering your historical preferences, generally improving your online experience, and helping us to offer you the best quality of our Service.

What purpose do we use cookies for?

We use cookies to collect valuable information with respect to your use of our Service, such as information related to your preferences. Cookies help us make our Service easier to use, deliver a personalized experience and better tailor our Service to your interests and needs. Cookies are used to help speed up your future activities and your experience when you use our Service.

We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our Service and to help us improve their structure and content and also help us measure the effectiveness of advertising campaigns.

What cookies do we use?

Some or all cookies described herein below may be stored in your web browser and may be visible and accessible to you (although that feature may be not available to certain mobile devices).The cookies used for the provision of our Service may be generally categorized as follows:

1. Necessary Cookies

These cookies do not identify you as an individual. These cookies are essential to make our Service work correctly, they enable you to move around the Web and make proper use our Service's features. Moreover, necessary cookies enable our Service remember your preferences, so as to provide improved and personalized features.

Without the use of necessary cookies, we will be unable to offer a quality and effective Service to users.

2. Performance Cookies

Google analytics: These cookies do not identify you as an individual. These cookies collect information about how you use our Service and which pages you go to most often. These cookies are used for the improvement of the use of our Service.

How can I control or delete cookies?

Most internet browsers are initially set up to automatically accept cookies. If you do not want our Service to store cookies on your device, you can change your browser settings so that you receive a warning before certain cookies are stored. You can also adjust your settings so that your browser refuses most of our cookies or only certain cookies from third parties. You can also withdraw your consent to cookies by deleting the cookies that have already been stored. The procedures for changing your settings and cookies differ from browser to browser. If necessary, use the help function on your browser.

If you disable the cookies that we use, this may impact your experience while using our Service or you may not receive personalized information when you visit a website. To find out more about cookies, visit http://www.allaboutcookies.org. Should you wish to see what cookies have been set and how to manage and delete them, visit http://www.AboutCookies.org.

CHANGES OF THE PRESENT POLICY

Wifins reserves the right to freely modify the present Policy, in accordance with the provisions of data privacy laws anytime in force. The Users of our Service must frequently read the present Policy, so as to be informed of any change, whereas Wifins shall provide all necessary notices to its users, in order to comply with the provisions of the General Data Protection Regulation (EU) 679/2016.