Privacy Policy

C.A. Papaellinas Emporiki Limited (HE 27397), operating under the brand name Alphamega (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our Terms and Conditions) applies if you use our online E-commerce platform through our website or our app (the Platform). This policy also applies if you contact us or we contact you for any of our services accessible through the Platform.

This policy:

• Sets out the different ways you interact with us and the types of personal data we collect.
• Explains the reasons why we use the data we collect.
• Explains when and why we will share personal data with third parties.
• Explains the rights and choices you have when it comes to your personal data.

Important Information and Who We Are

C.A. Papaellinas Emporiki Limited (HE 27397) is the controller and is responsible for your personal data (referred to as "Alphamega", "we", "us" or "our" in this policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, including any complaints or requests to exercise your legal rights, please contact the DPO using the details set out below.

DPO Contact details

• Email address: dpo@alphamega.com.cy
• Postal address: 2-4, Archbishop Makarios III Avenue, 1065, Nicosia, Cyprus
• Telephone number: +357 22 026123

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection (Commissioner), the Cyprus supervisory authority for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our policy under regular review.

It may change and if it does, the new policy will be posted on the Platform and where appropriate, we will take steps to call it to your attention.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Platform may contain links to other websites operated by other organisations. These websites and any services that may be accessible through these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data: first name, last name, username or similar identifier, the password you have chosen, your social family card details, your stick & win account details and any data provided to us when you speak with us on social media.
• Contact Data: postal and billing address, email address, phone number and any data provided to us when you speak with us on social media.
• Transaction Data: includes details about transactions performed such as information of a product bought, amount paid and where it was sent.
• Financial Data: your bank account and payment card details.
• Device Data: includes a unique device identifier, operating system and device used.
• Usage Data: includes details of your use of the website and app.
• User data: includes information about you as a user of our Platform, products and services.
• Interaction data: includes information on your online behaviour on our Platform and information about when you click on one of our adverts and in general how you interact with our products and services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. This means that you cannot be identified. 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.

We analyse the information collected about how people use our services. This is alongside feedback provided directly to us to troubleshoot and identify trends, usage, activity patterns, and to help us improve the quality of our services and provide you with targeted marketing. For example, we may analyse your shopping habits to determine how best to offer our products or products that are complementary to the products you have bought in the past.

We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.

For customers that have signed up or will sign up for the Social Family Card or Stick & Win Schemes, and choose to user them on our Platform, we will also use your data in the ways covered in the privacy policies applicable to those schemes.

How Is Your Personal Data Collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms through the Platform, or by corresponding with us (for example, by email or chat). It includes information you provide when you sign up or register to use the Platform, download or register the Platform, subscribe to any of our services, share data via the Platform’s social media functions, enter a competition, promotion or survey, and when you report a problem with the Platform. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you use our Platform we will automatically collect personal data including Device, and Usage Data. We collect this data using cookies and other similar technologies.

How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract, we are about to enter or have entered with 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.
• Where we need to comply with a legal or regulatory obligation.

See below for the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

Glossary of Lawful Basis for Processing

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Disclosures of Your Personal Data

We may also share your personal data with third parties for the purposes set out in the table Purposes for Which We Will Use Your Personal Data including:

• The following External Third Parties:
  • Payment card processors that process credit and debit card payments.
  • External companies that provide post, courier or other delivery services.
  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties we use to contact you or to send you information or news.
• Third parties we collaborate with from time to time, provided these third parties agree to comply with our privacy policy.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Public agencies, when we believe release is appropriate to comply with the law, to enforce our Terms & Conditions and other agreements, or to protect the rights, property, or safety of us, our employees or customers, our business partners, or others. In these instances, we provide them with only the information they need to perform their function.

International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data Security

All information you provide to us is stored on secure servers which belong to us and are based on our premises. The data of the servers are being operated by third parties we collaborate which provide solutions to us from time to time.

Your personal data may also be stored by other third parties, via cloud services or other technology, to support the business operations of the Platform.

Any transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform or the services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We require all data processors to whom we share your data to employ at least the same level of security that we use to protect your personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you, including in relation to a request by you for the data we hold on you (a subject access request).

Keeping your payment details safe

We are committed to ensuring the protection of your payment card details. Payments made via our Platform are processed and managed by specialist payment card companies which are not part of us. We only store and display the first six and last four digits of your payment card number, the card type and the card expiry date. The full payment card number is never stored on any of our systems and is only stored and processed by a payment card processing company approved by us.

We keep an encrypted authentication token to represent your card and this token is transmitted to the relevant payment card processing company during the order processing.

We use 3D Secure to provide additional fraud protection and to protect your payment card from unauthorised use. During the checkout process, you may be asked by 3D Secure to provide your Verified by Visa or Mastercard Secure Code password.

Data Retention

We retain your personal information for no longer than necessary in order to fulfil the purposes described above.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for at least seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the Platform for a period of 3 years then we will treat the account as expired and your personal data may be deleted.

Your Legal Rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us to stop sending you marketing communications.

You can exercise any of these rights at any time by contacting the DPO at the contact details stipulated above.