PRIVACY POLICY

The protection of your data is a serious matter for us.

We encourage our customers to read our privacy policy carefully. This privacy policy sets out how we collect, use, process and protect the data you provide to us. It also informs you of your rights in relation to the data we hold about you and how to contact us if you have any questions or comments.

1. Scope of Application

1.1 We are the swimming team, the limited liability company with the name "NIKOLAOS HATZIGIAKOUMIS & CO. E.E." and the distinctive title "ICHTHEIS AQUA CLUB", based in Thessaloniki, Miaouli 18, P.C. 55132, email: info@ixthys.gr, tel: +30 2313 054671, website: http://www.ixthys.gr/, and for the purposes of carrying out our activities, we process our customers' data in accordance with applicable national legislation and European Regulation 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) as applicable.    

1.2 For any issue regarding the processing of personal data, please contact our Data Protection Officer directly, at Tsilonis-Vogiatzoglou Law Firm with the distinctive title Newlaw, Tsimiski 10, 546 24 Thessaloniki, tel. 2310 551 501, fax: 2310 261 503, e-mail: dataprotect(at)newlaw(dot)gr.

1.3 This privacy policy applies to our customer data that we collect through our website (http://www.ixthys.gr/), by telephone, mail, email or other means of communicating with us.

Our privacy policy may change from time to time and, if this happens, the updated version will always be available on our website. We are also committed to notifying you of any significant changes to our privacy policy.

2. The information we collect

2.1. We collect your data when you fill out forms or forms on our Website or when you communicate with us by phone, email or otherwise. The data we collect includes information you provide to us when you register with us, when you place orders for course goods or services, when you take courses, when you voluntarily participate in customer surveys or when you enter competitions.

Our swimming pool collects and processes (receives, maintains and uses) the following categories of personal data.

1. For infant and child swimming lessons

Data of minor users of our services that we collect and process:

a) Full name, patronymic, maiden name, date of birth.

b) Health data related to the safety of minors when they receive our services, and any other information provided for by applicable legislation.

c) Photos and/or videos from lessons, as well as from seminars, programs, events, provided that the parent/guardian has given their consent on the relevant consent form.

Data of parents/guardians who accompany minors in the use of our services, which we collect and process:

a) Name, home address, mobile phone number, email address.

b) Health data and any other information provided for by applicable legislation.

c) Information required for the issuance of legal tax documents (Tax Identification Number, Tax Office, profession).  

1. For adult lessons (pregnant swimming, adult lessons)

Data of adult users of our services that we collect and process:

a) Name, home address, mobile phone number, email address.

b) Health data and any other information provided for by applicable legislation.

c) Information required for the issuance of legal tax documents (Tax Identification Number, Tax Office, profession).  

2.2. We collect information regarding the gender, biometric or medical data of our minor and adult users, in order to provide our services safely and effectively.

In particular, regarding the health data of our customers, adults or minors, the processing is carried out for the purpose of your safety when using our services and only with the express written consent of them or their parents/guardians in accordance with articles 9 par. 2 and 8 par. 1 of the GDPR.

We assure you that no automated decision-making or profiling will take place when using your data.

2.3. The information we collect through the website

2.3.1 You do not need to register to browse our website.

2.3.2 We process the data you provide to us when using our website, either by subscribing to the Company's Newsletter, or by completing the Contact Form, or by submitting a participation application to a seminar or the Swimming Academy, either through the use of microdata files (cookies) or in any other way. Similarly, we process the information you provide to us through third-party websites and social media for the purposes of advertising and promoting its services.  

2.3.3 This information is indicative: your name, email address, telephone number, IP address, as well as any other personal data resulting from completing the above forms.

2.3.4 If you wish, you can subscribe to our newsletter by providing us with your email address, first name, last name and telephone number. By subscribing to our newsletter, you accept our communication with you for promotional and advertising purposes. We undertake not to forward this address to third parties.

2.3.5 You have the option to unsubscribe from our Company newsletter at any time by notifying us. After this notification, your email address will be deleted from all our records within 5 business days.

3. Purpose and lawful basis of processing

3.1 We process the data we collect from you for the uses set out below:

a) To fulfill the obligations arising from the contract between us and to provide you with the information, products and services you request from us.

b) To answer your questions.

c) To inform you of important changes or developments to our Website or services.

d) To provide and personalize our services in general.

e) To measure or understand the success of our products and services and to improve the services we provide to you.

f) To contact you and inform you about other products and services we offer that we feel may be of interest to you.

g) To ensure that the content of our website is presented in the most effective way for you and your computer, making the Website easier for you and providing you with access to all parts of the Website.

or) For the issuance of the required tax documents.

i) For the purpose of civil liability insurance in the event of an accident of minors and adult users during swimming activities and during their stay in our infrastructure. For the preparation of the insurance contract based on the terms of the insurance company, we transmit the number of insured users per section. The data of minors and adult users of our services are transmitted only in the event of an insurance risk.

3.2  Legal basis for the above processing of our customers' data are:

a) The execution of the contract between us.

b) Compliance with applicable legislation, such as tax legislation, which requires the collection of your information and VAT number for the issuance of a legal document and their retention for a specific period of time and their transmission to the AADE.

c) Your explicit consent for specific purposes.  

d) The legitimate interest of our business.

3.3 We undertake not to use your data for purposes other than those mentioned herein, without your prior information and, where required, consent.

4. Who has access to your data?

The processing of your data is limited within PISCES. In particular, your personal data is available exclusively to our teaching and administrative staff, who are bound by an obligation of confidentiality.

5. Who is your data shared with?

Under certain conditions, your data may be shared with third parties. Recipients of the data may be:

a) Public authorities (Tax Authority, Independent Public Revenue Authority, Health Authorities, etc.).

(b) Judicial and prosecutorial authorities in the event of claims or criminal acts.

c) Other swimming pools (public or private) in case of your transfer (e.g. athlete's card).

d) Bodies with which the swimming pool collaborates on a case-by-case basis in the context of educational, sporting, cultural and other activities (participation in competitions organised by third parties).

e) External collaborators of the swimming pool on occasion, such as photographers, printers and editors of commemorative publications, medical personnel, lawyers, accountants, collaborating swimming schools and instructors in the context of seminars, etc., who are bound by an obligation of confidentiality, and only to the extent required for the execution of the specific tasks/instructions that each has within the context of the aforementioned processing purposes.

f) External partners who undertake tasks on our behalf such as data analysis, technical support, marketing assistance (including conducting market research). The aforementioned external partners are bound by an obligation of confidentiality and gain access to those customer data that are required to perform their duties and are not allowed to use them for other purposes.

g) Analysts and search engine providers who help us improve and optimize our website.

or) The insurance company of the swimming pool's civil liability policy.

6. Storage period

6.1 We take all necessary technical and organizational measures to safeguard and securely store your data in accordance with the definitions of the GDPR, while we commit to promptly informing you of any breach.

6.2 Your personal data is retained for the entire period of time that you remain an active member of ICHTHYES, that is, for the period during which you register, participate in ICHTHYES programs, renew your membership and remain a financially active member. After the end of your cooperation with ICHTHYES and your final departure from the swimming pool, your personal data is retained for a period of two years. After that, your data is automatically deleted unless:

a) State explicitly and in writing that you wish to re-register yourself/your child at the swimming pool.

b) It is mandatory to retain all or some of them for a longer period than the applicable legislation (e.g. tax data) and, in the event of claims, for as long as is required for their irrevocable resolution.

c) You expressly state in writing that you wish to retain your contact details solely for the purpose of informing and communicating with you about the swimming pool's activities (e.g. events). In this case, you have the right to exercise the right of objection, which is mentioned below in the next field, at any time you wish.

d) Audiovisual material (photos/videos) of you or your child will be retained for historical reasons, i.e. for the historical preservation of the activities, programs, events, etc. of the swimming pool, unless you revoke your consent, in which case they will be deleted or modified immediately so that your child's face and/or voice is not seen/heard. The same applies to photos/videos on the swimming pool website and social media.

6.3. Your health data is retained for a period of one year and then automatically deleted.  

7. What are your rights in relation to your personal data?

7.1 Every natural person whose data is processed by ICHTHYS enjoys the following rights:

a) Right of access

You have the right to be aware of and verify the lawfulness of the processing. Therefore, you have the right to access your data, to be informed whether personal data concerning you and your child are being processed, to receive copies of this data, as well as any other information regarding the processing carried out.  

b) Right to rectification

You have the right to review, correct, update or modify your personal data by contacting the Data Protection Officer (DPO) at the contact details above.

c) Right to portability

You have the right to receive your personal data in a format that allows you to access, use and process them using commonly used processing methods. You also have the right to ask us, if technically feasible, to transmit the data directly to another controller (e.g. another swimming pool). This right applies to data that you have provided to us and that is processed by automated means based on your consent or in execution of a relevant contract.

d) Right to erasure

You have the right to request the erasure of your personal data when we process it based on your consent or in order to protect our legitimate interests. In all other cases (such as, for example, when there is a contract, an obligation to process personal data imposed by law, public interest), this right is subject to specific restrictions or does not exist depending on the case (such as with tax information).

e) Right to restriction of processing

You have the right to request the restriction of the processing of your personal data in the following cases: (a) when the accuracy of the personal data is contested and until verification is carried out, (b) when you oppose the deletion of personal data and request the restriction of their use instead of deletion, (c) when the personal data are not needed for the purposes of the processing, but are nevertheless necessary for you to establish, exercise, or support legal claims, and (d) when you object to the processing and until verification is made that there are legitimate reasons that concern us and override the reasons for which you object to the processing.

f) Right to object

You can exercise your right to object in the following cases:

(i) To send updates via email, e-mail. In this case, we will stop sending updates as soon as possible after exercising your right.

(ii) In the transfer of data to cooperating insurance companies that provide us with civil liability insurance. In this case, if you exercise the right to object, we will weigh whether the reasons you invoke and relating to your particular situation outweigh the interests of our swimming pool for the transfer, which are mainly based on our obligation to meet the duty of care we have for the duration you or your minor children are on our premises, as well as whether there are alternatives for better protection of the data concerning you and your children.

The exercise of the right to object is made by expressly invoking reasons relating to your particular situation. After you exercise the right to object, we will stop processing the data concerning you unless one of the following conditions is met:

(i) the processing takes place for the establishment, exercise or defence of legal claims,

(ii) the processing takes place for compelling and legitimate reasons which override your interests, rights and freedoms,

(iii) the processing takes place for historical or statistical research purposes and is necessary for the performance of a task carried out for reasons of public interest.

In any case, we will inform you as soon as possible of the reasons that led to the rejection of your request.

g) Right to withdraw consent

Where processing is based on your consent, you have the right to freely withdraw it, without affecting the lawfulness of processing that was based on your consent before you withdrew it.

h) Right to complain to the APDPH

You have the right to submit a complaint to the Personal Data Protection Authority (www.dpa.gr): Call Center: +30 210 6475600, Fax: +30 210 6475628, Email: contact(at)dpa(dot)gr

8. PISCES contact details

To exercise your above rights as well as for any communication regarding personal data, please contact us at tel. 2313054671, 6955066413, 6989665757, 6980390316 or email: info@ixthys.gr or directly with the Data Protection Officer of FISH, Tsilonis-Vogiatzoglou Law Firm with the distinctive title Newlaw, Tsimiski 10, 546 24 Thessaloniki, tel. 2310 551 501, fax: 2310 261 503, e-mail: dataprotect(at)newlaw(dot)gr.