• Introduction: Data obtained through the use of microdata (cookies)

1.1 The Website uses small files called cookies which are used by the company “NIKOLAOS HATZIGIAKOUMIS & CO. EE” with the distinctive title “ICHTHEIS AQUA CLUB” (hereinafter, the Company) to customize the User’s experience. Microdata are small text files that contain information, such as the type of server used by each User, the type of computer, its operating system, the Internet service providers, as well as other such information. When the User visits the Website, the microdata are sent by its management software and stored on the computer’s hard drive or in the storage space of each User’s mobile device.

1.2 Microdata does not harm the User's computer or mobile device, nor the files stored on them, and does not take knowledge of any document or file from the User's computer. Microdata cannot reveal the User's identity, but may be used to identify their computer.

1.3 The use of microdata is technically necessary for the complete implementation of the User's connection to the Website. For this reason, before browsing the Website, the User is asked to accept the storage of microdata files on his computer, during Article 5(3) of Directive 2002/58/EC, as transposed into Greek law, as well as in accordance with article 6 of the General Data Protection Regulation 679/2016 which determines that data collection is possible for a legitimate reason.

1.4 Most web browsers automatically accept microdata. However, the User can configure the web browser he uses in such a way that microdata are not stored on his terminal device or that a prompt is constantly displayed before a new microdata is stored. It is noted that completely disabling microdata may result in the inability to use some functions of the Website. 

• Microdata Categories

2.1 Microdata is typically classified into session microdata (functionality microdata) and persistent microdata. The Website uses functionality microdata to provide the User with a more comfortable experience and to recognize which individual pages of the Website have been visited. These are automatically deleted once the User leaves the Website.

2.2 The Website also uses temporary microdata for ease of use, which are stored for a specified period of time on the User's terminal device. If the User revisits the Website to use the Company's services, the Company automatically recognizes that he has already visited the Website, what entries, settings and actions he has made, as well as which pages he has visited, so that he does not have to perform the same actions again. In addition, these microdata are used by the Company for the statistical analysis of the use of the Website in order to optimize its services, as well as to display information that is specifically tailored to the User.

2.3 The Website may use web beacons (also called clear GIFs, pixels or action tags, web bugs). These technologies are codes that provide a small graphic image on a website or in an email message. Web beacons can recognize certain types of information on the User's computer, such as microdata, the date and time a page was viewed, and a description of the page on which the web beacon is located. In general, any file that was part of a website can act as a web beacon. Web beacons are used for tracking and statistical purposes. Third parties may also use web beacons on the Website to obtain audit, research and reporting information or to understand the User's interests and tailor advertisements to them.

2.4 Some of the third-party partners of the Website may use Flash microdata, otherwise known as Locally Shared Objects (LSOs). Flash microdata are used to determine the interests of the User through the articles consulted and more generally to monitor the behaviors of Users. LSOs maintain collections of data such as microdata, stored in a directory on a User's computer, and are installed through Adobe's Flash Player video player.

2.5 Finally, the Website uses social networking microdata, such as the Facebook platform Pixel, through which the Company collects data regarding the behavior of users of this platform on the Website (time spent on the Website, individual pages visited by the User, etc.), while certain Users who visited it mainly on the said social networking medium may then be re-targeted. Similarly, the Company uses the Google Ads Search service microdata, in order to collect data regarding the behavior of Users of the Website, who visit it through the specific search engine (time spent on the Website, individual pages visited by the User, etc.).

• Purposes of Using Microdata

As mentioned above, the Company may, among other things, utilize microdata for various reasons, such as:

3.1 To conduct surveys for statistical purposes and/or to improve the content and services of the Website and/or to assess its effectiveness as well as to instantly record public opinion trends.

3.2 To collect data regarding the effectiveness of advertisements on the Website, how Users use it, as well as to display advertisements related to the website on other websites, based on the User's previous visits to it.

3.3 For the optimal technical ability to present and operate advertising messages, news and promotional actions regarding all types of services provided by the Company to natural and legal persons, businesses, bodies and organizations.

3.4 For the purposes of targeting and re-targeting Users coming from social media and search engines.

• Legal Basis of Processing

4.1 The Company uses microdata for the purpose of configuring and continuously optimizing the Website, for collecting information about the behavior of its Users as well as for the optimal advertising of its services. In addition, with the use of microdata, information is analyzed and evaluated for the purpose of optimizing the Website and the advertising displays displayed on it. In principle, by collecting microdata, the Company does not store or process personal data of the Users of its Website. In any case, if the processing of microdata is assumed to lead to the identification of a User, such processing is justified under Article 6(1)(f) of the GDPR.

4.2 The User can prevent the aforementioned technologies by setting the microdata in the web browser he uses. At the same time, he has the possibility to prevent personalized advertising based on interests with the help of the so-called Preference Manager or by activating the microdata opt-out options available. Finally, the User reserves the right to object to his identification through the processing of microdata, exercising the rights granted to him by the GDPR, as described in the Company's Privacy Policy.

• Specifically, Google Analytics Microdata

5.1 For the purpose of designing and continuously optimizing our websites, we use Google Analytics, a web analysis service of Google Inc. (“Google”) in accordance with Article 6(1)(f) GDPR. In this context, “pseudonymized” usage profiles are created and microdata (cookies) are used. The microdata records the following information about the use of this website:

• Internet browser type/version

• operating system used

• URL-type address reference (i.e. the previous page you visited)

• access computer name and Internet Protocol (IP) address

• transit server request time.

5.2 The information is used to evaluate the use of the Website, to compile reports on the activities and results of the Company's advertising campaigns, and for possible re-targeting of the User. Internet Protocol (IP) addresses are anonymized so that they cannot be matched by deleting one or more digits (so-called IP-masking). 

5.3 The User can prevent the analysis of the data generated by the microdata and relating to the use of the Website (including the Internet Protocol address) as well as the processing of said data by Google, by downloading and installing extension program for Google's Chrome web browserMore information about data protection in relation to Google Analytics can be found at Google Analytics website. 

5.4 The information generated by the microdata is transmitted to a Google server in the USA and stored there. Under no circumstances will the User's Internet Protocol (IP) address be merged with other data from Google. This information may also be transmitted to third parties if this is required by law or if third parties process this data on their behalf. 

5.5 After the "anonymization" of the IP address, it is no longer possible to connect it to the person of the User. The data created for statistical purposes is deleted from Google Analytics after 50 months. In the reports compiled based on Google Analytics, there is no longer any reference to persons.

• Specifically, Google Display Service Microdata

6.1 The Website also uses retargeting technologies, and in particular the microdata of the Google Display service. With these microdata, data of interest is collected using a pseudonym, i.e. information is collected about the browsing behavior of each User for marketing purposes in an anonymous form, which is stored in microdata files on their computer and analyzed through an algorithm. Subsequently, it is possible to display targeted service recommendations and personalized advertising banners with its services that are of interest to the User on the websites of the Company's partners. Thus, the Company ensures that only advertising that is tailored to their real or presumed interests will appear on each User's terminal device.

6.2 Under no circumstances can this data be used to identify the User. No processing of directly personal data takes place, and usage profiles are not merged with personal data. Even if it is assumed that the identification of the User is possible, this data processing is carried out on the basis of Article 6(1)(f) GDPR.

6.3 Users who do not wish to have the Company's personalized advertising banner displayed on their computers retain the right to object to this data collection and storage for the future, as follows:

6.3.1 By selecting the symbol displayed on each advertising banner (e.g. “i”), the User can go to the respective provider’s website. There, the systematics of the retargeting technology are clarified again and the option of opting out is provided. If the User unsubscribes from a provider, the so-called opt-out microdata is stored on his computer, which prevents the display of the respective provider’s advertising banner in the future. This opt-out can only be carried out from the User’s computer, while if the respective opt-out microdata are deleted, the User will inevitably have to repeat the opt-out process.

6.3.2 Alternatively, the User reserves the right to object to the processing of microdata, exercising the rights recognized by the GDPR, as described in the Company's Privacy Policy.

• Recipients outside the EU

7.1 With the exception of the processing described in paragraph 2.5 and 5 of this, the Company does not provide the User's data to recipients based outside the European Union or the European Economic Area. The processing referred to above leads to the transmission of data to the transit servers of the "tracking and targeting" technology providers authorized by the Company. Some transit servers are located in the USA (information on this can be obtained in the respective reports for the specific recipients). The transmission of data is carried out in accordance with the principles of the so-called Privacy Shield as well as based on the so-called Standard Contractual Clauses of the European Commission.