1. Introduction
This Privacy Policy applies to the website of ADTHISWAY P.C. (Company No. 180776630000) of 10 Dagkli Street, Kavala, P.C. 65403, Greece, (“ADTHISWAY”, “we”, “us”) and to services provided through it. ADTHISWAY is the creator and owner of all rights of this website (“Website”) with the domain name: www.adthisway.com
ADTHISWAY values the protection of personal data. Therefore, we prepared this Privacy Policy to inform the users of our Website about the way we collect, use, share, and protect the personal information we collect about individuals (“you”, “yours”) when you use the Website and the services we provide.
The Website operates under specific terms and conditions, which in principle are posted here. In addition, the Website may include links to other websites, which are under the responsibility of third parties.
Please review this Privacy Policy before using our services or providing us any personal information. If you have any questions, feel free to contact us. By using the services or submitting personal information to us, you consent to the practices outlined in this Privacy Policy. If you do not agree with this Privacy Policy, please refrain from accessing the services or providing personal information to us.
2. Definitions
(note: The definitions abide with art. 4 of the GDPR)
Personal Data: any information relating to an identified or identifiable natural person (‘data subject’)
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; in this case, the Company
Processor: the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
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.
Recipient: the natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a
third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with
Union or Member State law shall not be regarded as recipients.
3. Which personal data we collect, why and on which legal basis
When you visit the Website and as long as you create an account, use the services provided and/or communicate with us, your personal data are
collected.
The purposes of the processing carried out in the context of the operation of the website, the data processed, and the respective legal bases
are described below:
Α. Depending on the nature of each user (please advise our Terms and Conditions regarding the different types of services’ users),
we process the following personal data:
a. Full name,
b. E-mail address,
c. Adress,
d. Date of birth,
e. Phone number (fixed and/or mobile),
f. Tax Identification Number,
g. Social media profiles,
h. Any personal data filled in in the user’s bio/achievements section or other forms of the Website,
i. Photograph or other depiction of an individual, used as an account avatar,
j. Correspondence record, in case you contact us.
Β. We collect and process your above personal data to
a) enable you to use our services,
b) be able to provide services to registered users,
c) comply with our legal obligations when providing our services,
d) provide information and updates on potential opportunities to users who choose to do so.
The legal basis for the processing is in principle
a) taking measures at your request prior to entering into a contract and the performance of a contract (Art. 6 par. 1(b) GDPR),
b) the compliance with a legal obligation to which the controller is subject (Art.6 para.1(c) GDPR),
c) the legitimate interests of ADTHISWAY (Art. 6 para. 1(f) GDPR) and
d) the data subject’s consent (Art.6 para.1(a) GDPR) – the present legal base is applied for subscribing to ADTHISWAY newsletter, you can revoke your consent and opt-out at any time by clicking the Unsubscribe link at the bottom of the Newsletter email).
4. How long we keep your personal data
The personal data collected are kept for as long as your account is active. If your account is inactive for a period longer than five (5) years, then we delete
it, along with any personal data collected. Please advise our Terms and Conditions regarding the notions of active/inactive account. If you
choose to delete your account, any personal data collected are by default erased immediately.
However, in some cases we may be required to retain certain data for a specified period of time due to legal obligations, such as for accounting and
tax purposes.
We are committed to compliance with all applicable data protection laws and regulations, including the GDPR and national laws. This may require us to
retain certain data for a specified period of time, even if you have deleted your account.
5. Security of your personal data
Your personal data are processed by our appointed competent executives, who are committed to confidentiality.
We implement appropriate measures to ensure the security of all personal data, including safeguards to prevent accidental loss, unauthorized use, or
unauthorized access, throughout the duration of your use of our services. Additionally, we have procedures to address any suspected data security
breaches. If a breach is suspected, we will notify you and any relevant authority as required by law.
6. Sharing of your personal data
We don’t share, sell, rent, trade or transmit personal data to third parties. However, we may disclose personal data to our service providers, and more
specifically the providers of hosting services, of payment services and of statistical services, in order to facilitate or ameliorate the provision of our
services. These providers (Processors) have contractually provided guarantees for the protection of your personal data.
Regarding hosting, our Website and any data are physically stored on servers in France (please visit Hostinger’s legal notes for further details). No transfers outside the European Economic Area (EEA) take place. The billing process for ADTHISWAY is securely managed by Stripe, a third-
party payment provider. When you use our services under a paid plan, your billing information will be processed by Stripe. Please refer to Stripe’s Privacy Policy for more information.
Our Website uses Google Analytics, therefore certain personal data are processed by Google, and may be transferred outside EEA by Google. Please
visit Google’s Privacy Policy for more information.
ADTHISWAY uses Mailchimp to manage our Newsletter service. Please consult Mailchimp’s Privacy Policy for further information.
Finally, we may disclose personal data in case we are obligated to do so to comply with legal requirements or to enforce our Website Terms and Conditions and other agreements. However, we will strive to limit such disclosures to only what is reasonably necessary and, whenever possible, to notify you of such disclosures.
7. What are your rights
ADTHISWAY, as a Data Controller, satisfies and facilitates the exercise of Data Subjects’ rights, as set forth below. We ensure that Data Subjects can easily exercise their rights, and that all required actions can be initiated immediately. We shall respond to a request submitted by Data Subjects without undue delay and in any case not later than thirty (30) calendar days. If we cannot satisfy a right exercised by a Data Subject, we shall ensure that a specific, adequate and complete explanation is provided. Except in cases of manifestly unfounded or excessive requests, all actions concerning the fulfillment of the rights of Data Subjects will be carried out free of charge for them.
Right of access
Data Subjects have the right to receive, at any time, information from us as to whether we process their personal data and, if so, they may request to be
informed of the purpose of the processing, the type of data processed, the recipients of the data, the period of storage, the existence of a right to request
the rectification or erasure of personal data or restriction of processing or a right to object, the right to submit a complaint to a supervisory authority, if
automated individual decision making takes place. In addition, Data Subjects shall be provided with a copy of the personal data without undue delay.
Right to rectification
Data Subjects have the right to request from us the rectification of inaccurate or outdated personal data concerning you. They also have the right to request
the completion of incomplete personal data, including by means of a supplementary declaration. Furthermore, we undertake to communicate any
rectification of personal data to each recipient to whom the personal data were disclosed, unless this proves to be impracticable or involves a
disproportionate effort. We undertake to inform Data Subjects about such recipients upon request.
Right to erasure
Data Subjects have the right to request from us and under the conditions of Art. 18 GDPR and Article 34 of Law 4624/2019 to delete personal data
concerning them.
Right to restriction of processing
Data Subjects are entitled to request from us to restrict the processing of personal data concerning them. If the processing of personal data is
restricted, the said personal data, except for storage, shall be processed only if specific exceptions apply.
Right to data portability
Data Subjects have the right, under the conditions of Article 20 GDPR, to receive the personal data concerning them which they provided us in a
structured, commonly used and machine-readable format.
Right to object
Data Subjects shall have the right to object at any time and on grounds relating to their particular situation to the processing of personal data
concerning them, subject to the conditions set out in Article 21 GDPR. If Data Subjects object to the processing of personal data concerning them, we will
no longer process the data in question, unless it proves that there are compelling legitimate grounds for the processing, which override the interests
and rights of the Data Subject or for establishing, exercising or supporting legal claims.
Right to object to decisions based solely on automated processing, including profiling
We do not engage in automated individual decision-making. However, in any case and if in the future we proceed to automated individual decision-making,
Data Subjects shall have the right to object to a decision taken solely on the basis of automated processing, including profiling, where that decision
produces legal effects concerning him or her or significantly affects them.
In order to exercise the above rights, Data Subjects may submit a written request to ADTHISWAY here.
If Data Subjects consider that the processing of their personal data violates the applicable regulatory framework for the protection of personal data, they have the right to file a complaint with the Personal Data Protection Authority (postal address Kifissias 1-3, P.C. 115 23, Athens, tel. 210. 6475600, e-mail address contact@dpa.gr).
8. Aggregate Data
We may use anonymized and/or aggregate data, which do not constitute personal data, collected through your use of the services and the Website for statistical purposes, for improvement of the Services, to conduct research, or any other lawful purpose.
9. Modification of this Policy
We reserve the right, when deemed appropriate, in our sole discretion, to modify or update this Privacy Policy from time to time, either in whole or in part. Any modification to this Policy, will be effective immediately upon posting on the Website. Please consult this Policy regularly to ensure that you are aware of the most recent version.