PERSONAL DATA PRIVACY POLICY
Last updated on 19/06/2018

 

Preamble

Within the frame of your visit and navigation to the website www.owiwi.co.uk and the use of its services provided, it is possible that you register individual information and details of your Personal Data. Owiwi is committed to protect and respect your Privacy and Personal Data. Owiwi only uses information that is being collected legally from you. Please note that the use of the Owiwi’s website (“Website”) by your side is subject to this Privacy Policy (“Policy”) as well as to the Terms of Use of our Website. Our Policy explains which information/data we collect, the purpose of data collection, how we use it and/or share it and how this information is stored. Please note that this Agreement applies only for information which is collected by this Website and not for information which is collected or obtained in other ways or means. Please read this Policy carefully to understand our views and practices regarding your personal information and how we will treat it. The present Privacy Policy is in full compliance with new General Data Protection Regulation (EU 2016/679) and updated e-Privacy Regulations.
Owiwi respects your privacy rights and personal data and recognizes the importance of protecting the information collected about you.

For the needs of the present Privacy Policy the term “this website” refers to «www.owiwi.co.uk», which is owned and run by the Company/Owiwi with details as referred down below, and herein referred as “we”, “our”, “us”, or “the company”. The term “our services” refers to our online services, and any of our other products and services offered from time to time. We will refer to you using the terms “user”, “visitor”, “you”, “your”, “yours” in this Privacy Policy.

This Privacy Policy explains:

  • What Personal Data do we collect from you and for what purpose.
  • What about “cookies”.
  • How this Data may be used.
  • Who we will share your Personal Data with.
  • Where we process and store your Personal Data.
  • How long we can keep your Personal Data.
  • Marketing opt-in and opt-out provisions.
  • How you can access your Personal Data and keep it up to date.
  • Safeguarding your Personal Data.
  • Why we link to other websites/social media.
  • How we can make changes to this Policy.
  • Where and how to ask questions, complaints or contact us about this Policy.

Age Disclaimer: In order to use Owiwi’s website and the services offered, you must provide explicit consent that you are over 16 years old. If you are under 16 years old you must either refrain from using our website or inform your parents or guardians about our Privacy Policy to obtain their consent to the Privacy Policy before registering, subscribing or placing an order with us. Those with parental authority should protect juveniles from accessing and using websites that appeal to adults and are the solely responsible for this. Under no condition should our website be used by minors of age less than 13 years old.

 

WHAT PERSONAL DATA DO WE COLLECT FROM YOU AND FOR WHAT PURPOSE

Owiwi might collect personal information about you when you create an Owiwi Account, use our online services, subscribe and receive newsletters, interact with us in any other way, such as via social media, comment on any blogs or articles featured in our services, enter competitions or special promotions, sign up for our special offers or other updates, participate in research panels or fill in surveys. You must provide separate and explicit consent, in order for us to be able to process your personal data for any of the above-mentioned actions by ticking the box indicated in our website.
Owiwi declares that our website is in line with Data Minimization Principle and thus we collect the minimum data possible so as to be able to provide the services.

  • By creating an Owiwi Account, it means that either yourself or a  Candidate, will play the Game. In that case, you are asked to provide us, either as an Individual, Candidate or Company/Business/Organization/Academic Institution, with certain types of personal data.
  • There are three (3) types of personal data that will be collected and processed while playing the Game:
    • Registration Data:
      • As an Individual or a Candidate you have to disclose certain personal information of yours, such as, including but not limited, your full name, date of birth, gender, e-mail address, educational level, employment status, job title, position level, job industry, name of the Company/ Business/Organization/ Academic Institution in which you are currently employed and your job location and/or being a part of.
      • As a Company’s/Business’s/Organization’s/Academic Institution’s representative you have to disclose certain personal information of yours, such as, including but not limited, your full name, date of birth, gender, e-mail address, educational level, employment status, job title, position level, job industry, name of the Company/Business/Organization/Academic Institution in which you are currently employed and your location. Additionally, Companies/ Businesses/Organizations/Academic Institutions have to disclose their full trade name, the size and the field of their business activity and their URL.
    • Customer Data: All data providing to us when you make your Game purchase, meaning all Buyer and Payment Details, such as the Invoice Billing Address and the Payment Method preferred (Credit or Debit Card).
    • Game Data: By the term “Game Data” is considered:
      • the player’s date of birth, gender, educational level, employment status, job title, position level, job industry and job location
      • the access method that the player has used in order to play the Game (including but not limited, device, OS, network type, approximate IP address) and
      • the player’s Game results, meaning the player’s answers to each question of the Game, the player’s overall score and in general all user interface interactions.
  • We may also collect information from you when you submit information to us, including but not limited, when you complete surveys via Owiwi’s platform or when you post comments or opinions on Owiwi’s or other websites on which we have a profile or presence.
  • We may additionally collect data about how you use the services provided such the time you access each service provided and duration you are on it, the site you come to a service from or go to after leaving a service, selections and choices you make and preferences that you set when using a service as well as any data you input while conducting any assessment on the services provided.
  • We may collect data about the computer or other electronic device (“device”) you use to connect to the services provided such as details about the type of device (which can include unique device identifying numbers), its operating system, browser and applications connected to the services provided through the device, your Internet service provider or mobile network, your IP address and your devices telephone
    number (if it has one).
  • We do not collect information about your actual location, other than an approximate location (usually no more precise than city level) which can be determined from your IP (Internet Protocol) address. In certain instances, we may use cookies and similar technologies to store and access information we collect through the services provided.
  • We may collect your IP (Internet Protocol) address in order to assist us diagnose errors of our server and to administer Owiwi’s website. The IP address is a number given to your computer when you use the Internet. Your IP address is also used to facilitate your recognition during a specific conference and to collect broad demographic information.

For the reasons of any payment made via Owiwi’s website you will be asked to provide certain payment (credit/debit/ Paypal) details. For us to be able to keep your payment details secure, the payment of an order can be made via a credit/debit/prepaid card through the SSL Security and Technology Protocol, your Paypal account or by a deposit to the Company’s bank account under the following details: Bank: Eurobank Ergasias A.E.

IBAN: GR8102602770000740201147096,

Bank account Holder: Owiwi Private Company

By submitting your credit/debit/prepaid card details you guarantee that you are the lawful owner of the card you use or that you have been specifically authorized to use it by the owner of the credit/debit/prepaid card. In case you are not the lawful owner of the card you use Owiwi is not liable against the legitimate owner of the card it has been used. All card holders are subject to validation checks and authorization by the card issuer. If the issuer of your payment card refuses to authorize payment to Owiwi, we will not be liable for any delay or non-delivery. If you have an Owiwi account, we will securely store your card details encrypted in our system. These details will be fully encrypted and only used to process card transactions, which you have initiated. To help ensure that your Owiwi experience is safe, simple, and secure at our website, we use Secure Socket Layer (SSL) technology. Furthermore, we take reasonable care, in so far as it is in our power to do so, to keep the details of your payment secure, but in the absence of negligence on our part we cannot be held liable for any loss you may suffer if a third party procures unauthorized access to any data you provide when accessing the website.

In addition, Owiwi collects information, which is not collected to be associated with identified individuals concerned, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) of requested resources, time of request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc..) and other parameters regarding the operating system and computer environment. These data are used only to obtain anonymous statistics on site usage and to check its correct functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site: except for this possibility, at present, data concerning web contacts do not persist for more than seven (7) days.

Owiwi may additionally collect data about how you use the services provided such the time you access each service provided and duration you are on it, the site you come to a service from or go to after leaving a service, selections and choices you make and preferences that you set when using a service as well as any data you input while conducting any assessment on the services provided.

In certain instances, and upon your explicit consent, Owiwi uses cookies and similar technologies to store and access information which collects through the services provided. Owiwi may also collect your IP (Internet Protocol) address in order to diagnose errors of Owiwi’s server and to administer the website.

 

WHAT ABOUT “COOKIES”

  • Cookies are small files which are stored in your computer and hold your settings and options you have made in our Website. They are used to hold your settings (country, items you have seen etc) as well as for our better understanding as to the way of use of our Website. Owiwi uses technologies like cookies and pixel tags to provide, improve, protect and promote its services. This way Owiwi collects information about your use of Owiwi’s online services using cookies.
  • As the majority of websites in the Internet, so www.owiwi.co.uk can use cookies to provide to each user information and better services. Cookies help us remember who you are and other information about your visits. They can help display the information on a website in a way that matches your interests. The use of session cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to transmitting session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient exploration of the site. For example cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our services, and improving them based on that information and do not allow acquisition of personal identification data.  Please note that cookies do not harm your computer nor the files into which they are kept.
  • For the safe navigation to www.owiwi.co.uk, Owiwi, conforms with the European Directive 2009/136/EK regarding the protection of personal data and private life in the field of electronic communications and which directive was integrated to the Greek Law by L. 4070/2012 (Α’82/10.04.2012) “Settings of Electronic Communications, Transportation, Public Constructions and other provisions”. Owiwi clarifies that for the use of cookies your prior consent is a necessary prerequisite. Exception to this rule will only be cookies which serve functional needs of the Website (functional cookies) and are necessary for the appearance and the effective function of the webpage to your computer.

You can set your browser to not accept cookies, but this may limit your ability to use the services.
For more information on how we use cookies, please read our Cookie Policy.

 

HOW THIS DATA MAY BE USED

Whenever you give us your personal data we will use it in accordance with applicable privacy laws and for the purposes set out in this Policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.

When you use our services: If you use any of our services, set up, look at or change your account details we will record your personal details. Your information will be used in the first place to provide the services or information you have asked for and to provide you with a personalized navigation experience.

We mainly use the personal data provided to us in order to make sound scientific conclusions, to develop new services, to send you newsletters and information about events and/or other services in which we believe you may be interested in, as well as for statistical, survey and research reasons. More precisely, we use the information we collect in the following ways:

  • to manage your Owiwi Account and provide you with the features of the services provided, validate and keep your personal information accurate. We will use information we collect directly from you for this purpose.
  • to ensure that content from the services provided is presented in the most effective manner for you and for your device and to display content and features that are tailored to you, your interests and how you use the services provided. We will use information we collect directly from you, information about how you use the services provided and information about how you connect to the services provided for this purpose.
  • to provide you with information about services that you request from us or which we feel may interest you (in accordance with your marketing preferences). We will use information we collect directly from you for this purpose, and always upon your explicit consent by clicking the relevant
    box (opt-in policy) in our website.
  • to determine and predict information that may be of interest or relevant to you. We will use information we collect directly from you, information about how you use the services provided and information about how you connect to the services provided for this purpose.
  • to make sound scientific conclusions, to conduct surveys, for statistical and research reasons. We will use information we collect directly from you for this purpose and always upon your explicit consent by clicking the relevant box (opt-in policy) in our website.
  • to carry out our obligations arising from any agreements entered into between you and us, such as allowing the Companies/Businesses/ Organizations/Academic Institutions to evaluate the Game/s you have played. We will use information we collect directly from you, information about how you use the services provided and information about how you connect to the services provided for this purpose.
  • to notify you about changes to the services provided and address complaints, comments and issues you have in relation to your use of the services provided. We will use information we collect directly from you for this purpose.
  • to prevent, detect and investigate illegal activities, breaches of any agreements entered into between you and us and threats to the security of the services provided. We will use information we collect directly from you, information about how you use the services provided and information about how you connect to the services provided for this purpose.
  • to produce aggregate statistical information and analytics about you and of your submissions to the services provided, and always upon your
    explicit consent.
  • where required by law or in connection with legal proceeding or extrajudicial disputes;
  • to develop, test and maintain systems;
  • to carry out accounting, billing, reporting and audit obligations, credit or billing checking or credit or billing process screening, and /or authentication and identity checks; and /or credit, debit or other payment card verification and screening; and/or debt collection; and/or for preservation of security and safety, but also for training, administrative and legal purposes; Keep in mind that stored payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner’s systems.
  • any other uses set out in the terms and conditions for use of our services. For these purposes we may disclose your information to one or more of the other organizations listed in the section called “who we will share your personal information with”.

 

Psychometric Data: Upon your explicit consent and before playing the Game, Owiwi may collect and process sensitive data of yours, including psychometric data, as on these data is based your Owiwi Personal Report. Owiwi processes this special category of your personal data only to the extent necessary for the purposes of its legitimate interests and for the fulfillment of its contractual obligations towards you or towards the Company/Business/Organization/Academic Institution in which you are already an employee or you would like to work for or you are a part of. Owiwi, having taken the appropriate technical and organizational security measures is committed in respecting your personal data and declares that is fully compliant with the provisions of the applicable Greek and Community legislation on the protection of personal data, including the General Data Protection Regulation 2016/679/EU (GDPR). Owiwi declares that maintains a record of processing of all categories of your personal data, which may be available to the supervisory authority upon request. Additionally, Owiwi declares that carries out a Data Protection Impact Assessment (D.P.I.A.) before the processing of your personal data. Where necessary, Owiwi shall carry out a review to assess if processing is performed in accordance with the D.P.I.A. at least when there is a change of the risk represented by processing operations.

Customization of our online services and advert targeting: We may use the information you give us about yourself and the information we collect via cookies when you use our services to build up a picture of your interests. We may then use this information to try to make sure that when we send you marketing communications and when you visit our websites or use our online services. This information may also be used by our third-party advertising agencies and networks, to advertise our own or third party products and services to you when you visit third party websites and online services. This is called advert targeting or interest-based advertising. For more information on how to reject targeted advertising or interest-based advertising cookies please read our Cookie Policy.

Comments and reviews submitted to our online services: If you wish to submit a comment or feedback on a blog or article featured on our services, we may (but are not obliged to) publish your comment online or offline to promote our business and our services. We will collect your name or username which will be displayed next to your comment and e-mail address, which will not be published, but which we may use to contact you in relation to your comment.

Mobile services: When you request Owiwi’s mobile services, we may keep your mobile phone number, the make and model of your phone, the operating system used by your phone and details of your network operator, and we will link a unique identifier to your mobile phone number. Owiwi will be able to use any users’ feedback or comments shared with us, through Owiwi ’s live chat system (Intercom) or any e-mail communication. We’ll store your device language, app language, country. We need this information in order to provide the features and services enabled through our mobile services and to administer our mobile service.

Direct marketing: For information on how we may market to you, please read the section called “Marketing opt-in and opt-out provisions”.

Customer surveys: Every now and again, we may ask you for your opinion on our services. When we do research or surveys, we may use cookies and may combine the information collected by those cookies with your answer.

 

WHO WE WILL SHARE YOUR PERSONAL DATA WITH

  • We may share information, as discussed below, but we won’t sell it to advertisers or other third parties. In order for us to be able to share your information, you must provide your explicit consent by ticking the relevant box indicated in our website.
    We generally do not disclose your personal data except in the following cases:

    • there is your explicit consent about the above – mentioned actions, by clicking the box “I accept”, otherwise you have to send us a relevant e-mail at support@owiwi.co.uk.
    • the disclosure is to third, natural or legal person, with which Owiwi cooperates and only up to the extent where it is deemed absolutely necessary for the provision of each service provided by Owiwi’s website. We use certain trusted third parties (for example, providers of customer support and IT, accounting and legal services) to help us provide, improve, protect, and promote our services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy and will remain responsible for their handling of your information per our instructions.
    • if required by Law, by court order or requested by any other competent governmental, judicial, police, administrative or regulatory authority, upon legitimate request and according to the pertinent laws. You, within the frame of legislation for secrecy of the telecommunications, have the right of information and objection provided by domestic and Community legislation on Data Protection, including but not limited to GDPR 2016/679 and L. 3471/2006 as in force.
    • to protect any person from death or serious bodily injury;
    • prevent fraud or abuse of our users;
    • legally protect our property rights.
  • You can revoke your consent about the above – mentioned actions or you may request correction or completion of the data you have provided to us, by sending us a relevant e-mail at support@owiwi.co.uk.

 

WHERE WE PROCESS AND STORE YOUR PERSONAL DATA

  • All Registration Data provided to us shall be stored securely in order to ensure that content from the website is presented in the most efficient manner for you and for your computer and upon your explicit consent to send you newsletters and information about events and/or other services in which we believe you may be interested in except you decide either to deactivate your Owiwi Account or you wish not to be stored anymore, by sending us a relevant e-mail at support@owiwi.co.uk.
  • All data providing to us when you make your Game purchase (“Customer Data”), meaning all Buyer and Payment Details, shall be stored securely for a reasonable period of time, as mentioned down below, in order to have transparency in our transactions and to be able to have a list with our clients, with the exact purchase date and the method of payment preferred.
  • All Game Data provided to us shall be stored in an anonymized form in order to make sound scientific conclusions, to develop new services as well as for statistical, survey and research reasons. Anonymized Game Data cannot be linked to Individual Registration or Customer Data, Owiwi has therefore no means to delete them individually. By accepting Owiwi’s Terms of Use and this Policy it is presumed that you consent to us storing your Game Data in anonymized form.
  • The information we collect directly from you, including but not limited, about how you use the services provided and about how you connect these services may be transferred to, and stored at server’s destination inside the European Economic Area (“EEA”). Owiwi may designate third-party service providers for the processing of data (Data Processors) as well as for the management and operation of certain functions of the website. Owiwi guarantees that it takes all the appropriate organizational and technical measures to protect your data, even keeping an electronic record of all categories of processing activities. By using Owiwi’s services, you consent to any transfer, storage or processing of your personal information outside of your country, but inside the territory of EEA. We will take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this Privacy Policy.
  • All information you provide to us is stored on a third party’s secure servers providing data hosting services to us under our control or on computers of Owiwi. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the services provided, you are solely responsible for keeping this password confidential. If the password has been stolen or might otherwise be subject to misuse, it is your responsibility to notify us immediately for further action.
  • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

 

HOW LONG WE CAN KEEP YOUR PERSONAL DATA

  • All Registration and Customer Data will be retained until you deactivate your Owiwi Account and for a maximum period of ten (10) years or you wish not to be stored anymore, by sending us a relevant e-mail at support@owiwi.co.uk.
    The retention period of your personal information is always in compliance with domestic legislation.
  • If you delete your account, or upon a written request by you, by sending a relevant e-mail at support@owiwi.co.uk we will delete or destroy any of the personal information you had provided to us. But please note:
    • there might be some latency in deleting this information from our servers and backup storage; and
    • we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. Keep in mind that we follow a Data Minimization Principle and thus we request, process and store the minimum possible personal data so as to provide our services uninterruptedly.
  • All Game Data are anonymized and cannot be linked to Individual Registration or Customer Data, Owiwi has, therefore, no means to delete them individually. By accepting Owiwi’s Terms of Use and this Policy it is presumed that you consent to us storing your Game Data in anonymized form.
  • Any request by you to delete your personal information will not result in deletion of any game data submitted by you to a Company/Business/ Organization/Academic Institution (in respect of which we are a data processor and not a data controller).

 

MARKETING OPT-IN AND OPT-OUT PROVISIONS

We offer you the chance to receive news and updates for the products and services we offer through our website which, depending on your preferences, we will discuss with you by phone or live chat or send to you via email, SMS and/or direct mail. These include alerts for new features, enhancements, upgraded opportunities, contests, events of interest, and one-off marketing promotions. Our website being in severe compliance with personal data regulations follows a strict opt-in policy in relevance to receiving these updates, by ticking the box indicated in our website.

You have the right to change your mind anytime and to ask us not to use your personal information for marketing purposes. At all times, we will offer you the opportunity to unsubscribe from any service or update to which you have subscribed. Whenever you receive direct marketing from us, we will tell you how to unsubscribe.

 

HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION AND KEEP IT UP TO DATE

You have the right to see the information we hold about you (with the exception of anonymized Game Data, see section 4(c). If you would like a copy of your personal information, please contact at support@owiwi.co.uk.
You will need to pay a processing fee of fifteen (15) euros.
You have the right to review and update your personal details. If for any reason you are concerned that the personal information we hold is not correct, please visit our online services and, after logging into the site using the “Sign In” menu on the home page, your personal information will be made available for review and change in the “Customer Account” section. Only you or, upon your request, our Customer Care team, may access your personal data from our online services using your user ID and password.
If you prefer, you may contact us by email at support@owiwi.co.uk and we will amend your personal details.

 

SAFEGUARDING YOUR PERSONAL DATA

We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the data you have provided to us. We have put in place technology and security policies which are designed to protect the personal information we hold about you. We also follow the security procedures that applicable privacy laws require. These covers storing, processing, using and releasing any information you have provided as well as measures designed to prevent unauthorized access or use. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorized use. We want you to rest assured as we have a team dedicated to keeping your personal data secure and testing for vulnerabilities. We also continue to optimize technical features to keep your information safe in addition to things like authentication tools, encryption of files at rest, and alerts when new devices and apps are linked to your account.

Keep in mind that where we have given you (or where you have chosen) a password which enables you to access certain parts of the services provided, you are solely responsible for keeping this password confidential. If the password has been stolen or might otherwise be subject to misuse, it is your responsibility to notify us immediately for further action.

 

WHY WE LINK TO OTHER WEBSITES/ SOCIAL MEDIA

Our services may contain hyperlinks to websites that are owned and operated by other organizations. These websites have their own privacy and cookie policies, and we urge you to read them. They control how your personal data is used when you give it to these other organizations or they collect it with cookies. We do not approve any other websites and we are not responsible for any data, information, material, products or services that are on or accessible through those websites or for the privacy practices of websites.
If you follow us or interact with us on any of our pages on third party social media platforms, such as Instagram, Facebook, Twitter, Pinterest and Google+, information you provide will be subject to the third party’s privacy policy, as well as to this privacy policy.

 

HOW WE CAN MAKE CHANGES TO THIS POLICY

If there is a, total or partial, reorganization, merger, absorption, consolidation, change of control, transfer of substantial assets, acquisition or sale of our assets or liquidation of the Company, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event. You might be asked to renew your given consents in terms of what we can do and how we process your personal data.
We may revise this Privacy Policy from time to time, and will post the most current version on our website. Any amendment in this Privacy Policy will be valid once the amended Privacy Policy is uploaded in the website.

We recommend you to visit regularly our website’s Privacy Policy in order to be informed about all the amendments that have been made.
If a revision meaningfully reduces or alters your rights, we will notify you, and you might be asked to renew your given consents in terms of what we can do and how we process your personal data.

 

WHERE AND HOW TO ASK QUESTIONS, COMPLAINTS OR CONTACT US ABOUT THIS POLICY

For any complaints, we hereby notify you that you have the right to file a claim at Hellenic Data Protection Authority, which is the competent authority, located at 1 – 3 Kifisias Avenue, P.C. 115 23, Athens (tel. +30 210 64 75 628 – email: complaints@dpa.gr).
If you have any questions or concerns, please contact us at support@owiwi.co.uk
For the purpose of the Data Protection, the Data Controller is OWIWI P.C., a Greek company, under G.E.MI. Reg. No: 131688201000, having its address at 3 Asklipiou str., P.C. 106 79, Athens, Greece. In addition to Owiwi P.C. processing personal information as a Data Controller, we also process personal information as a Data Processor on behalf of Companies/Businesses/Organizations/Academic Institutions. In case you do not wish to store your personal data, you have to e-mail us at support@owiwi.co.uk