PRIVACY POLICY

1. Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

 

We know that there’s a lot of information here but we want you to be fully informed about your rights, and how the DaVinci Artisan Gelato uses your data. 

 

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

 

Our products and services are aimed at those age 16 and over.

 

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.

 

When you are using the DaVinci Artisan Gelato website, DaVinci Artisan Gelato is the data controller.

 

DaVinci Artisan Gelato is a Greek based company and therefore, when visiting our website, personal data that we may collect through cookies or online forms will leave the EU for Greece.

2. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

 

Consent

  • In specific situations, we can collect and process your data with your consent.

  • For example, when you tick a box to receive email newsletters.

  • When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

 

Contractual obligations

  • In certain circumstances, we need your personal data to comply with our contractual obligations.

  • For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

 

Legal compliance

  • If the law requires us to, we may need to collect and process your data.

  • For example, we can pass on details of people involved in fraud or other criminal activity affecting DaVinci Artisan Gelato to law enforcement.

 

Legitimate interest

  • In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

  • For example, we will use your purchase history to send you or make available personalised offers.

  • We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.

  • We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

  • We may contact you regarding market research.

3. When do we collect your personal data?

  • When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the DaVinci Artisan Gelato on the phone, in a shop or online.

  • When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.

  • When you engage with us on social media.

  • When you contact us by any means with queries, complaints etc.

  • When you fill in any online forms, regarding any franchise opportunities and enquiries.

  • When you ask DaVinci Artisan Gelato to email you information about a product or service.

  • When you enter prize draws or competitions.

  • When you book any kind of appointment with us or book to attend an event.

  • When you choose to complete any surveys we send you.

  • When you comment on or review our products and services. Any individual may access personal data related to them, including opinions. 

  • When you fill in any forms. For example, if an accident happens in store, we may collect your personal data.

  • When you’ve given a third party permission to share with us the information they hold about you.

  • We collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.

  • When you use our shops which usually have CCTV systems operated for the security of both customers and employees. These systems may record your image during your visit.

 

4. What sort of personal data do we collect?

  • Details of your interactions with us through contact centres, in store, or online.

  • Details given to us by your interaction with us via email

  • When you fill in a potential franchisee contact form online which includes enough information for us in order to analyse your skills as a potential franchisee. 

  • Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.

  • Open rates, click through rates on email marketing campaigns through the use of Pixels.

  • Your comments and product reviews.

  • Your image may be recorded on CCTV when you visit a shop or car park.

  • To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

 

5. How and why do we use your personal data?

  • We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

  • We then use this to offer you promotions, products and services that are most likely to interest you.

  • The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

  • Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

 

Here’s how we’ll use your personal data and why:

  • To process any orders that you make by using our websites, or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.

  • For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations.

  • To respond to your queries, requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

  • To protect our business from fraud and other illegal activities. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

  • To protect our customers, premises, assets and employees from crime, we operate CCTV systems in our stores which record images for security. We do this on the basis of our legitimate business interests. 

  • If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.

  • With your consent, or whenever you purchase with us and do not choose out of receiving our updates, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. 

  • Of course, you are free to opt out of hearing from us by any of these channels at any time.

  • To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.

  • You are free to opt out of hearing from us by post or by email at any time.

  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

  • To display the most interesting content to you on our websites, we’ll use data we hold about your favourite products and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at.

  • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. 

  • To comply with our contractual or legal obligations to share data with law enforcement.

  • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

  • Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences.

 

6. How we protect your personal data

  • We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

  • We secure access to all transactional areas of our websites and apps using ‘https’ technology.

  • We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

 

7. How long will we keep your personal data?

  • Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

  • At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

8. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

 

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

  • We provide only the information they need to perform their specific services.

  • They may only use your data for the exact purposes we specify in our contract with them.

  • We work closely with them to ensure that your privacy is respected and protected at all times.

  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

 

Examples of the kind of third parties we work with are:

  • IT companies who support our website and other business systems.

  • Direct marketing companies who help us manage our electronic communications with you.

  • Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.

  • Data insight companies to ensure your details are up to date and accurate.

 

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

  • With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

  • For example, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event and you agree to receive direct communications from them.

  • For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

  • We may, from time to time, expand, reduce or sell a store  or the company and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

 

For further information please contact our Data Protection Officer.

 

9. What are your rights over your personal data?

You have the right to request:

  • Access to the personal data we hold about you, free of charge.

  • The correction of your personal data when incorrect, out of date or incomplete.

  • The deletion of the data we hold about you, in specific circumstances. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.

  • A computer file in a common format (e.g. CSV or similar) containing the personal data that you have previously provided to us and the right to have your information transferred to another entity where this is technically possible.

  • Restriction of the use of your personal data, in specific circumstances, generally whilst we are deciding on an objection you have made.

  • That we stop processing your personal data, in specific circumstances. For example, when you have withdrawn consent, or object for reasons related to your individual circumstances.

  • That we stop using your personal data for direct marketing (either through specific channels, or all channels).

  • That we stop any consent-based processing of your personal data after you withdraw that consent.

 

You can contact us to request to exercise these rights at any time by contacting our Data Protection Officer.

 

If we choose not to action your request we will explain to you the reasons for our refusal.

 

Your right to withdraw consent

  • Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

 

Where we rely on our legitimate interest

  • In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

 

Direct marketing

  • You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

 

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

 

10. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr/en). 

 

You can contact them by calling 0030 210 647 5600. 

 

Or via email: contact@dpa.gr 

 

Please note we can't be responsible for the content of external websites.

 

If you are based outside Greece, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. 

 

11. Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

 

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

 

This notice was last updated on 01/11/21