PRIVACY POLICY – TERMS & CONDITIONS

Version 1.0 (Last Updated May, 2022)

KYANA (“KYANA,” “we,” “us”) collects, stores, and processes information from members, KYANA website (“Site”) visitors, and users (“you”) of our Services. KYANA values your privacy and works hard to protect your information. This Privacy Policy (the “Policy”) describes the information we collect from you when you interact with our website, the other websites of our company, or visit our physical locations.

If you don’t want us to collect or process your personal information in the ways described in this policy, you should not use the website.

Below, you will find our Policy separated into sections describing all aspects of our data collection practices. The sections are:

1. Summary
2. Consent to Data Collection
3. What Information We Collect
4. How We Collect Your Information
5. How We Use Your Information
6. Cookie Policy
7. Why We Collect and Use Your Information
8. Data Transfers
9. Sharing Your Information
10. Your GDPR Rights Regarding Your Information
11. Marketing Communications Choice and Opt-Out
12. Targeted Advertising
13. Confidentiality and Security
14. Third-Party Services
15. Contact Us

1. Summary

Our Privacy Policy is written to clearly explain and describe to you how we collect, use, share, and disclose the information collected by KYANA through our websites. We have divided our Policy into two different sections: (1) this succinct summary section that provides a general overview of our privacy practices; and (2) a more comprehensive policy outlining the specifics of what information we collect, how and why we collect that information, and your rights in regard to your data. In the bullet points below, you will find key areas of our Policy of which you should be aware. We encourage you to read the full policy before providing us with your information.

• We collect personal information in a few principal ways, including information you provide directly to us, information we gather from your use of our Services, and information we receive from third parties.
• We may share your information from time to time with third parties, including information necessary to provide you with our Services.
• You may request deletion, request a copy of, request rectification, restrict or object to processing, and request to transfer your data by emailing your request to [email protected]
• While it is not possible to guarantee that your information will remain entirely secure, we use commercially reasonable efforts to secure your information.

• Consent to Data Collection

By using our Services, you consent to the collection of your personal information either by collecting the information directly from you or by our tracking technologies, like cookies. You also consent to KYANA collecting and using your information as described in our Policy.

This website is not directed toward or intended for use by children or anyone under the age of 18. We do not knowingly collect information from anyone under the age of 13.

By accessing and using our Services, you accept all terms and conditions set out in this Policy. Before using our Services, you should read the Policy in its entirety and return to this page periodically to review any changes. We may update this policy from time to time and by continuing to use our Services after such updates you consent to those changes.

• What Information We Collect

The Types of Data We Collect

Personal Data. “Personal Data” is data that someone could use to individually identify or contact you. This includes information like your name, email address, telephone number, or address. It can also include non-public information of yours that is either associated with or linked to any of the data mentioned above. “Anonymous Data” is data that is neither associated with nor liked to your Personal Data. Anonymous Data on its own cannot identify you individually. KYANA collects both Personal Data and Anonymous Data.

Account Information. When you sign up for an account, we collect certain information about you. This includes basic information such as your email address, name, phone number, and address. If you fill out any surveys through your account, we keep that information as well. We may also collect information about your interest in and use of various products, services, and content you access through our websites. 

Social Media. You may be able to link some social media accounts to our websites. If you link such social media accounts, we may access surface level profile information from your account including your name, profile picture, contact list, username, pictures and videos, gender, birthday, location, people you follow and/or who follow you, and the posts you make or posts you “like.” By linking your account, you consent to KYANA collecting any linked information in accordance with this privacy policy. If you do not wish to share certain information from another social media account, you should change your preferences on that account. Any information from another social media service is subject to the data protection practices of the social media network itself and is not controlled by KYANA. As such, you should read through the privacy policy of any social media service you wish to link to before linking the account with our Services.

Device and Technical Information. As is true of most websites, when you access our websites through your computer or smartphone, we automatically collect information about the device you are using, including: your browser type, your operating system, your IP address, your Internet service provider or mobile carrier, IDFA, MAC address, and unique device identifier. We also collect crash logs, reports on bugs, feedback on our services, support requests, and certain device usage information. You can deactivate cookies through your own browser settings.

Financial Information. When you purchase a product through our websites we save your purchase for internal audit purposes or to send you additional content and product offerings and collect your credit card information in order to complete your transaction. We do not retain the card information. It is given to our financial service provider for the sole purpose of completing the transaction. An encrypted version of the card is retained on the third party payment processor platform.

Location Information. We may collect certain location information, such as country or address, when you either provide it to us directly, through device information, or other means. For instance, if you access our websites through your computer or mobile device, we may collect your precise device location through your IP address for security, regulation, and performance considerations. You can restrict what location information you provide to KYANA through your device settings. When you make a purchase at one of our physical locations, we will have a record of your location fir that purchase.

Information From Other Sources. We may collect information from other sources such as companies and sponsors for co-branding events to give you access to promotions, sweepstakes, and other specific event information. 

• How We Collect Your Information

Information Collected Directly From You

We collect information directly from you when you fill in account information and when you access our Services through any of your devices. We collect device information through the use of cookies, web beacons, pixels, and other similar technologies either used by us or used by other entities on behalf of KYANA.

Categories of Personal Information Collected From Third-Parties

We may collect information from third parties such as social media websites you link to, co-sponsors, and credit card processing companies. 

• How We Use Your Information

Communications With Users. We may contact you by email, phone calls, text messages, or physical mail to inform you about orders you have made.

Marketing and Promotions. We use your contact information, including your email address, phone number, and physical address, from time to time to send you marketing and promotional materials regarding our Services or other offerings. These materials include sponsored content or information on upcoming specials or opportunities. You may opt-out of or change your preferences for marketing communications at any time by either clicking the “Unsubscribe” button within the communications or by emailing your request to [email protected]

Technical Improvements. We use technical and usage information to improve our Services and make your experience with our Services more enjoyable, improve accuracy of information, reduce waiting times, improve product offerings, and to perform analytics on our Services. 

Compliance. To ensure that our services are in compliance with legal obligations and our own Terms of Use, we collect information to detect, investigate, and prevent activities that may violate the KYANA Terms of Use, infringe on the copyright of another, be fraudulent or otherwise illegal, or to ensure the safety of other users.

• Cookie Policy

We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies. A more detailed explanation of the technologies we use, and how to opt out when applicable, can be found in KYANA Cookies Policy. 

• Why We Collect and Use Your Information

We collect your information under the lawful bases of legitimate interest, consent, and contract. In order to provide you with the best and most relevant experience with our Services, our legitimate interest is to track consumer insights and needs and provided a tailored satisfactory experience. We also collect what you allow us to collect and what you voluntarily provide and what is necessary to fulfill our contracts with you. You may withdraw consent at any time by emailing [email protected] When you sign up for an account with KYANA we collect and keep information on the basis of contract and will keep and use your information in order to execute our purchases with you.

• Data Transfers

We may transfer your data outside of the country in which it was collected. We may need to do this in order to fulfill orders or complete transactions with you. Other countries may not have the same rules, regulations, or protections of your country or the country in which your data was collected. When transferring data across borders, we ensure that any entity with which we share that information will protect your data according to our privacy policy.

• Sharing Your Information

We may share and disclose certain information with third parties in the following ways or for another purpose disclosed at the time of collection:

• With Your Consent. We may disclose Information when you provide us with your consent to do so.
• Legal and Law Enforcement Purposes. If it is necessary to respond to legal process, we may disclose your information to a court or law enforcement agency. We may also disclose Information to third parties: (i) in connection with fraud prevention activities, (ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, and (v) as otherwise required by law.
• Change of Control. In the event of a business transaction whereby we or one of our subsidiaries or relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.
• Service Providers. We may give our agents and contracts (“Service Providers”) access to certain Information in order for them to help carry out the services they are performing for us, such as, but not limited to: creation of the Site, maintenance of the Site, hosting the Site, delivery of KYANA Services and products that you request, conduct authorization and payment processing, email and order fulfillment, fraud protection, administer contests, conduct research and analytics, product customization, serving certain types of advertisements to you, marketing and promotional material distribution (including direct mail marketing) and/or customer service. We require Service Providers to protect the Information consistent with this Policy through contractual obligations.
• We may disclose Information to affiliates. We require all our affiliates to protect any Information we share with them according to our Privacy Policy through contractual obligations.
• Business Partners and Third Parties. We may share your information with certain business partners or Affiliates. (e.g., other companies, retailers, research organizations, advertisers, ad agencies, advertising networks and platforms, participatory databases, publishers, and non-profit organizations) that may want to market products or services to you. If we share personal information with such unaffiliated third parties for their own marketing purposes, we provide you with an opportunity to opt out of such uses either at the point of collection or through the choice mechanisms set forth in this Privacy Policy.
• Linked Sites. Some of our websites may contain links to social media sites whose information practices may differ from ours. Information you submit to those other linked sites are governed solely by their privacy policy and terms of use or service.
• Sponsors and Co-Promotions. We may sometimes offer content or programs that are sponsored or co-branded with identified parties. The sponsoring or co-branding parties may collect or obtain certain Information from visitors that participate in the activity. We have no control over these sponsoring or co-branding parties’ use of this Information. We encourage you to visit the privacy policy of any such sponsoring or co-branding party to learn about their data protection practices prior to providing Information through sponsored or co-branded content or programs.

1. Your GDPR Rights Regarding Your Information

Under the General Data Protection Regulation (GDPR) you may have the following rights in regard to your personal data:

• The right to access. You have the right to be informed of all the personal information we hold on you.
• The right to information. You have a right to know why and how we collect your personal information.
• The right to object to or restrict processing. You have the right to opt-out of having your personal data processed or limit the processing of your personal data at any time.
• The right to correction. You have the right to rectify any inaccurate personal information we have on you.
• The right to erasure. You have the right to request for us to delete any information we may hold on you.
• The right to data portability. You have the right to request a copy of your data in a portable format.

To exercise any of the above rights, please email our Data Protection Officer at [email protected] with your request in the subject line. 

KYANA has the right to refuse to honor your request to delete any of your Personal Data if it is necessary to exercise the right of freedom of expression and information, to comply with any legal obligation that may require processing of your Personal Data, for reasons of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, or for the establishment, exercise or defense of legal claims. KYANA may also refuse to delete or delay deleting information if it is necessary to carry out a contract we have with you. 

KYANA does not use your Personal Data to make any automated decisions about you.

1. Marketing Communications Choice and Opt-Out

We want to communicate with you only if you want to hear from us. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in the emails and the bottom of our home page on the Site, updating your communications preferences in your membership account on our Site or contacting us at [email protected]. Please note however, that as a user of the Service, you cannot opt-out of some administrative communications that are reasonably necessary to the service, such as billing or service notifications. 

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may access, update or correct any of your personal information in your account by editing your profile within your account. You may request access, updating or the correction of inaccuracies in other personal information in our custody or control by writing or sending an email to us at [email protected] 

We reserve the right to retain any personal information reasonably necessary to appropriately document our business activities and for archival and record retention purposes to the extent permitted by law. We will store personal information for as long as reasonably necessary for the purposes described in this Privacy Policy. You may have a right to request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request where required by law, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.

1. Targeted Advertising

We may share email addresses (in a hashed or de-identified form) that have been provided to us by our registered users, with network advertisers and ad exchanges , to serve targeted advertisements to you about our goods and services. We may work with third parties and our Service Providers, such as network advertisers and ad exchanges that use tracking technologies on our websites in order to provide tailored advertisements on our behalf and/or on behalf of other advertisers across the Internet and we may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your activities (including past visits to our websites) across the Internet and mobile media (“Targeted Advertising”). 

Targeted Advertising (also known as Behavioral Ads) uses information collected on an individual’s web browsing behavior on one website (such as the pages they have visited or the searches they have made) in order to target advertising to that individual on another website. Targeting called Cross Device Tracking can also take place across devices such as tablets, smartphones, laptops and smart televisions. Third parties collect this information by placing or accessing cookies or other tracking technologies in your browser when you visit this, or other, websites.

Behavioral Ads enable us to target advertisements to you for products and services in which you have demonstrated an interest. If you object to receiving Behavioral Ads from us on third party sites, you can learn more about your ability to limit Behavioral Ads below. Our third party ad network and exchange providers, the advertisers and/or traffic measurement services may themselves set and access their own technologies on your device and track certain behavioral usage information via a device identifier. These third party technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements; and (c) understand the usefulness of the advertisements that have been delivered to you.

Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

While sites use a variety of companies to serve advertisements, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp , which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members not mean you will no longer receive any targeted content and/or ads. You may also opt-out of receiving Behavioral Ads on participating sites and services by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices/rs no longer will be allowed under their own rules to deliver Behavioral Ads to you, but do. Please note, if your browsers are configured to reject cookies when you visit an opt-out page, or you subsequently erase your cookies, use multiple devices or change web browsers, your opt-out may not, or may no longer, be effective. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options or programs.

1. Confidentiality and Security

KYANA takes your privacy concerns very seriously and protects your information by appropriate technology, policies, and procedures to prevent unauthorized use, access, disclosure, modification, copying or destruction, and to maintain the integrity. We protect your information both online and offline. We only process your Personal Data fairly and lawfully after receiving your consent and we do not use your Personal Data in any manner inconsistent or incompatible with the purposes for which KYANA collects the information. KYANA may retain your personally identifiable information as long as there is a business requirement, or if otherwise required under applicable laws.

No method of transmission over the Internet, or method of electronic storage, is entirely secure. KYANA uses reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure; however, KYANA cannot guarantee its absolute security.

1. Third-Party Services

Categories of Third-Parties With Whom We May Share Your Information

Third parties we may occasionally share your information with include financial services companies, business partners, co-sponsors, analytics services, email service providers, cloud service providers, fulfillment services, technical support, delivery services, and marketing platforms. 

KYANA  does not sell your Personal Data at this time, but you can email us at [email protected] to request that your information not be sold in the future should our practices regarding selling data ever change.

1. Contact

If you have any questions regarding this Privacy Policy, please contact our Data Protection Officer either by email at [email protected]  or by mail. KYANA  Markou Mpotsari 118 544 53 Thessaloniki, Greece