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Privacy Policy & Cookies

This Privacy Policy (hereinafter referred to as the “Policy”) refers to your personal data collected and processed by the company called “PHIND P.C.”, which is located in the Municipality of Athens, Greece, at 11-15 Aristotelous Street, with VAT registration number 802454740 General Commercial Register number 176660801000 (hereinafter referred to as the “Company”) when you use the “phind” application and/or the Company’s website at https://phindapp.com/ (hereinafter referred to as the “Application / App” or the “Website”). More specifically, the Policy provides you with information about the processing of your personal data by the Company, the duration of their retention, their disclosure to third parties, as well as your rights in relation to your personal data and the ways of contacting the Company. In addition to the information provided to you in the Policy, further information, highlighting certain uses of your personal data together with the possibility of consenting or not consenting to them, may also be provided at the stage of collecting your personal data.

The Company is a modern company that operates on the basis of international standards and is mainly active in the provision of software reproduction services, application operation and information technology infrastructure, web hosting, online content production, sale of advertising space on the Internet, etc. Through the “phind” Application and its Website https://phindapp.com/, the Company aims to directly connect professionals and amateurs as well as agencies active in the field of information technology and the Internet (including but not limited to photographers, models, make-up artists, show business people, influencers, etc.) for the creation and collaboration in the development of photographic and artistic projects.

The collection and processing of personal data by the Company is carried out in full compliance with the General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“General Regulation”), which has been in force since 25th of May 2018, and with the applicable national/Greek legislation, in particular Law no. 4624/2019, as amended and in effect currently, which is supervised by the Data Protection Authority (DPA).

1) Personal Data Controller
The Data Controller is the Company, i.e., the company under the name “PHIND P.C.”, which is located in the Municipality of Athens, Greece, at 11-15 Aristotelous Street, with VAT registration number 802454740 and General Commercial Register number 176660801000, as legally represented. For any information regarding the processing of your personal data, you can contact the DPO Mr. Georgios Michos at dpo@phindapp.com.

2) Where we collect the data we process
The Company processes personal data that you yourself have disclosed to us or are going to disclose to us as prospective and/or existing customers of the Company, i.e., users/owners of personal/company profiles in the “phind” Application and/or users on the Company’s Website at https://phindapp.com/. The personal data that you yourself provide to the Company must be complete and accurate and must be updated with your own diligence immediately in case of any change. These data are collected electronically, through the Company’s App and Website respectively, when creating your profile on the “phind” App, purchasing subscription packages, purchasing any other products (micro-purchases) through the App or from our online store, sending a message from you to the Company and, if applicable, in the context of any other communication with the Company and/or your stay on the Application and our Website and use of your profile. Also, your personal data may be collected by e-mail or direct message that you send to the Company. The Company does not process personal data without your consent or without you having voluntarily created a profile on the “phind” Application or, in any case, without you having provided the Company with your data yourself (as prospective users/customers/personal/company profile holders or by contacting the Company, as described above).

3) Which data are processed
The Company processes the data entered by the user when creating a personal/company profile in the “phind” Application and/or the Company’s Website or sent by e-mail or other means of communication. The personal data may be, indicatively and not restrictively, the following:

  • First name, surname, maiden name, age (date of birth), gender
  • Residential address/work address, shipping and/or billing/invoicing address
  • Contact details (telephone number, e-mail address)
  • Identity card/passport
  • Tax registration number, Public Financial Service
  • IBAN bank account
  • Login and account details, including username, password, and unique user ID
  • Information about your profile, your photos, the projects you create or participate in, your collaborations, your interaction with other profiles and users, your subscription, your other purchases, your purchase history, your activity and navigation on the Application and our Website in general and your preferences
  • Personal preferences, such as the list of desired/favorite projects/users/photos and so on, as well as marketing and cookie preferences

At this point, it is noted that you are responsible for the accuracy and updating of the data you provide to the Company. In any case, for reasons of security, reliability, and protection of other users of the Application and the Website, you must, in any case requested by the Company, confirm and update your personal data (indicatively and not restrictively scanned identity card/passport, home/work address, etc.).

4) Purposes of processing
Your personal data is processed:
(a) for the provision of services by the Company to you,
(b) for the compliance of the Company with its legal obligations (tax, insurance, regulatory, etc.), such as the transmission of data to competent tax, audit, and supervisory authorities,
(c) for the operation, improvement, and maintenance of the business activity, products, and services of the Company and for the protection of the legitimate interests of the Company,
(d) for the communication to you of information regarding the Company’s business activity, products, and services,
(e) for the proper coexistence, communication, and effective cooperation with other users/profile holders on the Application and our Website and the successful achievement and elaboration of the photographic projects, which is the purpose of the “phind” application,
(f) for the security of users and profile holders, and
(g) for general research and analysis purposes.

5) Legal basis for processing
Unless otherwise specified on a case-by-case basis, the legal basis for the processing of the aforementioned data is one of the following:
(a) the data is processed with your consent for one or more specific purposes,
(b) the processing is necessary to take measures at the request of the data subject prior to the conclusion of the contract or for the performance thereof, where the data subject is a party to the contract,
(c) the processing is necessary to comply with a legal obligation of the Company, and
(d) the processing is necessary to protect the legitimate interests of the Company.

6) Recipients of the data processed
The Company is obliged or, where applicable, may disclose your personal data to third natural or legal persons, public authorities, or other bodies, such as:
(a) employees of its business and operational units, within the scope of their responsibilities,
(b) third natural or legal persons acting on its behalf and on its behalf, provided that they respect professional secrecy and the duty of confidentiality, such as, among others:

  • companies supplying, developing, and supporting information systems and applications, including internet hosting companies (e.g., cloud computing/cloud providers),
  • database management companies,
  • postal service providers,
  • lawyers, law firms, notaries, and bailiffs,
  • accountants and/or accounting firms,
  • research, analysis, and promotion management companies, and
    (c) public authorities and agencies.

If the Company entrusts the processing of your personal data to third parties acting on its behalf, they must act and fully comply with the Company’s instructions and the applicable legal provisions for the protection of personal data.

7) The length of time for which your personal data is kept
The period of time for which your personal data is kept by the Company varies depending on the type of data, the purpose for which it is collected, the legal basis for processing, and the legal obligations with which the Company must comply. In cases where you enter a contract with the Company (e.g., by purchasing a subscription package from the Company), the Company retains and processes your personal data in accordance with the terms of the contract and for as long as it is necessary for the performance of the contract and/or provided for by the applicable legal and regulatory provisions. If, after the expiry of the above period, judicial or extrajudicial actions are in progress, the data retention period will be extended until the dispute pending before the courts or any other authorities (e.g., arbitral) is resolved in any way. If you create a profile/account on the Application and/or the Website, your personal data will be retained by the Company for as long as you maintain such profile/account.

8) Right to withdraw consent
Where your personal data is processed based on your consent, you have the right to withdraw your consent at any time, with future effect. Withdrawal of consent does not affect the lawfulness of the processing based on it before it was withdrawn and may affect the Company’s provision of certain services to you. If consent is withdrawn, the Company may further process your personal data if there is another legal ground for the processing.

9) Respect and exercise of rights regarding your personal data
Your rights in relation to your personal data are as follows:
(a) Right of access: The right to be informed whether the Company processes personal data, what it is, what the purposes of the processing are, and who the recipients/categories of recipients are.
(b) Right of rectification: The right to request the correction of inaccurate data and the completion of incomplete data by sending/attaching the necessary documentation.
(c) Right to erasure (“right to be forgotten”): The right to request the erasure of your personal data, subject to the provisions of the applicable legislation and the above paragraphs for the protection of the Company’s rights and interests.
(d) Right to restrict the processing of personal data: The right to submit a request for restriction on the processing of personal data, in accordance with the provisions of the applicable legislation and subject to the above paragraphs for the protection of the Company’s rights and interests.
(e) Right to object to processing: The right to object at any time to the processing of personal data when it is based on Article 6(1)(e) or (f) of the General Regulation, as applicable, and which will be satisfied unless the Company demonstrates that there are compelling legitimate grounds for the processing which override the rights and freedoms of the data subject or for the establishment, exercise, or defense of legal and legitimate claims.
(f) Right to portability: The right to receive data that has been provided with your consent or which was necessary for the performance of the contract, in a structured, commonly used, and machine-readable format, or to request direct transmission by the Company to another corresponding provider if this is technically feasible and free of charge. The exercise of this right does not imply the deletion of the data from the Company’s files, provided that their retention is necessary for the Company to comply with its legal obligations or to protect its legitimate interests.
(g) Right to object to a decision based on automated processing: The right to request to be excluded from decisions based on automated processing, including profiling.
(h) Right to withdraw consent already given: See paragraph 8 above.
(i) Right to transparent information on the exercise of your rights.

In order to exercise your above rights, you may contact the Company by e-mail at info@phindapp.com. The Company will make every effort to respond to your requests in exercising your above rights within thirty (30) days of their submission. This period may be extended by sixty (60) days if deemed necessary, considering the complexity of the request and the total number of requests. In this case, you will be informed of the extension within (30) days of the submission of the request. The Company’s refusal or unjustified delay in the satisfaction of data subjects’ requests in the exercise of their rights gives the right of recourse to the Data Protection Authority of Kifissia 1-3, Kifissia, Greece, P.C. 11523, Athens, tel: +30-210 6475600, website: www.dpa.gr, e-mail: contact@dpa.gr, as the competent supervisory authority for the application of the General Regulation. In any case, you reserve the right to lodge a complaint with the above Authority if you consider that the processing of personal data is in breach of the applicable legislation.

10) COOKIES and Pixel Tags
What are Cookies?
Cookies are small text files stored by your browser on your computer or mobile device. Cookies will collect information about your use of the Application as well as the Company Website, information about your device, such as:
(i) your device IP address and browser type,
(ii) your unique cookie ID number, information about your cookies, and information about whether your device has software to access certain data,
(iii) your unique device ID number and device type,
(iv) your domain, browser type, and language,
(v) operating system and system settings,
(vi) country and time zone,
(vii) previous visits to websites,
(viii) information about your interaction with our App and Website, such as number of clicks, purchases of subscription plans and products, stated preferences, favorite profiles, photos, desired partnerships, etc., and
(ix) access times and related URLs, as well as demographic data.

If you are a registered user of the Application and/or the Company’s Website, your email address is also collected.

It is also possible for third parties to collect information through the Application and the Website using cookies, third-party plugins, and widget tools. These third parties collect data directly from your web browser, and the processing of such data is subject to their own privacy policies.

Cookies are widely used to make applications and websites in general work better and more efficiently. To do this, they store the above information, allowing them to recognize you and remember important information that will make using the application and/or website easier (e.g., by remembering your preferences). The use of this technology is in accordance with Greek Law no. 3471 on “Protection of Personal Data & Privacy in Electronic Communications” and the applicable legal provisions on the protection of personal data, as amended and in effect currently.

Use of cookies
The cookies used in the Application and the Website are divided into the following categories:

  • Functional cookies: These cookies are required for basic website functions and are therefore always enabled. They include cookies that allow our App and Website to “remember” you when you browse, during a single visit or, if you request it, from one visit to another. They allow “Shopping Cart” and “Checkout” features to be available and assist with security and regulatory compliance issues.
  • Performance cookies: These cookies allow us to improve the operation of the App and our Website through tracking usage. In some cases, these cookies improve the speed at which we can process your requests and allow us to remember your preferences on profiles, websites, and so on. Rejecting these cookies may result in insufficient personalization of recommendations for you and poor website performance.
  • Social media and advertising cookies: Social media cookies offer you the ability to connect to the social media networks you use and share content from the App and our Website on social media. Ad (third-party) cookies collect information to help better personalize ads according to your interests and preferences, both on our App and Website and others. In some cases, these cookies involve the processing of your personal data. Rejecting these cookies may result in the display of ads that are not as relevant to you or the inability to effectively connect to social media and/or the inability to share content from you on social media.

For a complete and up-to-date summary of all third parties that have access to the web browser you use (through the Application and/or the Company’s Website), we recommend that you install a plugin specifically designed for this purpose. You can also enable a notification to be sent to you from your mobile phone, tablet, or computer each time cookies are sent, or you can choose to disable all cookies. This is done through the web browser settings on each web browser and device you use. Since every web browser is different, we recommend that you refer to the Help menu of the web browser you are using to find out the right way to modify your cookies. If you disable cookies, you may not be able to access many of the features that make our App and our Website more effective, and we make you aware that some of our services may not function properly.

Managing cookies
You can change your browser settings to delete cookies already stored while using the Application and/or our Website and not accept new cookies. To learn more about this, visit the help pages of your device’s browser. Please note that disabling cookies may limit the services we can provide you and may affect your experience using the Application and our Website.

11) Policy Amendment / Update
The Company may revise, supplement, and/or modify this Policy within the framework of the applicable legislative and regulatory provisions, which will always be available in the “phind” Application and on its official website https://phindapp.com/. If we make material changes to the way we process your personal data, we will send you prior notice or, where required by law, request your consent to implement such changes.

Opting Out of Marketing Communications
If you have a profile/account on our “phind” App, you may opt out of receiving marketing communications from the Company by modifying your preferences in the relevant section. Alternatively, you may contact us.