4. PRIVACY POLICY

Data Controller of the personal data under processing in the context of the Loyalty Program “Rewards for Life” and of the issue of a member’s card “Rewards for Life” is the Company under the name «WELLNESS MARKET SINGLE MEMBER SOCIETE ANONYME» and the distinctive title «WELLNESS MARKET S-M SA», a member of FOURLIS Group, with TIN:801835574, registered with the Athens Tax Office for SAs, with G.C.R. No.164239301000, engaged in the «Import and Trade of Packaged Food Supplements, Pharmaceutical Products and Cosmetics» (hereinafter referred to as the “Company” or “WELLNESS MARKET S-M SA”). The Company’s seat is located in Kifissia Attiki, Ermou str. 25, PC: 14564, tel: 2106293860, e-mail: info@hollandandbarrett.gr.

4.1 Which Personal Data the Company is collecting and for what purposes:

The Company collects directly from you the data you fill in the Rewards for Life Loyalty Program registration form. Specifically, the personal data that each member must provide to register for the Program are: Mobile phone number, first name, surname, and optionally, if the member wishes to receive special offers and gifts, the date of birth and the name day. In case the registration takes place in a physical HOLLAND & BARRETT store, the contact e-mail is also included in the optional information.

The Company also collects data generated from the use of the Rewards for Life Loyalty card and from the member’s purchases, such as e.g. the categories of the products that the member buys.   

The member is informed that the Company does not collect or require the member to share personal data of a special category (sensitive personal data) for the needs of the Rewards for Life membership card. 

The Company processes the above data as well as the data of the user’s account in the e-shop, in case of consolidation of the Loyalty Card “Rewards for Life” with the user’s account for the following purposes:

1. Implementation of the terms of the Loyalty Program “Rewards for Life”;
2. Communication of general or special offers or/and gifts to the member and information about the Company’s products and services;
3. Provision of the Card’s Rewards and Benefits and analysis and research of the purchasing trend of its customers (product categories selected, visitation in the physical stores and the e-shop of the Company, product categories selected by the Customers, response to the general and specified offers etc.) so that the management of the clientele of WELLNESS MARKET S-M SA is improved and the provision of products and services better matching its customer base is enhanced;
4. Fulfillment of WELLNESS MARKET S-M SA’s obligation under applicable law, such as when the relevant data are requested from the tax authorities in the context of tax audits or for the service of its obligations and legitimate interests, e.g in the event of pending cases before regulatory, administrative, or judicial authorities and for the assurance that the member is an adult natural person and resident in Greece.

4.2 Legal Basis for Processing and Data Updating:

4.2.a. For the processing of the data of the members of the Loyalty Program “Rewards for Life”, WELLNESS MARKET S-M SA relies on the following legal bases:

• Performance of a Contract: In order to achieve the purposes of this contract and the Rewards for Life card, i.e. a)the member’s participation in the Program by registration and analysis of the member’s purchases and rewarding with points and benefits/rewards from their purchases; b)informing the member about special offers and privileged services as well as c)the general analysis of the general purchasing trend of the Program’s members, it is necessary to process the personal data provided by the member during their registration in the Rewards for Life Program and the data generated by their transactions.
• Legitimate Interests: WELLNESS MARKET S-M SA reserves the right to process the members’ personal data in order to improve its services and the management of its clientele, to promote its products, as well as for the detection of a fraud or misuse of the member’s card attempt, any cooperation with judicial and regulatory authorities, and also for the safeguarding and support of the general legitimate interests of WELLNESS MARKET S-M SA.

WELLNESS MARKET S-M SA also reserves the right of regularly informing the member by phone call, e-mail, mobile SMS/ Viber message or by any other appropriate means of communication to be selected, to the member’s contact details, duly obtained, in the context of registration in the Loyalty Program “Rewards for Life”, about its products and services in the context of their transactional relationship (article 11 par. 3 of L.3471/2006) and provided the member has not objected (opt-out) to this communication. This information may include promotional and specified information about its products, special or/and general offers, promotional activities, and competitions. Furthermore, WELLNESS MARKET S-M SA may communicate with the member via SMS services such as SMS, Viber etc. for reasons of better communication with the members and control of the communication cost.

The members have the right and obligation to keep their personal information up to date and/ or request the change of the means to be used by WELLNESS MARKET S-M SA for the purpose of informing them or/and to request the termination of the commercial communication:

a) via their account in www.hollandandbarrett.gr in the section «Rewards for life» by selecting the field “Management of Communication Means”

b) via the contact form of www.hollandandbarrett.gr

c) by sending an email to the e-mail address: info@hollandandbarrett.gr as well as

d) by a phone call to the number 2106293860

For technical reasons and, since they have objected to the commercial communication of WELLNESS MARKET S-M SA, they will not be eligible to receive information and promotional messages, as well as offers for the members. It is clarified that WELLNESS MARKET S-M SA will continue to use the above communication channels for the non-commercial communication with the member to whom this communication concerns, in particular, the use of such member’s card and the present terms and conditions. 

4.2.b. The member has the right but also the obligation to access, correct and update their personal data, and is obliged to promptly notify the Company of any change in them.

Any change of the member’s personal data can be made:

1. a) by email addressed to info@hollandandbarrett.gr
   b) by a phone call to 2106293860 or
   c) provided the member is also a registered user in the e-shop or is going to be registered on a later date, via the member’s account in the section “My personal details».

Given, in fact, that the mobile phone number constitutes the member’s identification method for the use of the Rewards for Life card, WELLNESS MARKET S-M SA shall bear no responsibility in the event that the member does not notify the Company beforehand of the change in their mobile phone number. In case of any change, especially in the mobile phone number, which the member has stated at their registration in the Rewards for Life Loyalty Program or later, the member’s mobile phone number will be re-confirmed via One-Time-Password (OTP) that the member will receive, in order to be verified that the number belongs to the said member.

4.3 Recipients of Personal Data

For the data necessary to serve each of the above processing purposes and within the scope of the responsibilities of each recipient, the recipients of the member’s data may be:

1. The responsible workers of WELLNESS MARKET S-M SA.
2. The tax, audit, judicial, regulatory, etc. authorities in case of a relevant audit.
3. The company under the name «MENA FRANCHISE PCC», which provides CRM services, and has undertaken among other things, the registration, updating, and maintenance of the database with the members’ data, acting as a processor on behalf of «WELLNESS MARKET S-M SA» and in accordance with the instructions and the written directions of the latter or/and any other company that is going to provide in the future to WELLNESS MARKET S-M SA the same services in replacement or in collaboration with the above company. 
4. to the extent that this is appropriate for the fulfillment of our contractual obligations, in order to better serve you and to satisfy your requests, personal data may be transmitted to providers cooperating with the Company, such as companies providing legal, consulting and auditing services, IT companies, companies that provide internet services, or other services necessary for the operation of the website and the implementation of the company’s services.

Upon registration and processing of the member’s personal data, the workers and agents of WELLNESS MARKET S-M SA as well as any processors acting on its behalf shall fully comply with the provisions of the European General Data Protection Regulation  2016/679 as well as with the applicable Greek legislation and case-law on the protection of personal data, shall be contractually bound to respect and fulfill their respective obligations and shall not be allowed to use the personal data for their own commercial or other purposes, but only on behalf of WELLNESS MARKET S-M SA on the basis of specific contractual commitments and directions provided to them and for the purposes stated herein. 

4.4 Rights of the Data Subject:

Every member, as a data subject, may at any time exercise their rights to their personal data processed by the Company in the context of the Loyalty Card “Rewards for Life”, as these are provided for in the EU-General Data Protection Regulation No. 679/2016, (in particular, in Articles 12 to 23 thereof) and the national legislation. More specifically: 

1. the right to be informed and to access their personal data
2. the right to limit the processing of their data
3. the right to correct or erase part of or the entire personal data of any member
4. the right to object, that is to raise objections against the processing of their personal data and
5. the right to portability of their data, that is to request the transmission of their personal data or/and their transfer to another data controller using the format to be indicated by the competent supervisory authority.

The above-mentioned rights can be exercised by the member as follows:

• by submitting a relevant request to the e-mail address: dpo@fourlis.gr
• by a written letter to WELLNESS MARKET S-M SA to be posted to the address: Ermou 25, Kifissia, PC: 14564 (c/o DPO).

WELLNESS MARKET S-M SA will take any possible measure to satisfy the member’s request within one (1) month from the date of its valid submission and, in the event that more time is required it will inform the member accordingly. In this case, the member is informed that it is possible that some of their minimum necessary personal data will be kept, to safeguard the legitimate interests of WELLNESS MARKET S-M SA. It is clarified that, in order for the exercise of the above rights to be considered valid, the identification of the member may be requested, in order to ensure that the personal data for which any of the above actions are requested actually belong to the member/natural person requesting the specific action. 

In addition, the member may request at any time that the Company terminates sending commercial communication to one of or all their contact details (SMS to their mobile phones or Viber message to their mobile phones):  

a) via their account in www.hollandandbarrett.gr in the section «Rewards for life» by selecting the field «Management of communication means»

b) via the contact form uploaded in: www.hollandandbarrett.gr

c) by sending an email to the e-mail address: info@hollandandbarrett.gr as well as

d) by a phone call to the number 2106293860.

The member should also be aware that, due to the nature of the operation of the Loyalty Program «Rewards for Life», any possible exercise of any of the above rights and, in particular, the right to object or to request the limitation of the processing and the erasure of the member’s data, partly or in whole, will also result in the termination of the present contractual relationship, and therefore of the member’s participation in the Loyalty Program “Rewards for Life” and in the erasure of the points that the member has collected within thirty (30) days from the submission of the relevant request, because without the processing of the member’s data the Rewards Loyalty Program cannot work.

For any information regarding their personal data as well as their processing and protection, the member may address the Data Protection Officer (DPO) of WELLNESS MARKET S-M by email to dpo@fourlis.gr, and provided the member considers that they are not satisfied from the actions and steps of WELLNESS MARKET S-M SA, they shall be informed that they have a right to file a complaint with the Data Protection Authority (address: Kifisias str. 1-3, P.C. 115 23 Athens) by completing and submitting the electronic form to the link https://www.dpa.gr/el/polites/katagelia_stin_arxi. 

4.5 Personal Data Retention Time:

The Company will retain the member’s personal data until the member cancels the membership card “Rewards For Life”. Nevertheless some necessary personal data relating to the member’s transactions with WELLNESS MARKET S-M SA, as well as the member’s declarations as regards the processing of their data may continue to be retained as information about the member in the systems of WELLNESS MARKET S-M SA, in order to ensure that we have evidence of the legality of the processing of the member’s data by our Company “WELLNESS MARKET S-M SA” and to safeguard the members’ legal claims.

Nevertheless, WELLNESS MARKET S-M SA shall keep the member’s personal data for thirty (30) days from the date of the member’s deletion. The member, however, shall be informed that even after the lapse of these 30 days, WELLNESS MARKET S-M SA will keep the tax data of the member’s purchases, whereas some basic member’s data will be retained and will continue to be kept in the Company’s records for the purpose of safeguarding the legality of their processing (e.g. the member’s mobile phone number and e-mail address in an encrypted format, the date of registration and deletion from the Loyalty Program), so that the legitimate interests of WELLNESS MARKET S-M SA are safeguarded.

The data collected due to your communication with WELLNESS MARKET S-M SA, either through the online contact form in www.hollandandbarrett.gr, or by email or by phone call, shall be kept by the Company’s Customer Service Department and anonymized nine (9) months from the date of communication.  

4.6 Technical and Organisational Protection Measures:

WELLNESS MARKET S-M SA, the processors acting on its behalf and its agents/  fulfillment assistants apply and implement the appropriate technical and organisational measures for, as far as possible, the best protection of personal data against accidental or unlawful destruction or loss, alteration, unlawful disclosure or access to them and in general their unlawful processing (including remote access) as well as to ensure the possibility of restoring availability and access to them.

These measures aim to ensure a level of security that corresponds to the risk that the specific data may face, always taking into account the type and criticality of the data, the technical capabilities of WELLNESS MARKET S-M SA and of its partners, the development of technology, the cost of implementation and the nature, scope, context and the purposes of each specific processing, while at the same time implementing procedures for the regular testing, assessment and evaluation of the effectiveness of these technical and organizational measures.

In any case, WELLNESS MARKET S-M SA, the processors acting on its behalf and its agents/ fulfillment assistants are contractually bound to maintain the confidentiality of the members’ personal data and not to share it or allow access to it to any third party without prior notification of each member, except in cases expressly provided by law.