ATHLON takes care to collect only the absolutely necessary Personal Data, which are appropriate and clear for the intended purpose. This data includes the following:

a. Data when creating an X user account and when connecting a User to the Website and/or the Application

To create a User account on the Website and/or the Application, the user is requested to enter his/ her name , email address and a password to the service ( login password ). In order to connect the User to the Website and/or the Application, the user is asked for his email address and his password to the service ( login password ). In case of connection of the User using the account of a third party provider (e.g. Facebook, Google +), the corresponding username , any e- mail and other connection details, such as profile photo, will be used .

b. Data in the User Profile
Each User’s profile contains data related to their name, email address , service access code ( login password ) and the registration date. You can optionally state your gender, height, home address and year of birth.

c. Data during your communication with ATHLON
When you communicate with ATHLON we collect notes from our conversations with you, details of any complaints or comments you make and how and when you communicated with us.

d. Data while browsing our Website
During your browsing on our Website and after downloading and installing the Application, we collect and process data related to the interests and preferences of users, with the aim of improving the experience of each user based on his preferences for products and services within the environment of the APPLICATION . With the above process, ATHLON has the ability to add and customize discount coupons (COUPONS) to products and services of the PROVIDERS and personalize goals and challenges that users can set or participate in in order to receive additional reward points (MOTIONS). We collect data from the use of the application, such as the number of MOTIONS, their input and output history, the performance and statistics of the users’ physical activity and their participation in competitions and challenges. We also collect data regarding the COUPONS selected/purchased by users by category and PROVIDER, marked as Favorites and available for redemption by users, their purchase frequency and flow, their (physical and online) redemption stores and dates expiry of the purchased products and services of the Company. In addition, we collect technical information about your computer, device, and browser, including possibly your IP address, browser type, and other software or hardware information, as well as the web pages you view when you visit our services. . For the information collected by the use of cookies in your browser, read the Cookies Policy (if we also put a Cookies Policy)

e. Data to prove your age and identity
In order to transact with ATHLON and to prove your age or identity, when required by law, we may ask you for a copy of your ID or passport and collect data relating to your full name, residential or residential address , your date of birth as well as your facial image (photo), while if you provide a passport, the data will also include your place of birth, gender and nationality.

f. Data when you browse websites operated by unaffiliated companies
The ATHLON Website may link to websites , including social networking sites , operated by unaffiliated companies and may serve advertisements or offer content, functionality, games, newsletters, contests or applications developed and maintained by unaffiliated companies. ATHLON is not responsible for the privacy practices of unaffiliated companies, and once you leave ATHLON ‘s services or click on an advertisement you should review the other service’s applicable Privacy Policy.

The processing of personal data consists of the collection, registration, organization, structure, storage, alteration, retrieval, information search, use, transmission, limitation or deletion of personal data that have come or will come to ATHLON’s knowledge in the context of transactions your relationship with her.

ATHLON processes personal data that you have submitted or are about to submit to ATHLON and which are necessary for the initiation, maintenance and execution of your business relationships with ATHLON , existing or future, depending on the services provided and the its applicable procedures and policies. The personal data you provide to ATHLON must be complete and accurate and must be updated with your care immediately, in any case of change or whenever deemed necessary by ATHLON to maintain your business relationships or to fulfill an obligation of ATHLON that derives from the law and the applicable regulatory provisions.

ATHLON does not process personal data relating to your racial or ethnic origin, your political opinions, your religious beliefs or your membership in a trade union, as well as data concerning your sex life, sexual orientation or criminal record your background.

The processing of personal data of minors is carried out on the condition of the prior consent of the parents or those exercising their parental care, unless otherwise stipulated by law. For the purposes of this, minors are considered persons who have not reached the age of 18.

The processing of your data is carried out either by the specially authorized staff of ATHLON , or through IT systems and electronic devices from ATHLON and exceptionally by third parties, who, having contractually committed to maintaining confidentiality and protecting your data, carry out work that are necessary to achieve the purposes strictly related to the use of our Website and/or Application and the provision of our services through our Website and/or Application.

The collection and processing of your above personal data by ATHLON is necessary for the initiation, execution and maintenance of business relations between us. Any objection by you to the provision or processing of your personal data may lead to the impossibility of starting or continuing your cooperation with ATHLON (e.g. refusal to process and use the e-mail address makes it impossible to create a User account).

We collect, process and use your personal data through our Website and/or Application for the purposes of the services provided by ATHLON and in particular for:

a. the initiation, servicing, support and monitoring of the business relationships between us and the management of our services provided,

b. compliance with the legal obligations imposed by the applicable legislation and regulatory framework, e.g. tax legislation, e-commerce directive, ATHLON ‘s response to requests from competent government authorities, exchange of data with judicial authorities following the issuance of a court order, sending communications required by law or necessary to inform you of changes in the services provided , e.g. privacy policy modification updates, provision of additional services.

c. the operation, improvement and maintenance of our business activity and services, the control, development and adaptation of our systems and services to your preferences and choices regarding the services we provide you.

d. the protection and defense of the legal rights and legal interests of ATHLON , which, indicatively, are related to: i . asserting its legal claims before the competent judicial authorities or other out-of-court/alternative dispute resolution bodies , ii. the prevention of fraud and other criminal acts, iii. the evaluation and optimization of security procedures and information systems. If we detect any criminal activity or alleged criminal activity through suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting illegal acts. Our goal is to protect our customers, employees and partners from criminal activities.

e. the completion of a corporate transaction, such as indicatively a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of the activities, assets or stocks of the business.

f. sending, with your prior consent, offers, promotions and other commercial communications ( email marketing communications ) and newsletters related to ATHLON services . In these cases, however, you will be able to unsubscribe from the recipient list by clicking on the relevant link that we provide in each of our emails or via email at info @ athlonapp , gr.

g. customer service, sending responses to customer requests, questions, complaints or complaints regarding services offered by ATHLON , conducting evaluation and satisfaction surveys of our customers in order to be able to improve our services. We do this based on our contractual obligations to you, our legal obligations and our legitimate interests, so that we can provide you with the best possible service and be able to improve our services based on your own personal experience.

h. participating in contests conducted by ATHLON , in case you agree to participate, to notify you if you are the winner of the contest and to deliver your prize.

Data protection legislation sets out various reasons why a natural or legal person (Data Controller) may collect and process your personal data.

Article 6 par. 1 item a) of the GDPR acts as a legal basis for the processing activities, for which we obtain your consent for a specific processing purpose.

Article 6 par. 1 item b of the GDPR states that personal data may be processed for the performance of a contract. Also, this provision applies to any processing activity that is necessary for carrying out activities during the pre-contractual stage.

Article 6 par. 1 item c) of the GDPR applies in cases where we are bound by an obligation imposed by law, which requires the processing of personal data.

ATHLON Website and/or Application and for the conclusion and execution of contracts

To provide services from the ATHLON Website and/or Application , you register and provide us with your personal data. This data is entered in a data entry form and stored by us. The registration is carried out for the execution of a contract or for carrying out activities during the pre-contractual stage and consequently, it is based on article 6 par. 1 item . II of the GDPR. For the conclusion and execution of contracts, we collect, process and use name, surname, email address , profession , telephone number, postal address, postal code, city, tax registration number. Particularly, ATHLON processes users’ personal data in order to provide them with all the necessary functions of the APPLICATION (e.g. conversion of steps into MOTIONS, purchase and redemption of vouchers, physical activity statistics, etc.). Consequently, the processing of the data is considered necessary for the operation of the APPLICATION, and the user’s consent to the processing of this data is provided by his agreement/declaration that he wishes to use ATHLON’s services.

Data that we are required to store in accordance with our legal data retention obligations will be retained for a maximum period of 20 years.

Sending information about our services, special offers and newsletters

The sending of information, to the email address you provide us, about our services, special offers, promotions, customer service and purchase surveys on the Website or our Application and newsletters , will be only with your prior consent or as permitted by law. Your consent is governed by article 6 par. 1 item . a’ and article 7 of the GDPR.

Contact, registration on the Website and/or Application

When you communicate with us via e-mail or via the contact form to submit requests or questions, register on the Website and/or the Application, your personal data will be processed based on article 6 par. 1 item . b and f of the GDPR, i.e. for the execution of the contract between us and to properly handle your requests, complaints and questions, in accordance with our legal interests. The communication will be recorded in order to be able to prove the communication in accordance with the applicable law. The data collected in relation to the above will be deleted by us after the discussion in question has been completed and the matter in question has been finally resolved.

Data processing due to our compliance with a legal obligation, for reasons of security, execution of orders from public authorities and our legal defense

Based on article 6 par. 1 item c of the GDPR, we process your personal data to comply with our legal obligations, such as for example our compliance with tax obligations or with obligations arising from consumer protection legislation ( law 2251/1994), but also when required to share information about your transactions with us to the tax authorities, Also, we are obliged by law to manage and respond to your requests, regarding the protection of your personal data.

Based on article 6 par. 1 item f of the GDPR, we use and store your personal data and technical information, as long as it is necessary to prevent or investigate malicious use or other illegal behavior in the context of the operation of our Website and Application, as well as for the smooth operation and security of our systems and to send satisfaction surveys and other promotional communications to our users, e.g. in order to maintain the security of data in the event of attacks on our information technology systems, to combat specific incidents concerning in particular bookings made through the ATHLON Website and Application that are considered suspicious for fraud, unauthorized use or theft of a bank card, etc. .

In addition, we may take the above actions pursuant to the orders of public authorities or other governmental and regulatory authority or courts, to the extent that we are required to act in this way by law, and also in order to protect our rights and interests and to have the possibility of our legal defense.

We inform you that for the proper functioning of the Website and the Application and the services provided, the measurement of efficiency, the extraction of statistical data, the provision of personalized services and content (including advertisements) relevant to the preferences and interests of users, on the Website and our Application, the technology of cookies is used and exploited . The placement of cookies on the User’s device is defined by the browser settings . If the User has allowed cookies to be placed on his computer or device, during the visit and browsing of the Website and/or the use of the Application and when interacting with certain functions or content of the Website and/or the Application, upon relevant prior information and consent from the User, a unique online ID ( guest id) will be assigned to him and a corresponding cookie ID will be placed on his computer or device, which will identify him (but without being able to to be otherwise identified) every time he visits the Website or uses the Application. In case of not providing the relevant consent and consequently not providing the User with a corresponding online ID, the use and browsing experience of the Website and the use of the Application will be limited. The User may at any time opt-out, withdraw consent and request the deletion of said online identifier for the future. More extensive information on the use of cookies and how to prevent the installation of cookies on the User’s computer / device accessing the Website and/or the Application is provided in the Policy on the Use of Cookies.

Access to your Data is given to the absolutely necessary ATHLON personnel , within the scope of their competences, who are bound by confidentiality and the companies cooperating with us or third party service providers who process your Data as Processors on our behalf and in accordance with our orders, in the context of the proper execution and fulfillment of their contractual obligations.

ATHLON does not transmit or disclose your personal data to third parties, unless it is for :

a) Businesses (domestic and foreign) that serve or support ATHLON ‘s services to which it has delegated, in part or in whole, the processing of your personal data on behalf of it and which have undertaken towards ATHLON an obligation of confidentiality in framework of a contractual relationship between them, which determines the object, the purpose, the duration of the processing, the type of personal data processed and the rights of ATHLON [( indicatively, cloud service providers are mentioned (hosting, management and maintenance of our data ), IT services, newsletter sending services via email).

b) Transmission required for the initiation of a business relationship or the performance of a contract or for the collection of ATHLON ‘s claims in the event of non-fulfillment of your obligations under a contract concluded with ATHLON (e.g. transmission to cooperating lawyers, law firms and bailiffs, notaries, engineers and valuers).

c) Transmission or disclosure to service providers of analysis and performance measurement of our Application such as Google.

d) Transmission or disclosure to data network service providers for the interconnection of our infrastructures with the internet.

e) Transmission or notification to partner stores (PROVIDERS) for the processing of COUPON redemption of users in the “SHOP” environment of the ATHLON Application or settlement of any question, complaint or comment.

f) Transmission or disclosure, which is required by the applicable regulatory, legislative and generally regulatory framework or court decision (e.g. transmission to judicial authorities, tax authorities).

g) To other third parties: i . to prevent illegal uses of our Website and/or App or violations of our Website and/or App Terms of Use and Policies, ii. for our own protection against third party claims and for the assertion and exercise of our rights and interests, iii . to assist in the prevention or investigation of criminal activity.

h) To other third parties when you yourself have given your consent.
ATHLON has legally ensured that the processors on its behalf will maintain confidentiality, will not send your data to third parties without ATHLON ‘s permission , will meet the conditions and provide sufficient assurances for the implementation of appropriate technical and organizational measures and will comply with the legal framework for the protection of personal data and in particular Regulation 2016/679 EU (GDPR), so that the processing of your personal data ensures the protection of your rights.
In the context of using analytics and advertising tools for businesses, provided by Meta Platforms Ireland Ltd. _ (Facebook Business Tools ), we act as Joint Controllers together with Meta Platforms Ireland Ltd , also in accordance with the data sharing agreement , which – among other things – defines our compliance obligations, according to the GDPR, in terms of joint processing. The Meta Platforms Ireland is responsible for meeting your requests in accordance with Articles 15-20 GDPR, in relation to personal data stored by Meta Platforms Ireland after joint processing. You can find more information in Meta ‘s Privacy Policy Platforms Ireland .
When we share your data with third parties: i . we provide only the information needed to perform their specific services, ii . they can only use your data for the precise purposes we set out in our contract with them, iii . we work closely with them to ensure that your privacy is respected and protected at all times, iv . if we stop using their services, any of the data they hold will be deleted or anonymized.
Apart from the above, the personal data of the Users are not disclosed and are not shared with third parties and are not exploited in any way. To avoid misunderstandings, it is clarified that the above does not include the content and data that the User chooses to make publicly available on the Website and/or the Application or chooses to share on social media services and generally through third-party applications.

We process and store your personal data only for as long as is necessary to fulfill the purposes stated in this Privacy Policy or until you withdraw your consent and request its deletion (if this happens earlier) or for as long as we are obliged to we store them in accordance with the law or the applicable regulations and in any case for a period of twenty (20) years from the last calendar day of the year of the end of your respective business relationship with the ATHLON . In this case, ATHLON will make every reasonable effort to limit the processing as much as possible. At the end of the retention period, or if someone requests the deletion of their account or data and no other dispute or legal interest arising from the use of ATHLON’s services is pending , your data will be deleted completely or anonymized, for example by aggregation with other data so that they can be used in a de-identified way for statistical analysis and business planning.

Personal data that we keep in the context of the execution of a service contract through the Website and/or the Application are stored for a maximum period of twenty (20) years.

Personal data that you have provided to us in order to contact us for the purpose of making a request, complaint or query is stored in our records until we can properly handle the relevant matter and respond to your request, complaint or query.

The personal data of unregistered users resulting from their interaction with ATHLON ‘s services is kept for a maximum period of two (2) years after their last visit to the Website or use of the ATHLON Application.

The browsing data of registered users collected by ATHLON through cookies is considered by ATHLON as personal data of a contractual nature, capable of proving the transaction and supporting any legal claims of ATHLON . For this reason, this data will be kept for a maximum of five (5) years by ATHLON . Then, this data will be deleted or completely anonymized (that is, it will no longer be considered personal data by law).

Also, the personal data you have provided to us for the purpose of sending newsletters, promotional material, targeted advertising and customer service surveys and customer satisfaction surveys, is stored by us until you decide to unsubscribe from the relevant list or withdraw your consent. In the event that you request to be removed, we will ensure that your information is promptly removed from the relevant list.

In the event of a legal dispute, your personal data will be kept until the end of the pending litigation, even if the above period of twenty (20) years is exceeded.

The security of your data is a priority for our Company. ATHLON in compliance with the current legislative framework has taken all the necessary actions, applying the appropriate administrative, technical, organizational and physical measures, taking into account the latest technology, the nature , scope, context and purpose of processing as well as the different possibilities and the seriousness of the risk, in terms of the rights and freedoms of individuals, for the legal observance, processing and safe keeping of the personal data file, committing to ensure and protect in every way the processing of personal data your data from loss, theft or leakage, alteration, transmission, disclosure, unauthorized use, modification or in any other way improper processing thereof. Indicatively, these measures include pseudonymisation and encryption, as well as the shielding of ATHLON ‘s systems to ensure the privacy, integrity, availability and reliability of the data, the timely restoration to a secure operational state in the event of a physical or technical event, as well as the continuous control and evaluation of the effectiveness of the technical and organizational measures, implemented to ensure uninterrupted safe processing.

In addition, the information used to identify you as an account user is two: the login password ( u sername ) and the personal secret security password ( password ). Each time you register your details, you are given access to your personal account. The specific process is achieved safely through encryption during their transfer to the internet and ATHLON ‘s servers . By the same standards, you are given the possibility to change your personal secret security code ( p assword ) as often as you wish. After entering the desired code, the new code is coded and stored in ATHLON ‘s systems . For this reason, you are the only one who knows your password and you are solely responsible for keeping your password confidential from third parties. These measures are reviewed and amended when deemed necessary.

ATHLON informs you that it has put in place the necessary procedures required to enable the exercise of your rights based on EU Regulation 2016/679 . As a Data Subject you have the following rights:

a. Right of access to personal data processed by ATHLON and receiving information about the processing being carried out.

b. Right to correct inaccurate and complete incomplete data (Article 16 GDPR). If you find that there is an error in your data you can submit a request to us to correct/ update it immediately (eg name correction or address change notification).

c. Right to delete your personal data (right to be forgotten) subject to ATHLON ‘s obligations and legal rights to retain them ( compliance with a legal obligation that imposes the processing, for reasons of public interest and for the establishment, exercise or support of legal claims) , for a specific period of time, based on the applicable legislative and regulatory provisions (Article 17 GDPR). You can ask ATHLON to delete your data if it is no longer necessary for the aforementioned processing purposes.

d. The right to limit the processing of your personal data if, either the accuracy thereof is disputed, or the processing is illegal, or the purpose of the processing has expired and provided that there is no legitimate reason for their retention (Article 18 GDPR). You can ask ATHLON to restrict the processing of your data pending the consideration of your objections to the processing.

e. Right to portability of your personal data to another controller, provided that the processing is based on your consent, in accordance with Article 6(1)(a) GDPR, or in the performance of a contract, in accordance with Article 6(1)(b) GDPR . The fulfillment of this right is subject to the legal rights and obligations of ATHLON to retain the data and fulfill its duty in the public interest (Article 20 GDPR). You can ask ATHLON to receive a human-readable copy of the data you have provided, or ask ATHLON to transmit it to another controller, in a structured, commonly used and machine-readable format . In the event that you request the direct sending of the data to another data controller, this will only be carried out if it is technically possible.

f. Right to object for reasons relating to your particular situation in the event that your personal data is processed for the fulfillment of a task performed in the public interest or in the exercise of public authority delegated to ATHLON or for the purposes of legitimate interests sought by ATHLON or a third party (Article 21 GDPR). In cases where ATHLON processes your personal data based on its legitimate interest, in accordance with Article 6(1)(f) GDPR, as well as when it processes your personal data for direct marketing purposes, you can ask it to stop processing for reasons related to your personal situation. ATHLON must then do so if it has no legitimate compelling reason to continue processing your personal data.

g. Right not to be subject to automated decision-making. You have the right not to be subject to a decision based solely on an automated decision-making process, such as profiling, if such a decision would have legal or other equally significant consequences for you.

h. Right to withdraw the given consent to the processing of your data. If you have given your consent to the collection, processing and use of your personal data, you can withdraw your consent at any time with future effect, without prejudice to the lawfulness of the processing based on it until its withdrawal. Regarding the use of technologies such as cookies , you can change your choice and withdraw your consent at any time by changing the options in the section of the Cookies Policy . Also, regarding your exact location through a browser , you can withdraw your consent directly from your browser ‘s privacy settings . With respect to authorizing access to your device’s exact location, you can disable this authorization and withdraw your consent directly from your device’s privacy settings.

i. Right to information in case of notification of correction or deletion of personal data or restriction of their processing to other recipients. Where you have exercised the right to correct or delete your personal data or restrict its processing, we will inform all recipients of your personal data that the said data has been corrected, deleted or is no longer subject to processing restrictions, unless it is not possible for us to do so or such updating requires a disproportionate effort.

For any question, clarification or request regarding the processing of your personal data or to exercise your rights, you can submit a relevant request by letter to the postal address of ATHLON ( ATHLON MOTION APP IKE, Katouni 28, PO Box 546 25, Thessaloniki or via email info@athlonapp.gr and ATHLON will look into it and get back to you as soon as possible .

Exceptionally:
a. if you wish to correct your data in your user account, you can log in to it and make any correction/change without the need to submit a request,
b. if you wish to withdraw your consent to send a newsletter, you can do so by selecting the link at the bottom of each newsletter ,
c. if you wish not to receive web push notifications from ATHLON you can disable the option from your browser settings.

To protect the confidentiality of your information, we will ask you to verify your identity before making any request under this Privacy Policy. If you have authorized a third party to make a request on your behalf, we will ask them to demonstrate that they have your permission to act for this purpose.
ATHLON responds to your requests free of charge without delay, and in any case within one (1) month of receiving your request. However, if your request is complex or there are a large number of your requests, we will inform you within the month if we need to obtain an extension of another two (2) months.
If your requests are manifestly unfounded or excessive, in particular due to their repetitive nature, ATHLON may impose a reasonable fee, taking into account the administrative costs of providing the information or carrying out the requested action, or refuse to proceed with the request.

You have the right to submit a complaint to the Personal Data Protection Authority (postal address Kifisias 1-3, PO Box 115 23, Athens, telephone center 210/ 6475600, fax 210/6475628, e-mail address (e- mail ) contact@dpa.gr , complaints @ dpa . gr , website www . dpa . gr ), if you consider that we have not adequately satisfied your request or that our processing of your Personal Data violates in any way the applicable national and regulatory legal framework for the protection of personal data data. ATHLON cooperates and will provide any necessary assistance requested by the Personal Data Protection Authority.

Website and / or Application may include links to other websites , which are not controlled by ATHLON , but by their owners (natural or legal persons). ATHLON is not responsible under any circumstances for the personal data protection measures taken by the other websites, which you can access through these links, nor for the Personal Data Protection Terms of its users/visitors on third-party websites.

ATHLON , based on its current policy for the protection of personal data and within the framework of the applicable legislative and regulatory framework, may revise or modify this Privacy Policy, which will always be updated and available on its website ( www.athlonapp.gr ).

The management and protection of your Personal Data is subject to the terms of this Privacy Policy. Applicable law is Greek law, as formulated in accordance with the General Regulation for the Protection of Personal Data 2016/679/EU, and in general the applicable national (L. 4624/2019) and European legislative and regulatory framework for the protection of personal data . Competent courts for any arising disputes related to your data are the Courts of Thessaloniki. From the use of the services of the ATHLON Website and Application, the knowledge and full and unreserved acceptance of the present terms and the user’s consent to the processing of personal data in accordance with the aforementioned are irrefutably presumed.