© COMPUTERINN All Rights Reserved
Privacy Policy - GDPR Compliance
1. Who We Are
We
are
a
single-owner
“Michail
Polimeneris/Computer
Inn”
establishment,
incorporated
under
the
laws
of
Greece
with
company
registration
number
17289/1989,
whose
registered office is at
20 Kallirrois str. 18539 Kallipolis
Piraeus, Greece, ("we", "us", or "our").
We
are
dedicated
to
establishing
a
trusting
relationship
with
our
Users,
based
on
respect
for
personal
identity
and
information
and
by
promoting
the
use
of
fair
information practices. We want to demonstrate our commitment to our Users' privacy and establish our Users' trust in our ability to protect their information.
2. This Privacy Policy
For residents of the EU, please note that this Privacy Policy has been updated in accordance with the requirements of EU General Data Protection Regulation ("GDPR").
We
provide
a
number
of
Products
and
Services
and
to
do
this
we
need
to
collect,
store,
use
and
disclose
a
wide
range
of
information.
This
Privacy
Policy
describes
how
we
and
our
authorized
business
partners,
affiliates
and
agents
process
information,
particularly
personal
data,
that
we
receive
from
you
and
others
through
your
use
of
our
website, apps, software, Services and other related technology ("Products"). This Privacy Policy sets out:
1
.
The information we collect.
2
.
How we use the information.
3
.
The legal bases we rely on to collect this information.
4
.
With whom we share information.
5
.
The choices available to Users regarding collection, use and distribution of the information.
6
.
The types of security procedures that are in place to protect information under our control.
7
.
A User's rights, how a User can contact us and update or correct any inaccuracies in their information that we collect.
Please
read
this
Privacy
Policy
carefully
so
that
you
understand
our
approach
and
practices
regarding
your
personal
data
and
other
information
and
how
we
treat
it.
Please
do
not
use
our
Products
and
Services
if
you
do
not
agree
with
the
ways
in
which
we
will
process
your
information.
We
appreciate
that
you
may
not
want
to
give
us
particular
information
about
you
but
please
be
aware
that
this
may
lead
to
us
not
being
able
to
provide
you
with
the
Products
or
Services
you
need
or
our
desired
level
of
customer Service.
PART B - INFORMATION COLLECTION
For the purpose of the GDPR, we are the controller of your personal data.
We
collect
information
from
our
Users
at
several
different
points
on
our
Products
and
Services,
in
accordance
with
the
Data
Protection
Legislation
and
other
applicable
data protection laws, strictly for the purposes necessary to our business and our Users' convenience.
All
information
will
be
obtained
fairly.
The
information
we
collect
will
be
adequate,
relevant
and
not
excessive
in
relation
to
the
purposes
for
which
it
was
obtained.
These
purposes include:
1. Registration
In
order
to
use
the
paid
subscription
version
of
our
Products
and
Services,
a
User
must
first
complete
the
Registration
Form
or
the
Contract.
During
registration,
a
User
is
required to provide contact information (such as name and email address). We may also collect the User's internet protocol (IP) address and hardware ID.
2. Ordering and Payment
We
may
use
a
distribution
partner(s)
and
a
trusted
third
party
payment
processor(s)
to
help
us
manage
ordering,
invoicing
and
processing
of
payments
for
our
Products
and
Services.
When
a
User
pays
for
a
subscription
to,
or
purchases,
one
of
our
Products
or
Services,
the
User
has
to
enter
information
through
an
online
order
form
or
to
provide
it
in
a
contract
sheet
or
mail.
A
User,
or
someone
in
the
User's
organization,
must
provide
contact
information
(such
as
name,
company
name,
telephone
number,
email,
and
billing
address)
and
financial
information
(such
as
credit
card
number
and
expiration
date).
We
and
our
distribution
partners
and
third-party
payment
processors
may
also
collect
the
User's
internet
protocol
(IP)
address
and
hardware
ID.
We
may
request
and
receive
from
the
distribution
partner
and
third
party
payment
processor a copy of the payment history between the User and us.
When
a
User
provides
their
information
to
our
distribution
partner
or
third
party
payment
processor,
use
of
the
User's
personal
data
is
governed
by
that
third
party's
terms
of
service
and
privacy
policy.
A
link
to
both
the
terms
of
Service
and
to
the
privacy
policy
is
provided
on
the
purchase
form.
A
User
must
agree
to
both
of
these
before they purchase or subscribe to our Products and Services acquired in conjunction with our distribution partners or third party payment processors.
We
may
receive
a
User's
financial
information
(such
as
the
credit
card
type,
expiration
date,
and
the
last
four
digits
of
the
credit
card
number)
from
the
third
party
payment
processor,
along
with
other
personal
data.
The
third
party
payment
processor
may
also
provide
us
with
unique
authentication
tokens
to
make
payment
requests. This information is used to make payment requests or to register the User for an auto-renewing subscription that requires automatic payments in the future.
3. Supplementation of Information
In
order
for
us
to
properly
fulfill
our
obligations
to
Users,
it
may
be
necessary
for
us
to
supplement
the
information
we
receive
with
information
from
third
party
sources.
For
example,
we
may
verify
the
billing
address
on
credit
card
transactions.
The
information
obtained
from
these
third
party
sources
is
maintained
by
us
in
a
manner
consistent with our Privacy Policy.
4. When Using Our Products and Services
We
collect
and
use
the
information
a
User
directly
provides
to
us
or
one
of
our
trusted
partners,
such
as
the
information
a
User
provides
when
they
access,
use
or
purchase
our
Products
and
Services,
information
about
how
a
User
accesses
and
uses
our
Products
and
Services,
and
information
a
User
provides
when
communicating
with
us,
including
for
customer
support.
We
may
also
process
and
analyse
information
from
the
scans
a
User
conducts
using
our
Products
and
Services
or
third
parties
tools and utilitirs, as further described in Section 5 (Information from Scans) below.
If
a
User
is
using
a
paid
subscription
Product
or
Service,
their
Username
and
Password
is
sent
and
received
during
each
communication
for
security,
authentication
and
verification purposes and to help resolve billing disputes. Payment card and other financial information is collected by us and our third party payment processors.
To
facilitate
renewal
or
reinstatement
of
a
subscription
we
or
our
third
party
payment
processors
may
also
retain
non-financial
contact
information
and
support
and
scan
logs for customers whose licenses have expired.
5. Information from Scans
Reports:
When
a
scan
for
viruses
and
internet
threats
is
started,
or
an
attack
is
attempted,
a
diagnostic
report
from
the
User's
system
will
be
transmitted
to
us.
We
collect
this information for the purposes of diagnosing existing threats, identifying new threats, providing customer support and for tracking the origin of malware infections.
Program
Classification
Information:
We
are
using
third
parties
utilities
in
order
to
identify
potentially
unwanted
or
harmful
files,
programs
and
software.
To
help
accomplish
this,
we
receive
and
analyse
data
on
unknown
executable
files
that
a
User
attempts
to
launch
or
access,
and
examine
files
and
programs
that
start
automatically or that are active on the User's system. Once we identify those files and programs, we are taking actions based on the estimation of the threat they pose.
6. Licensing, Versioning and Maintenance Server Log Files
Our
servers
use
log
files
to
analyse
trends,
administer
our
Products
and
Services,
track
the
different
locations
a
User
may
use
our
Products
and
Services
in
the
aggregate,
and
gather
broad
demographic
information
for
aggregate
use.
This
information
may
include
IP
addresses,
geolocation
information,
hardware
ID,
browser
type,
internet
Service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
7. Flash LSOs
We
may
use
Local
Shared
Objects
(LSOs),
such
as
Flash,
to
store
content
information
and
preferences.
Third
parties
with
whom
we
partner
to
provide
certain
features
on
our
website
or
to
display
advertising
based
upon
a
User's
web
browsing
activity
may
use
LSOs
such
as
Flash
to
collect
and
store
information.
Various
browsers
may
offer
their
own
management
tools
for
removing
HTML5
LSOs.
To
manage
Flash
LSOs,
please
visit
https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-
flash.html.
8. Cookies and Other Tracking Technologies
We
do
not
use
cookies,
beacons,
tags,
scripts
and
related
technologies
(collectively
called
"Cookies")
in
order
to
provide
our
Products
and
Services
to
you,
although
our
partners,
third
party
affiliates
and
service
providers
may
use.
By
accessing
or
using
our
Products
or
Services
you
consent
to
the
use
of
Cookies
in
the
manner
described
in
this Privacy Policy. Please do not use our Products or Services if you are not comfortable with the ways in which Cookies are used generally in nowadays IT&C.
What is a Cookie?
Cookies
are
small
text
files
sent
from
a
server
and
stored
to
a
User’s
computer
or
other
device.
When
a
User
visits
a
website
or
application
more
than
once,
the
browser
sends
Cookies
back
to
the
website
or
application,
allowing
the
website
or
application
to
recognise
the
User
and
remember
things
like
their
personalised
details
and
preferences. More information about Cookies and details of how to manage or disable them can be found on aboutcookies.org.
Do We Use Cookies?
No. We do not obtain information about your general internet usage by using Cookies that are normally stored on the hard drive of your computer or on other device.
Third Party Cookies
Some
Cookies
that
have
been
set
on
our
Services
may
not
be
related
to
or
controlled
by
us
and
may
originate
from
one
of
our
partners,
affiliates
or
service
providers.
We
do not control the use of these Cookies and cannot access them due to the way Cookies work, as Cookies can only be accessed by the party which originally set them.
You should check the applicable third party's website for more information about these Cookies.
How to Refuse the Use of Cookies
You
can
change
your
browser
or
application
settings
so
your
device
warns
you
each
time
a
Cookie
is
sent,
or
to
turn
off
all
Cookies.
Each
web
browser
or
application
is
different,
so
please
look
at
your
browser
or
application
"help"
menu
to
learn
how
to
modify
your
Cookies
preferences.
However,
if
you
disable
Cookies
you
will
not
have
access to certain features that may make your browsing smoother and some of internet sites may not be available to you.
9. Advertising
You
always
have
a
choice
as
to
whether
or
how
you
interact
with
an
advertisement
(for
example,
by
clicking
to
learn
more
about
an
offer).
We
may
place
ads
for
our
Products
on
other
Products
we
provide
or
on
various
third
party
websites
and
platforms,
and
as
a
result,
you
may
see
ads
for
our
Products
when
visiting
Google,
YouTube,
Facebook,
and/or
a
variety
of
other
websites
and
platforms.
We
may
ask
the
proprietors
of
these
websites/platforms
to
present
our
ads
to
particular
demographic
groups.
The
third
party
websites
and
platforms
may
use
information
they
already
have
about
the
User,
or
may
place
cookies
or
similar
tracking
technologies
in
the
User's
browser,
in
order
to
decide
what
ads
the
User
will
see,
including
potentially
our
ads.
If
a
User
has
questions
or
concerns
about
the
ads
they
see
on
any
of
these
third
party
websites/platforms
or
if
they
have
questions
generally
about
their
privacy
practices,
we
encourage
them
to
consult
the
privacy
policies
of
those sites or enquire with the proprietors of those sites.
PART C – INFORMATION USE
1. Information Use
Your personal data will be kept only for clear and legal purposes. All personal data will be processed fairly and in keeping with the purposes for which it was obtained.
We use your information for the following purposes:
•
providing our Products and Services to you;
•
etermining your suitability for our Products and Services, and for personalisation;
•
maintaining and improving our Products and Services, and developing new ones;
•
administering
and
managing
the
Products
and
Services
we
provide
to
you,
to
provide
customer
support,
to
authenticate
you
as
a
User,
to
charge
you
and
process
payment, investigate disputes and billing queries, collect any amounts you may owe us, and to fulfill orders for our Products and Services;
•
promoting
the
safety
and
security
of
our
Products
and
Services,
our
staff,
other
Users
and
members
of
the
public,
and
investigating
suspicious
activity
or
violations
of our policies;
•
providing you with information about our Products and Services and those of our related companies and affiliates;
•
conducting
surveys
(as
set
out
in
Part
E
(Third
Party
Links
and
Content))
and
analytics
to
enhance
and
improve
the
quality
of
the
Products
and
Services
we
offer;
and/or
•
as permitted or required by any law or regulation applicable to us or arising from your interaction with us.
Legal Bases
We
rely
on
a
number
of
legal
bases
to
collect,
use,
share,
and
otherwise
process
the
information
we
have
about
you
for
the
purposes
described
in
this
Privacy
Policy.
These legal bases include:
•
as is necessary to enable your use of our website, apps, software, Services and other Products;
•
where you have consented to the processing, which you may revoke at any time;
•
for us to comply with a legal obligation, a court order, or to exercise legal rights or defend legal claims;
•
when necessary to protect your vital interests, or those of others;
•
when necessary to ensure performance of a contract;
•
where you have made the information manifestly public;
•
where necessary in the public interest; and/or
•
where necessary for the purposes of our or a third party's legitimate interests,
Our legitimate interests
We process your information in furtherance of some or all of the following legitimate interests:
•
Keeping
the
Products
and
Services
safe
and
secure:
We
use
your
information
as
it
is
necessary
to
pursue
our
and
our
customers'
legitimate
interests
in
ensuring
our
Products
and
Services
are
secure,
such
as
by
implementing
and
enhancing
security
measures
and
protections,
protecting
against
security
breaches,
fraud,
and
spam.
•
Providing,
improving
and
developing
the
Products
and
Services:
We
use
your
information
to
provide
and
further
develop
the
Products
and
Services.
We
do
so
as
it
is necessary to pursue our legitimate interests of providing a secure offering to all our customers on a continuing basis.
•
Providing
seamless
Services
across
our
group
of
companies:
Where
the
Products
and
Services
require
the
engagement
of
our
affiliates,
subsidiaries
or
related
companies, we share your information with them to provide, administer and improve the Services and Products.
2. Customer Service
We
may
communicate
with
Users
to
assist
with
enquiries
and
to
provide
Users
with
better
customer
Service.
To
do
so,
we
may
reply
via
email,
in-app
message,
or
phone.
If
you
contact
us
directly
for
any
reason,
and
if
we
are
able
to
provide
support
or
Service
to
you,
we
will
use
the
information
you
have
provided
in
order
to
respond
to
you,
to assist with enquiries you have and to maintain our records.
3. Service Announcements
On
occasion
it
is
necessary
to
send
out
a
Service
related
announcement.
For
instance,
if
one
of
our
Products
or
Services
is
temporarily
suspended
for
maintenance
or
we
want
to
notify
you
about
changes
to
our
Products
and
Services,
we
might
send
Users
an
email
or
other
communication.
These
communications
are
not
promotional
in
nature.
4. Spam
Generally, spamming means the use of electronic messaging systems to send unsolicited messages. We have a zero tolerance policy for abuse through spamming.
PART D - INFORMATION SHARING WITH OTHERS
1. Sharing of Information
We
will
share
the
information
we
collect
from
you
with
third
parties
only
in
the
ways
that
are
described
in
this
Privacy
Policy.
We
do
not
sell
or
rent
your
personal
data
to
third parties.
The
information
we
collect
from
you
may
be
transferred
to
third
parties
in
connection
with
operating
our
business.
It
may
also
be
processed
by
these
third
parties
and/or
by
our
and
their
respective
employees
and
Service
providers.
We
will
take
steps
to
ensure
that
these
third
parties
will
only
process
data
in
accordance
with
our
instructions, and take appropriate security measures to protect your data.
By submitting your information, you agree to this transfer, storing or processing of your personal data by us.
We may disclose your information to the following third parties:
•
our related companies, subsidiaries, affiliates or our distribution or commercial partners and other businesses we work with;
•
our professional advisers in order for them to provide us with advice;
•
third
party
Service
providers,
such
as
our
payment
processors,
where
necessary
for
them
to
provide
us
with
Services
or
to
provide
Products
and
Services
that
you
have requested;
•
our
technology
providers,
including
those
which
host
your
data
on
our
behalf
and
co-provide
certain
auxiliary
or
complementary
IT
support
and
professional
Services to us; and/or
•
business
partners
and/or
possible
acquirers
or
investors
(and
our
and/or
their
advisors)
in
the
context
of
a
facilitating
or
implementing
a
business
re-organisation
or a transfer/sale of all or part of our assets or business.
Where
required
or
authorised
by
law,
we
reserve
the
right
to
release
personal
data
without
your
consent
and/or
without
consulting
you,
when
we
believe
that
this
is
appropriate
to
comply
with
our
legal
obligations,
to
protect
the
security
of
our
Products,
Services,
systems
and
related
technologies,
to
prevent
and
minimise
the
effects
of fraud, and otherwise to protect our legitimate interests and/or the legitimate interests of our staff, Users or members of the public.
2. International Data Transfers
Data
may
be
transferred
to
or
from
our
third
party
Service
providers
for
legitimate
purposes
as
described
in
this
Privacy
Policy.
This
may
include
the
transfer
of
data
to
other
jurisdictions
for
processing
at
a
destination
outside
the
European
Economic
Area
(EEA)
which
may
not
provide
the
same
level
of
protection
of
personal
data
as
within the EEA. By submitting your personal data or using our Products and Services, you agree to this transfer, storage and processing.
PART E - THIRD PARTY LINKS AND CONTENT
1. Links
When
using
our
Products
or
Services,
you
may
be
redirected
to
third
party
websites,
for
example,
to
our
payment
processor's
website
to
complete
your
payment.
Your
use
of
these
websites
and
any
associated
Services
will
be
subject
to
these
third
parties'
terms
of
use,
privacy
policies
and
cookie
policies.
Please
review
the
specific
privacy policy and terms of conditions of these websites, as we are not responsible for them.
2. Surveys
Periodically,
our
site
may
request
information
from
Users
via
surveys.
Participation
in
these
surveys
is
completely
voluntary
and
the
User
therefore
has
a
choice
whether
or
not
to
disclose
this
information.
The
requested
information
typically
includes
contact
information
(such
as
name
and
address),
and
demographic
information
(such
as
post
code
or
zip
code).
Survey
information
will
be
used
for
purposes
of
monitoring
or
improving
the
use
and
satisfaction
of
our
Products
and
Services.
Though
we
may
use an intermediary to conduct these surveys, they may not use customers' personal data for any secondary marketing purposes.
3. Blog
Our
website
may
offer
publicly
accessible
blogs.
Any
information
you
provide
in
these
areas
may
be
read,
collected,
and
used
by
others
who
access
them.
To
request
removal
of
your
personal
data
from
our
blogs
or
community
forum,
contact
us
at
the
address
shown
at
the
end
of
this
Privacy
Policy.
In
some
cases,
we
may
not
be
able
to remove your personal data, in which case we will let you know if we are unable to do so and why.
4. Social Media Widgets
Our
website
may
include
social
media
features,
such
as
a
Facebook
"Like"
button
and
widgets,
such
as
a
"Share
This"
button
or
interactive
mini-programs
that
run
on
our
site.
These
features
may
collect
your
IP
address,
which
page
you
are
visiting
on
our
site,
and
may
set
a
cookie
to
enable
the
feature
to
function
properly.
Social
media
features
and
widgets
are
either
hosted
by
a
third
party
or
hosted
directly
on
our
site.
Your
interactions
with
these
features
are
governed
by
the
privacy
policy
of
the
company providing it.
PART F – SECURITY AND THE PROTECTION OF YOUR INFORMATION
We
take
precautions
that
we
deem
to
be
reasonably
necessary
to
help
ensure
User
information
is
treated
securely
and
in
accordance
with
this
Privacy
Policy.
This
includes
encrypting
your
information
at
rest
using
256-bit
AES
encryption,
wherever
it
is
vital,
two
(2)
level
Entrance
Codes
with
operational
hierarchy
to
Apps
for
our
internal use (like Accounting and Reporting). We seek to ensure that we keep your personal data accurate and up-to-date.
When
our
registration/order
forms
ask
Users
to
enter
financial
information,
such
as
a
credit
card
number,
that
information
is
encrypted
and
is
protected
with
an
encryption
protocol.
Most
modern
web
browsers
should
indicate
when
a
User
is
on
a
secure
page,
for
example
some
web
browsers
show
a
locked
padlock
icon
at
the
bottom of the screen.
While
we
take
these
steps
to
maintain
the
security
of
your
information,
you
should
be
aware
of
the
many
information
security
risks
that
exist
and
take
appropriate
care
to
help
safeguard
your
information.
The
nature
of
the
internet
is
such
that
we
cannot
guarantee
the
security
of
the
information
you
transmit
to
us
electronically,
and
any
transmission
is
at
your
own
risk.
We
store
information
you
provide
to
us
on
secure
servers
and
deploy
appropriate
technical
and
organisational
security
measures
in
the
storage and disclosure of your personal data to try to prevent unauthorised access or loss.
If you pay for a subscription or contract to our Products and Services we also rely on you to maintain the security of your account with us.
If you have any questions about our security, you can contact us at the address shown at the end of this Privacy Policy.
PART G – SOME FINAL TERMS
1. Retention of Data
We
retain
your
personal
data
for
no
longer
than
is
necessary
with
regard
to
the
purposes
for
which
it
was
collected
or
lawfully
further
processed,
or
for
so
long
as
may
be
necessary
in
light
of
our
legal
or
statutory
obligations
(for
example,
as
may
be
required
to
comply
with
audit
requirements)
or
in
order
to
exercise
our
legal
rights
or
defend legal claims. We commit to undertaking periodic reviews of the personal data we hold to ensure personal data is not held for any longer than is necessary.
2. Your Rights and Subject Access Requests
You
have
rights
under
the
Data
Protection
Acts
1988
and
2003,
and,
from
25
May
2018,
the
General
Data
Protection
Regulation
(2016/679)
("Data
Protection
Legislation").
If
an
EU
resident,
you
have
the
right
to
obtain
confirmation
from
us
as
to
whether
or
not
your
personal
data
is
being
processed,
to
request
a
copy
of
your
information,
request
that
your
personal
data
is
updated,
corrected
or
that
any
inaccuracies
in
your
personal
data
are
deleted.
You
may
withdraw
your
consent
to
our
processing
of
your
personal
data
at
any
time.
You
can
access,
correct
or
delete
certain
personal
data
and
update
your
privacy
preferences
by
sending
an
email
to
Support@ComputerInn.gr
or by writing to us at “
Michail Polimeneris/Computer Inn,
20 Kallirrois str. 18539 Kallipolis
Piraeus, Greece
”.
Despite
this,
we
retain
the
right
to
collect,
process
and
maintain
information
provided
by
and
collected
about
you,
and
disclose
this
information
to
the
extent
required
to
comply with our reasonable business and legal obligations.
If
you
choose
not
to
provide
certain
information
to
us
or
if
you
withdraw
your
consent
to
our
processing
of
your
personal
data,
we
may
not
be
able
to
continue
to
provide
you with the Products or Services you require and/or it may affect our ability to better respond to your needs.
3. Notification of Changes to this Privacy Policy
From
time
to
time,
we
may
need
to
change
this
Privacy
Policy.
If
we
do
so,
we
will
post
an
updated
version
of
our
Privacy
Policy
on
our
website
and
it
will
apply
to
all
of
your
information
held
by
us
at
the
time.
We
may
notify
you
of
any
material
changes
by
an
in-app
message,
email
or
by
posting
a
notice
on
our
website.
Continued
use
of
our Products or Services indicates your acceptance of the changed Privacy Policy.
4. Definitions
Any capitalized terms not defined in this Privacy Policy have the meanings given to them in the Data Protection Legislation.
5. Contacting Us
If
you
have
any
queries,
comments
or
requests
about
this
Privacy
Policy
or
our
management
of
your
personal
data,
please
email
us
at
Support@ComputerInn.gr
or
write
to us at “
Michail Polimeneris/Computer Inn,
20 Kallirrois str. 18539 Kallipolis
Piraeus, Greece
”.
If
you
want
just
to
be
unsubscribed
from
our
Mail
IDs
Database,
please
send
a
message
to
GDPR@ComputerInn.gr
with
Subject
“REMOVE”
,
no
need
to
write
anything
else
in the body, without being forbidden to do so, if you wish.