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3. PERSONAL DATA PROTECTION POLICY
3.1 Legal Base for Processing, Provision of Information / Notification and Data Update
The company under the name “WAKAH TRADING LTD”, is responsible for the processing of personal data of the visitor/registered user and controls the processing of his data in the webpage of 
www.speakingroses.com.cy services.

 

WAKAH TRADING LTD informs the visitor/registered user-customer of the following, and the visitor/registered user-customer acknowledges that he/she is aware of the following:

3.1.a For the processing of his/her personal data as described below, WAKAH TRADING LTD relies on the following legal bases:


• Execution of the Agreement: In order for the purposes of this agreement to be satisfied, i.e. in order for the visitor/registered user-customer to conclude his orders in 
www.speakingroses.com.cy the processing of the personal data he gives upon his registration and submission of his order in the order registration form and the reporting of his transactions are necessary. Purpose of this basic processing of data is the completion of the certain order, the contact with the user-customer and the dispatch of informative messages relating to the stages required until the order is properly delivered, the provision of explanation in relation to the order, and in general the information about purchases made, the delivery of the order to the place of the user’s/  customer’s choice, the confirmation and identification of the user/customer in any necessary case and the notification about the available stock in the www.speakingroses.com.cy.

 

WAKAH TRADING LTD also reserves the right to inform the member regularly via a phone contact, by post, via e-mail, mobile SMS or through any other appropriate means of communication using the member’s contact details, duly obtained, in respect of the registration in www.speakingroses.com.cy for online purchase of its products and services under their transactional relationship (Law 112(I)/2004), and provided the member has not objected against this contact. This information may include information about its products or/and offers or/and competitions, the contact for survey purposes for the improvement of the products and services provided to its members as well as any other promotional actions of the Company and the service of similar purposes.


• Legal Interests: Any form of processing of personal data is necessary for the improvement of services provided by WAKAH TRADING LTD (processing of statistical and non-identifiable data), the detection of a fraud attempt or misuse by the member, as well as for ensuring the legal interests of WAKAH TRADING LTD.


• Approval-Consent: The registered user/customer is invited to give his specific, clear and free consent to the individualized analysis of the consumer behavior of the registered user-customer with the purpose of sending to him commercial communication details together with personalized offers about the products or the services of WAKAH TRADING LTD according to the preferences of the aforementioned user-customer with or without human intervention, so that the registered user-customer could receive individualized notifications and offers by WAKAH TRADING LTD, which shall better match his profile and preferences.

3.1.b. The member has the right but also the obligation to access, rectify and update his personal data, and he is obliged to notify as soon as possible WAKAH TRADING LTD of the following:
• any change of personal data provided upon his registration in the e-shop of WAKAH TRADING LTD for the better service of the member;
• for the members of LCDH Loyalty Program concluding purchases in the 
www.speakingroses.com.cy the terms of the Program apply.

3.2 Processing and category of personal data - Rights of visitors/ registered users
a) Personal Data Processing: WAKAH TRADING LTD shall process the personal data of the visitor/registered user-customer, as these are given by himself at the opening of his account and in his order in the data registration form, in order for the specific order be completed through our online store. The user/customer has the option to select 2 ways in order to complete an online order and to register his personal data:
1. As a guest/visitor: In this case the personal data of the visitor/customer shall be retained in the records of WAKAH TRADING LTD for thirty (30) days as of the closing and deliver of his specific order and the processing of these data shall only relate to the execution of the sale agreement remotely. The data, however, proving the conclusion of the transaction shall be retained for tax purposes (invoice statement).
2. As a registered user of the online store: In this case the customer/user has created a user’s account in our online store and his personal data shall be retained in the records of the company until he requests their deletion. Once per year WAKAH TRADING LTD shall request from the user/customer to confirm the accuracy of the data it maintains and to update them provided there are changes. The user/customer may at any time change or correct his data making a log-in into his account in 
www.speakingroses.com.cy (login) filling in his username and his password.

b) Personal Data Category More specifically, the personal data that every visitor/registered user/customer should provide in order for any transaction can be performed via the e-shop (
www.speakingroses.com.cy) of WAKAH TRADING LTD, and in order for orders of company products to be submitted, are the following:
• the full name (first name and surname) of the customer;
• the delivery address of the products;
• the charging address of the order (in case this is different from the delivery ad-dress);
• the invoicing data (in case an invoice payment has been selected);
• the number of a contact line;
• the e-mail of the customer.

The category of the personal data processed by WAKAH TRADING LTD according to the processing purpose is the following:
i. For the execution of the agreement (thus, in order for the visitor/registered user-customer to conclude his orders in 
www.speakingroses.com.cy):
• the full name (first name and surname);
• the delivery address of the products;
• the charging address of the order (in case this is different from the delivery ad-dress);
• the invoicing data (in case an invoice payment has been selected);
• the number of a contact line;
• the e-mail of the user/customer;
• products purchased;
• history of orders
The visitor/registered user is informed that the provision of his aforementioned obligatory personal data as well as his transactions data are necessary and constitute a requirement for the proper execution of the order agreement and the delivery of the products and services. For this reason, the consent of the user/customer to this specific processing is not required.
ii. For the analysis of the individualized consumer behavior of the registered user-customer with the purpose of sending to him commercial communication with personalized offers for the products or the services of WAKAH TRADING LTD, according to his preferences with or without human intervention so that the member can receive individualized notifications and offers from WAKAH TRADING LTD, which shall better match his profile and preferences, WAKAH TRADING LTD shall process additionally the following data of the member:
- Products bought via the online store: 
www.speakingroses.com.cy
- Frequency of Visits (Visitation Rate) to 
www.speakingroses.com.cy
- Products in the visitor’s/customer’s basket or in the wish list on the online store: 
www.speakingroses.com.cy
- Demographic data disclosed in the online store: 
www.speakingroses.com.cy
- Years of using the online store 
www.speakingroses.com.cy as a registered user-customer
- Participation in promotional activities/campaigns
- Expense made upon purchase in the online store: 
www.speakingroses.com.cy
- History of Orders in the online store: 
www.speakingroses.com.cy

iii. In case a delivery of the products to a third party different from the visitor/register user is requested, the latter acknowledges that he shall have full responsibility for the provision of information to and the full consent of the aforementioned third party, whom he appoints as a recipient, for the disclosure of his personal data to the company “WAKAH TRADING LTD”, only for the purpose of delivery to the third party, of the respective products, and undertakes full liability for any claims of this person (third party) against the company “WAKAH TRADING LTD”.

The credit card data are not stored in storage means of the company during the transaction but are registered directly in a safe environment of the partner company (JCC Payment Systems Ltd), which has undertaken the launching of the payment procedure by cards.

iv. The visitor but also the registered user-customer is also informed that in respect of the contact between him and WAKAH TRADING LTD, under the (Law112(I)/2004), WAKAH TRADING LTD is processing the contact details registered by him. Fur-thermore, when notifications about changes of the terms of use of 
www.speakingroses.com.cy are sent via SMS/viber/email etc. to the registered user-customer with a hyperlink (link), the IP address of his electronic device (mobile phone, tablet, computer, etc.) may be registered as a proof that the member has received the relevant information.

c) Data Recipients: As regards the data which are necessary for the pursuit of each and any of the above mentioned processing purposes and in respect of the responsibilities of each recipient, the recipients of data of the registered user/customer are or may be:
i. The responsible employees of WAKAH TRADING LTD;
ii. The tax authorities and the banking authorities in case of a relevant audit;
iii) External partners who provide internet services, orders storage and management, call centre services, courier service or group shipping of products, services for product establishment and services for the sales data analysis, internet service providers and e-commerce providers and call centres for customers service with whom WAKAH TRADING LTD collaborates, and who are subject to the special strict terms of personal data processing agreed with WAKAH TRADING LTD as Data Controller.
During the registration, access or/and processing of the personal data of the member, the workers and agents of WAKAH TRADING LTD fully comply with the provisions of the European General Regulation 2016/679 for Data Protection as well as with the applicable Cyprus legislation and case law regarding the personal data protection. WAKAH TRADING LTD requests from its workers, the maintenance providers of its webpage, as well as from its associates-third parties to take all necessary technical and organizational measures (including the appropriate policies and procedures, so that they can prevent the disclosure of the personal data of its visitors/registered users-customers, who process, possess and apply management procedures and data processing procedures in a way provided by law and protect them according to the GDPR).

d) Rights of the Data Subject:
 Each registered user-customer, as a data subject, may exercise at any time his rights, as prescribed in the General Data Protection Regulation 679/2016 EU and, particularly, in the articles 12 until 23 of GDPR and the national legislation, and more specifically:
i. the right to receive information and obtain access to the data processed by WAKAH TRADING LTD;
ii) the right to restriction of his data processing;
iii) the right of rectification or erasure of some or all (right to be forgotten) of his personal data;
iv) the right to object, that is to oppose the processing of his personal data, and
v) the right to data portability.

The member may exercise his aforementioned rights as follows:
Regarding the right/obligation of access and rectification of /completion the personal data, the company provides to the registered users-customers of 
www.speakingroses.com.cy the option to review, rectify/supplement their personal data through their personal account in www.speakingroses.com.cy in the menu “My information” and in the filed “Processing”.
Regarding the right of data portability, WAKAH TRADING LTD provides the option to registered users-customers of 
www.speakingroses.com.cy to obtain their personal data or/and transmit them to another data controller in the form indicated by the competent supervisory authority, submitting the relevant request to the e-mail address: info@speakingroses.com.cy.
The member is entitled to revoke his consent at any time and for any processing of his personal data performed under his consent, without affecting the legality of the processing based on the consent prior to the withdrawal of the consent. The revocation of the consent may be executed from his personal account in 
www.speakingroses.com.cy in the menu “My information”, and in the field “Processing” or by sending an e-mail to info@speakingroses.com.cy
In case of exercise of one of the above mentioned rights of the registered user/customer, WAKAH TRADING LTD shall take any possible measure for the satisfaction of the request within one (1) month as of its submission. In this case, the registered user-customer is informed that the least required information of his personal data shall be maintained in order for the company to secure its legal interests. The deletion of the registered user-customer of 
www.speakingroses.com.cy may be performed via email in the e-mail address: info@speakingroses.com.cy.

e) Term for the Retention of Personal Data: The data of the visitor user-customer shall be kept and processed by WAKAH TRADING LTD for a period of thirty (30) days as of the completion of his specific order.
The data of the registered user-customer shall be kept and processed by the company until the registered user-customer requests the deletion of his account or, for any data processing performed under his consent, until he declares the withdrawal of his consent for the purposes of provision of services of WAKAH TRADING LTD. Nevertheless, some required personal data relating to this transactions with WAKAH TRADING LTD as well as the information, consent and withdrawal of consent of the member for the processing of his data may be retained as information about the registered user-customer as a guaranteed proof of the lawful processing of his data by WAKAH TRADING LTD and for ensuring the legal claims of the parties.

f) Special Category Data: The member is informed that WAKAH TRADING LTD neither collects nor demands the disclosure of sensitive personal data (data of a special category) for the needs of 
www.speakingroses.com.cy.

g) Transparency Obligation: For any information regarding his data as well as their processing and protection the registered user-customer may address the Data Protection Officer of WAKAH TRADING LTD (Data Protection Officer) in the email 
info@speakingroses.com.cy and in the call line 25 101593 and provided that he considers his answer non-satisfactory, he is informed that he has the right to file an action before the competent supervisory authority (Data Protection Authority, 1 Iasonos str, 1082 Nicosia, commissionerdataprotection.gov.cy).

h) Technical and Organizational Protection Measures: WAKAH TRADING LTD, the data processors acting on behalf of WAKAH TRADING LTD and its agents/assistants for the performance of its duties apply the appropriate technical and organizational measures for the best possible protection of the personal data against any incidental or illegal destruction, damage or loss, alteration, illicit notification or access to these and in general their unlawful processing (including the remote access) as well as for ensuring the recovery option of the availability of data and of access to them. These measures aim at ensuring a safety level ad-dressing the risk that may affect the certain data, taking always into account the kind, category and significance of the data, the evolution of the technology, the ap-plication cost and the nature, scope of application, the framework and the purposes of each specific processing, applying at the same time procedures for the regular testing, assessment and evaluation of efficiency of these technical and organizational measures. In any case WAKAH TRADING LTD, the data processors on behalf of WAKAH TRADING LTD and its agents/ assistants are committed to keep the confidentiality of the personal data of the members and not to disclose or all access to the data to any third party without the prior notification of the member except for in cases explicitly provided by law.

WAKAH TRADING LTD declares that no other use of the personal data of the member shall be made for other purposes, apart from those mentioned in the present terms without notification in advance, and where required, his express con-sent.

Cookies
In our webpage we use Cookies.
WAKAH TRADING LTD holds a strict policy for the protection of privacy of 
www.speakingroses.com.cy visitors. In this note we provide you with more information on how we use “cookies” as well as other automated means in order to collect certain information regarding the visitors of our webpage, such as the number of visitors of our webpage and our most visited websites, through any kind of browser and device used. Upon collection of this information we learn to adjust better our webpage and our advertisements to our visitors.

Cookies and other Automated Means for the Collection of Data
Cookies
Cookies are short software texts stored in any of your devices through the use of any kind of browser, whenever you visit a website. We may use cookies in order to be informed for example, if you have visited our webpage in the past or if you are a new visitor as well as to help us detect features of our webpage, for which you may be more interested. Cookies may improve your online experience by storing your preferences while visiting a specific webpage.


IP and URLs Addresses
The IP address is a unique locator used by certain electronic devices in order to be detected and contact each other in the Internet. When you visit our webpage, we can see the IP address of the device you used in order to connect to the Internet. We use this information in order to specify the general geographical location of the device and comprehend from which geographical areas the visitors of our webpage are coming. We can use this information in order to change the presentation method of our webpage so that we can improve your visit.

The URL (Uniform Resource Locator) is a unique locator or address for any media in the internet and, basically, it means the address of the webpage you visit. We shall use this information so that we can find out which webpage are most visited as well as the way you use to surf in our webpage.

What kind of cookies we use?

In our webpage we use the following cookies:

Absolutely Necessary Cookies
The absolutely necessary cookies are of vital importance for the proper function of the website, they allow you to surf in the website and use its options, as well as they give you access to secure areas, registration forms, list of beloved persons, use of the basket for purchases and for security reasons. These cookies do not recognize your personal identity. Without these cookies we cannot offer an effective function of our website.

Cookies of Performance and Analysis
These cookies collect information about the way the visitors use the website, which pages they visit more frequently and if they receive error messages from the webpage. These cookies collect consolidated, anonymous information, which do not identify any visitor. They are used exclusively for the improvement of the performance results of a webpage and allow us to collect information regarding the rate of using our webpage, including the content you choose during your surf in our webpage, in order to measure the effectiveness and the interaction of the consumers with the webpage as well as to improve our pages in due course. These cookies can be provided to us by third parties-providers of analytical tools but only used for the purposes related to our webpage
Eg.: https://developers.google.com/analytics/devguides/collection/analyticsjs...

Cookies for targeting/advertising
These cookies are used for the provision of content which suits you and your interests bet-ter. They may be used for the sending of targeted advertisement/offers, the limitation of advertisement presentations or the measurement of the effectiveness of an advertising campaign. These cookies can be used in order for us to remember the websites you have visited so that we can determine which online marketing channels are more effective and allow us to praise webpage of third parties and external partners who forwarded you to us.

How can you De-activate the Use of Cookies?
In case you wish to activate or deactivate the use of cookies in the settings of your browser, depending on the kind of your browser, you must visit the following webpage, in order to learn about the required relevant actions.
Internet Explorer 
http://support.microsoft.com/kb/278835
Firefox 
http://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
Chrome 
http://support.google.com/accounts/answer/61416?hl=en
Opera 
http://www.opera.com/browser/tutorials/security/privacy/
Safari 
http://support.apple.com/kb/PH5042
Safari for iPad and iPhone 
http://support.apple.com/kb/HT1677