Privacy Policy

Edition – October 2024

Introduction

The protection of your personal data and information is of utmost priority and forms the foundation of the trust relationship we aim to establish with you. Please take a moment to read this Privacy Policy carefully.

This Privacy Policy (the “Policy”) aims to inform you about how we collect, process, use, and store your personal information and data (hereinafter collectively referred to as "Personal Information" or "Personal Data" or "Personal Details"). The Policy provides a detailed description of the data used on the website www.welby.gr(the “Website”) and the Welby mobile application software available for download on the App Store and Google Play (the "App"), through which Users can make reservations for the services of Partners (together referred to as the "Platform").

The data controller for the personal data is VACHRI I.K.E., with VAT No. 802185491 and GEMI No. 171680901000, which operates under the name WELBY, managing and operating the Website and the App ("Welby," "we," "us," or "our"). You can reach us by emailing contact@welby.gr.

1. What Data Do We Collect?

The term Personal Data refers to any information that directly or indirectly identifies an individual (such as name, address, phone number, email address). In the context of our Services, the following categories of personal data are collected and further processed for the reasons described accordingly:

1.1. When you, as a Partner, wish to create an Account, we collect and store the following personal information:**

Basic identification and contact information of the Account holder, such as full name, email address, postal address, and phone number.
Username and login password.
Employment status as an employee of the Partner and job position.

1.2. When you wish to create an Account as a User of the Services, we collect and store the following personal information:**

Basic identification and contact information of the Account holder, such as full name, email address, postal address, and phone number.
Gender.
Date of birth.

1.3. If you wish to contact us via email for any matter or provide feedback regarding our Services:**

Basic identification details, such as your name and email address.
The content of your email.

1.4. When a reservation for a Partner is made using our Platform or via a phone call, the User’s personal data requested by the Partner is stored on our Platform.**

This personal data may include name, email address, phone number, gender, date of birth, and booking details or preferences. Partners may also, on their own initiative, add notes about each User, which the Partner may consider important for enhancing customer relations and offering personalized services, such as specific time and day preferences or the number of visits to the Partner.

1.5. When a User makes a financial transaction with a Partner through the Platform (to secure a booking), all necessary information to complete the transaction, including credit/debit card information, may be provided via the Platform.

However, we do not directly receive or store payment information on our servers. These details may be shared between the Partner and third parties as defined in this Policy.

1.6. When you use other features and services through the Platform:

Contact details and other information you may provide regarding job applications, expressing interest in our Services, or any other inquiry via our email address provided on the Website for such communications.
In certain cases, we also automatically collect technical information that does not directly identify you, such as the type of browser, operating system, Internet Protocol (IP) address (a number automatically assigned to your computer when you use the Internet, which may vary per session), domain name, date/time stamps, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamps, and data flow information regarding your visit and cookie usage. For more information on the use of Cookies through the Platform, please visit our Cookies Policy.

1.7. If you wish to participate in surveys conducted through the Services with your explicit consent or if we exercise our legitimate interest in improving the Services, additional profile information may be collected.

1.8. It is crucial that all Personal Data you provide when registering as a user or otherwise when using the Platform is accurate and correct.

This includes, but is not limited to, ensuring that we have the correct contact details for you (including your email address).

1.9. If you intend to submit Personal Data of another person (e.g., when making a booking on their behalf), you must only provide their details with their consent and after giving them access to information on how their details will be used, including the purposes defined in this Policy.

2. How Do We Use Your Personal Data?

We use your Personal Data to provide the services and products you request, process payments, offer customer service, deliver content and advertisements that we believe may interest you, conduct customer research, send promotional messages, and inform you of important changes to our Platform.

2.1. To fulfill a contract or take steps linked to a contract:

Sending you information about the services you requested (e.g., appointment reminders) via email, SMS, and push notifications.
Facilitating your bookings and processing payments.
Responding to your questions and concerns.
Managing your account.

2.2. As required by Welby to operate our business and pursue our legitimate interests, particularly:**

To keep the Platform and our systems secure and to prevent fraud, security incidents, and other crimes.
To verify compliance with our terms and conditions and for the establishment, exercise, or defense of legal claims.
To notify you about new Welby services and special offers that we believe will be valuable to you, for example, through email and advertising on third-party websites like Facebook (where consent is not required).
To customize and personalize promotional notifications and advertisements for you and others based on the information you provide and your usage of the platform, our products and services, and other websites (for more information, please refer to the Cookie Policy).
To help us monitor, improve, and protect the Platform, our products, and services, and to personalize the Platform, products, and services (and those of our Partners) for you, based on the information you provide and your usage of the Platform, our products and services, and other websites (for more information, see the Cookie section of this Privacy Policy).
To investigate and respond to any inquiries or complaints we receive from you or others regarding our Platform or our products or services.
To conduct internal research and analysis so that we can understand how the Platform, our products, and services are used and how our business is performing.
To conduct market research and consumer surveys.
To gather and publish reviews of products or services offered by our Partners and to use them in promotional campaigns.
To process job applications submitted directly or indirectly to Welby, including assessing your suitability for the role, your resume, and professional skills, scheduling interviews and assessments, communicating with referees, and, if successful, offering employment and establishing an employment relationship with you. The personal data you provide will be retained for a period of 12 months and may be used if you apply for a future job at Welby unless you choose to delete this data, which you can do by following the link in the confirmation email of your application that we sent you.

2.3. With your consent:

To notify you about new Welby services and special offers that we believe you will find valuable, for example, via email and advertisements on third-party websites such as Facebook (where consent is required).
To send you information about competitions, surveys, and promotional activities of our Partners, as well as details about goods or services from other selected third parties, such as health, beauty, leisure, and lifestyle brands, via email and as push notifications through the App.
To transfer your personal data to our Partners and other selected third parties, such as health, beauty, leisure, and lifestyle brands, so that they can send you information about their goods and services on their behalf.
To place cookies and use similar technologies in accordance with the Cookie Policy and the information provided to you when these technologies are used.
To use customer communications for training, record-keeping, and quality control purposes. If you call our customer service team and do not opt out, your call may be recorded. We will inform you if such recording is taking place and will provide you the option to opt out of the recording if you wish, as well as the means to do so.
In other cases where we request your consent, we will use your data for the purpose explained at that time.

2.4. When required by law:

To respond to requests from government authorities or law enforcement conducting investigations.
To comply with legal, regulatory, and compliance requirements.

3. Withdrawal of Consent for Direct Marketing Communications

Where we rely on your consent, you will always have the option to withdraw your consent, although we may have other legal grounds for processing your data for other purposes, as described above. You have the absolute right to opt out of receiving direct marketing communications at any time. You can do this by following the instructions included in the communication if it is an electronic message, or by contacting us using the details provided below.

If you wish to unsubscribe from receiving communications sent by Welby, you can do so by clicking the "unsubscribe" button at the bottom of the electronic communications we send you, or alternatively by contacting us at contact@welby.gr. Please note that in the case of promotional material sent via email, it may take up to 48 business hours for your email address to be removed from our system.
If you wish to unsubscribe from receiving communications sent by Partners and other third parties, please contact the Partner or third party directly. In the case of our Partners, if you need assistance with this, we will be happy to do our best to help you.
If you no longer wish to receive push notifications through the App, you can do so by revoking the permission for push notifications for the App in your settings.
Please note that if you have opted out of receiving marketing communications via email using the methods described above, you may still see our non-targeted advertisements while browsing online if your interest settings on Facebook align with an audience segment (predefined by Facebook) that our business also targets. We do not control whether these ads will appear to you.

4. Disclosure of Personal Data to Third Parties

We do not disclose, transfer, or otherwise distribute any personal information we process to any third party, except as outlined in this Policy. Any information we process in the context of the services we provide will be held by our authorized personnel.

4.1. To ensure optimal service delivery and functionality and in accordance with applicable data protection laws, we may disclose your personal data to third parties we collaborate with, such as:**

4.1.1. Our Partners with whom you make service reservations through the Website or the App.**

Your data is shared with the Partners to:

Facilitate the bookings and, if necessary, allow for pre-appointment communications.
Send marketing emails from the Partners you book with, if you have opted in to receive such messages, featuring updates and special offers.
Help improve the services offered to their customers and support their business activities by providing statistical data about customers, both aggregated and individual.

4.1.2. To third-party commercial companies/brands with whom we collaborate for products, services, competitions, and campaigns.

4.1.3. To third-party software providers used by our Partners to ensure that these third-party solutions display real-time availability to customers.

4.1.4. To media agencies and advertising partners to conduct targeted marketing campaigns** (refer to our Cookies Policy for more details on online advertising practices).

4.1.5. To other third parties, for the purpose of facilitating our business and improving our products, content, services, or advertising. This may include, but is not limited to, sending emails or publishing reviews about our products and services or those of our Partners.

4.2. We may share your personal data with third-party service providers in order to provide our services; to conduct quality assurance testing; to facilitate account creation; to offer technical support; to receive hosting services; and/or to provide other services to us.**

We may use third-party payment processors, such as VIVA, to process payments made via the Platform to the Partners. Regarding these payments, we do not store personally identifiable information or financial details such as credit or debit card numbers. All such information is provided directly to the relevant third-party payment processors, whose use of the customer’s personal data is governed by their own privacy policies.

4.3. Unless otherwise stated herein, we may be required to disclose personal information in response to investigations conducted under law enforcement or in cases required by applicable laws (primarily the General Data Protection Regulation (GDPR) 679/2016, Greek Law 4624/2019, and any other laws governing the use and disclosure of personal data) to the relevant administrative, judicial, or public authorities, or generally to any legal or natural person to whom, by law or court order, we are obligated or entitled to disclose this data.**

4.4. We may share some or all of your personal data in connection with or during negotiations of any merger, financing, acquisition, or dissolution, or any transaction involving the sale, transfer, divestiture, or disclosure of all or part of our business or assets.

In the event of insolvency, bankruptcy, or receivership, personal data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Policy.

4.5. The security of your information is of utmost importance to us.

We take every reasonable measure to ensure that all your personal data and account details are secure. We store this information on secure servers, continuously monitor, and implement changes and improvements in the field of electronic data security to maintain the safety of the personal data we hold. We consistently review and improve our procedures, methods, and data processing architecture to maintain security and exceed all related compliance requirements. We scrutinize all suppliers acting as subprocessors on our behalf, work with independent advisors, legal counsel, and other technology companies to understand best practices, interpretation, and standards related to applicable data privacy laws. For our clients, i.e., the Partners, we support, as much as possible, the processing of data for export, deletion, and retention to meet data subject requests directed to them and other similar compliance obligations.

Nevertheless, we recommend that you read the Terms of Use of our Website and App, which refer to matters beyond our control, such as how you access and use the Website.

Note: By posting any personal information in any publicly accessible part of our Platform (such as review sections), this information may be collected by third parties we do not control. We are not responsible for the use of such information by those third parties. Therefore, please exercise due care and caution before disclosing any personal data that may be exposed in public areas. You should also avoid disclosing in public areas any personal data that could be used to identify you (such as your name, age, home or work address, or your employer’s name).

5. Your Rights Regarding Your Personal Data

5.1. In relation to the personal data we hold about you, you may have the right to request:

A copy of your personal data.
Rectification, deletion, or restriction of your personal data processing.
To receive the personal data you provided to us for a contract or with your consent in a structured, machine-readable format, and to ask us to transfer this data to another organization.
To object to the processing of your personal data in certain circumstances (particularly where we do not need to process the data to fulfill a contractual or other legal requirement, or where we are using the data for direct marketing).

5.2. Initially, you can view or change the data you provided by logging into your online account.

5.3. Your rights regarding your personal data are limited in certain cases.

For example, if fulfilling your request would reveal personal data about another person, or if we have a legal obligation or compelling legal grounds, we may continue to process the personal data you have asked us to delete. You may also have the right to lodge a complaint if you believe your personal data has been mishandled. We encourage you to first contact us, but to the extent this right applies to you, you may also lodge a complaint directly with the relevant supervisory authority. If you wish to exercise any of the above rights, please contact us at contact@welby.gr. However, note that no financial data will be provided without verification.

6. External Links

6.1. We are not responsible for the practices employed by websites linked to or from our Website or App, nor for the information or content they contain. Often, links to other websites are provided solely as pointers to information on topics that may be useful to users of our services.

6.2. Remember that when you use a link to go from our Website or App to another site, this Policy no longer applies. Your browsing and interaction on any other website, including those that have a link on our Website or App, is subject to the terms and policies of that website. Always read these terms and policies before proceeding.

7. Where We Store Your Personal Data

The data we collect from you may be transferred to and stored in a destination outside the United Kingdom and the European Economic Area (EEA), including the United States and Israel, among others, for the purposes of processing such data by selected third parties to facilitate Welby’s business operations. Countries outside the EEA may not have laws that provide the same level of protection for your personal data as the laws within the EEA. In such cases, personal data is adequately protected by EU Commission-approved standard contractual clauses, appropriate Privacy Shield certification, binding corporate rules of the processor, or other adequacy mechanisms established under applicable data protection laws. A copy of the relevant mechanism may be provided to you upon request at contact@welby.gr.

8. Data Retention Period

We retain your personal data for as long as necessary to fulfill the activities outlined in this Policy, for the duration communicated to you, or otherwise for as long as permitted by applicable law.

9. Changes to the Privacy Policy

If we change our privacy protection policies and procedures, we will post those changes on our Website to keep you informed about what data we collect, how we use it, and under what circumstances we may disclose it. You acknowledge and agree that any use of the Services following our modifications constitutes your acceptance of this Privacy Policy.

Viva Payment Processor:

We use a third-party payment processor, Viva, to handle all payments made on our Website and App. We receive limited information from Viva, such as the last four digits, the issuing country, and the expiration date of the payment card. The processing of this data by Viva is governed by its own privacy policy, which you can view here: https://www.viva.com/el-gr/privacy-notice