We will be happy to answer any questions you may have about this policy and our procedures and principles for the protection of your personal data and privacy. You may contact us with such questions at email@example.com and address them to our Data Processing Manager George Stergiopoulos or submit a request to the Company’s postal address at Voutadon 28, Athens, 11854.
Bespot is a multi-purpose application designed and built with a lot of creativity and imagination, to combine the routine of your daily shopping activity with a real treasure game in the city, helping you to discover new shopping spots that may interest you, earn points, coupons and offers, and all this by promoting and rewarding your well-being, since the more you walk, the more you win!
The app works in two ways, through anonymous use, if you don’t want to share personal information and data with us, and through creating a user profile, providing us with a range of data that helps us to offer you a more personalized experience and allows you to enjoy the benefits of the app to 100%.
1.What data do we collect and process?
Α) If you choose anonymous use
The app allows you to use its main features anonymously. This means that you do not need to create a user profile and enter any other personal data to use the application, apart from MAC address information, IP address, operating system version, other statistics and the connection and geolocation data using your mobile phone’s GPS. You may choose not to provide us with your geographic location, but if you do so, your ability to use key functionality of the App will be affected. For example, if you choose to grant permission to access location information, in accordance with the iOS and Android user guidelines, we will be able to reward you for being at certain locations and otherwise your ability to use the service will be limited.
In addition, if you choose to share your preferences and interests with us, bespot will inform you about offers, coupons, new stores and shops around you, related to your interests.
In addition, we process any other information you may voluntarily provide to us (for example, through our service designed for Customer Service, etc. or by answering questions related to your app experience).
B) If you choose to create a user profile
If you choose to take full advantage of the functions and features offered by bespot, you will need to create a user profile. By clicking on the “Facebook Login” button you will be asked to log in to the platform via your personal Facebook account (social log-in). Through the profile, in addition to MAC address information, IP address, operating system version, other usage statistics, your declared interests and your geographic location, upon your login to the Platform in accordance with the above, we collect all of the following data if you have registered them in your Facebook account:
- full name,
- your name, name, email address,
- profile photo
Difference in usability
Even if you don’t choose to share additional personal data with us, you can still use the app to see offers and points of interest on the map, collect points, earn discount coupons and learn about offers and new places of shopping interest around you. The main difference between anonymous and profiled users is the ability to use points and discount coupons, and the personalized options offered to profiled users.
We remind you that whenever we ask you to fill in your personal data in order to access any of the functions or services of the Application, we will mark certain fields as mandatory, as they are the basic information we need in order to be able to provide you with the service. Please note that if you do not provide us with such data, you may not be able to complete your registration or take advantage of the relevant services.
The use and redemption of points, coupons and other rewards is only possible if the user of the application can be identified with the person visiting the store through his/her profile information.
2. Why do we collect and process your data?
The reason for the collection and processing of your data by bespot is to provide you with the best possible experience, in the context of the hidden treasure shopping game we have organized with our partner stores and businesses.
In short, we need to know your location on the map to let you know about shops and businesses you might be interested in, offers that might be of interest to you, and reward you with points and coupons as you move around the site and discover our hidden rewards. Your full name is then needed for your identification so that you can use and redeem the points, coupons and other rewards you have collected and won. Your e-mail facilitates our communication, while allowing us – if you choose – to send you information about campaigns and offers that may be of interest to you, and in any case gives you, through your profile, the possibility to check and change at any time your data that we collect and process, as well as to stop their collection and processing. Finally, your preferences and interests help us to send you specific information tailored to your needs.
But because we want your relationship with bespot to be one of trust, and we always seek to keep users of the app informed and in control of their choices, in this section we’ll give you a few more details about the exact reasons for collecting and processing each data item individually and in addition scores.
2.1 Device identification – The MAC and/or IP address:
If you decide to use the App, we need to process your data to identify you as a user of the App and to ensure your access to the App and the possibility of collecting points and other rewards. You may cancel this account by uninstalling the App from your device.
2.2 Points collection and directions feature – Your position on the map and your movement:
Bespot collects, stores and uses the exact location of your device, such as GPS information. This allows bespot to know where you are in order to earn points, collect coupons and other rewards that are tied to where you are and where you are moving.
2.3 Rewards redemption and delivery – Your name & e-mail:
If you choose to create a user profile, you enter into the app and share with us via the Facebook login your full name, an email address and profile photo.
The personal data you provide us by creating a user profile is collected and processed for your reward by bespot partners.
In order to receive some gift vouchers or other gifts collected through the app, we may need to identify you and send you more information via e-mail.
2.4 Personalised Content – Your interests:
If you want an even more personalized experience, you can choose to share your interests with us by selecting from a list of various activities, hobbies, etc.
Please note that your interests are not considered personal data, but in combination with the other information you provide us with, they may reveal a lot of information about your personality, character, shopping habits and more. For this reason, bespot leaves you with a choice, and in any case, it respects and protects this information as if it were personal data.
2.5 News, offers & promotions
Bespot wants to be able to communicate with you about app updates, company news and promotions. If you give us your consent, we will be able to use your e-mail or contact number if you choose to register it and if you give us your consent to use it in this case as well, to contact you about news or promotions that interest you
Furthermore, we will use data from your recent activity on the app and your device to provide you with relevant suggestions, content and special offers for you to make your experience with the app even better.
2.6 Participation in surveys
At bespot we are constantly looking for ways to improve your experience (a) with the App, develop new features, improve existing features or design new services for our users and (b) with the services provided by our partners. Your feedback is very important to us, so we may ask you to participate in our surveys and allow us to collect useful information about your device and your use of the App. Your participation in surveys is optional, even if you choose to be informed about them. We will use your feedback and the data we collect from the surveys solely to better understand and analyse the sector in which we operate.
If you do not wish us to contact you, you can – as you easily did when you agreed to it – withdraw your consent by deactivating the corresponding “Participate in surveys” toggle button via the “Privacy and Security” section of the App.
Please note that the revocation and subsequent changes apply only going forward and will take effect or be implemented no later than 48 hours after revocation.
2.7 Facebook Sign up
We give you the option to register or log in to the bespot Application using your Facebook login information, a service provided by Facebook Ireland Limited Liability Company, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). This requires the Facebook Login option to be enabled. To sign in, you will be taken to a Facebook page where Facebook will ask you for certain permissions and you will be able to sign in using your Facebook account data. This results in your Facebook profile being linked to our bespot App. This connection will allow us to see the data you have provided to Facebook (name, email address, public profile, age range, gender, profile photo, time zone, Facebook ID). For the purpose of the Facebook Connection, we only use your email address, your name, your profile photo and your Facebook ID for identification purposes in accordance with Article 6(1.)(f) of the General Data Protection Regulation (GDPR). At the same time, the type of device (e.g. iPhone), operating system, language, time zone, resolution, app version number and location of your time zone (e.g. Europe/Athens etc.) are automatically transmitted to Facebook.
Please avoid using the Login via Facebook feature if this is not in line with your wishes.
2.8 Bug fixing, customer service and functionality improvements
To enable the elimination of glitches in the bespot Application, to answer specific customer questions about functionality and to adapt the Application to the needs of users, the following personal data are processed for the performance of the contract in accordance with Article 6(1.)(b) of the General Data Protection Regulation (GDPR):
Name, email address, profile photo (optional registration), your location data, coordinates when making at the entrance of the points collection points, and information about your terminal equipment (Device ID, etc.).
We may also process data that has become anonymous or aggregated data rather than personal data, in cases where such data is deemed sufficient for this purpose.
a) Google Analytics (Google Analytics)
The bespot Application uses GoogleAnalytics, a web analytics data analysis service provided by Google, Inc. (“Google”). For this purpose, a cookie is installed on your device. The information obtained from the cookie about your use of the App (including your IP address) will be transmitted to and stored by Google on servers in the United States.
Google will use this information to evaluate your use of the App, compiling reports on App activity for App administrators and providing other services relating to App activity and internet usage to the App provider. Google will not associate your IP address with any other data held by Google. For further information on how Google uses your data, please contact https://policies.google.com/privacy?hl=el#infocollect.
Objection to data collection:
In addition to changing your browser settings, you can prevent Google from collecting and using data by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=el
b) Facebook’s Custom Audience Program by downloading and installing the Facebook Custom Audience Program plug-in.
We participate in Facebook’s Custom Audience program which allows us to contact people who have already installed our app or to block people who are already using it from seeing our ads . To do this, we share your email address (email) or mobile phone number in an encrypted format with Facebook so that it can identify you if you are already a Facebook user.
Objection to data collection:
You can adjust your ad preferences from your Facebook settings.
2.10 To conduct competitions or offers, as permitted by law and for other uses with your express consent.
2.11 To protect the rights, property or safety of ourselves or others
2.12 To comply with our obligations under the law
2.13 For our legitimate interest. In certain circumstances, we collect your Data in a way that is reasonably expected as part of the operation of our business and that does not substantially affect your rights, freedom or interests. Our legitimate interests include marketing, providing and developing our Services, understanding User behavior and preferences, protecting and preventing fraud, and complying with applicable legal requirements and our policies.
3. Who has access to your data?
Access to your personal data, interests and preferences is restricted exclusively to bespot team members, depending on their position in the team, and the security and privacy classification of their duties.
3.1 All members of our team have signed confidentiality clauses and are fully aware of their responsibility with regard to the protection of your privacy, as well as the security, confidentiality, integrity and availability of your data. The same will apply to any new members that may be added to the bespot team in the future.
3.2 All our team members, existing and future, are bound by covenants and clauses to process your data only in the context of the purpose for which you have provided it to us and on the basis of the consent you have given us.
We do not collect or process your data for any other purposes than your consent.
- Anti-fraud detection and prevention agencies,
- technology service providers,
- providers of customer support related services,
- partners and service providers related to advertising and marketing.
They assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending contact messages, updating marketing lists, analyzing data, providing support services, or performing other tasks, from time to time.
We may also share your personal data with third parties in connection with a potential or actual sale of our company or any of our assets, or the assets of any affiliated company, in which case the personal data we hold about our users may be one of the transferred assets.
We collect (or process) the personal data in Greece. However, for reasons of service efficiency, some of these providers are located in regions outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union.
We will also respond to requests for personal data when required by law or when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, request from a regulatory authority or any other legal process served on us.
4. Protecting your data
The bespot team has taken all appropriate technical and organisational measures to ensure the highest possible level of security and protection of your personal data so that you feel confident, secure and trusting about how we process your data and how we protect it.
We apply the same high level of protection, privacy and information security to all the data we collect and process, whether it relates to anonymous users or users who have chosen to create profiles.
We have policies and procedures in place to protect personal data, including clauses and confidentiality agreements that bind all members of our team and all partners who may be acting on our behalf as Processors. We will not transfer your data to third parties, including our associated specialists, without your consent and unless we ensure that they implement equivalent security measures to protect your data.
We continually strive to improve our technical and organisational measures to provide an ever-increasing level of protection of your data, privacy and confidentiality. To this end, we have established regular security controls and specific protocols to prevent the risk of accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to your data by unauthorised or malicious third parties, and to mitigate the negative impact by implementing appropriate technical and organisational security measures, including those required for the matters referred to in Article 32(a) to (d) of the Regulation.
Encryption, pseudonymisation and anonymisation measures will be used to protect your privacy and personal data whenever possible.
Unfortunately, no one can guarantee that the transmission of data over the Internet or any electronic data storage system is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any personal data you may have sent to us has been compromised), please notify us immediately.
5. Keeping your data
bespot retains personal data as Data Controller or Data Processor for as long as necessary for the provision of the Services to the Platform Users. If you log in with a social networking service, we may receive and store authentication information from that service to enable you to log in, as well as other information you allow us to receive when you log in with those services. We will retain and use the Data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements with our customers and/or for the period required by applicable laws.
Your rights to your Data
Bespot is designed not only to make you feel secure about the data you provide to us, but also to enable you to freely exercise your rights in relation to that data. In particular you have:
i. The right of access, including the right to know whether and what kind of data we have collected and processed from you, the origin, purposes and legal basis for processing, the recipients or categories of recipients to whom the data have been or will be disclosed, where possible, the intended period for which the personal data are stored or, if not possible, the criteria used to determine that period, etc. (see Article 15 of the Regulation)
ii. the right to rectification, including the correction of any inaccurate personal data and the completion of any incomplete personal data. (see Article 16 of the Regulation)
iii. Right to erasure, allowing the deletion of your personal data in the following cases: (see Article 17 of the Regulation).
a. when your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
b. when you withdraw your consent to the processing of your personal data and there is no other legal basis for the processing.
c. where your personal data have been processed without the necessary legal basis,
d. when it is required by law to erase your personal data,
- Right to restrict the processing of your personal data in the following cases: (see Article 18 of the Regulation).
a. if they are no longer accurate and until they are updated and their accuracy is recalibrated.
b. when you want to restrict the processing of your data,
c. when your personal data are no longer required for processing purposes, but are necessary for the exercise or maintenance of legal claims
- Right to challenge – the right to object to the processing of your data unless there are compelling and legitimate grounds for processing. (see Article 21 of the Regulation)
- You have the right to portability of your personal data. (see Article 20 of the Regulation)
vii. Right to withdraw consent at any time (without retroactive effect)
- These rights may be limited due to our legal obligations, in particular in the event that data deletion is requested. (see also Article 23 of the Regulation)
- You can read more in Chapter III of the Regulation (also https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/my-rights/what-are-my-rights_el)
- To exercise your rights, you can submit a request to us at the postal address of the Company, Voutadon 28, Athens, 11854 or to the e-mail address firstname.lastname@example.org with the title “Exercise of Rights” and we will take care to examine it and reply to you as soon as possible. You have the right to lodge a complaint with the Personal Data Protection Authority (postal address 1-3 Kifissia Street, P.K. 115 23, Athens, tel. 210. 6475600, e-mail address email@example.com), if you consider that the processing of your Personal Data violates the applicable national and regulatory framework for the protection of personal data.
- Minimum Age
The Platform is not intended for children under the age of 16 and we try not to collect Personal Data from children under the age of 16. Bespot directs the Services and the Platform to adults and not to children under 16. In the event that we become aware that we have collected personal information from a child under the age of 16, we will promptly delete that information. If you believe we may have any information from a child under the age of 16, please contact us at firstname.lastname@example.org.
If we take the above actions, we will notify you by various means through the App (for example, via a banner, pop-up or push notification) or we may even send you a notification to your email address.
7. Further information
We will be happy to answer any questions you may have about this policy and our procedures and principles for protecting your personal data and privacy. You may contact us with such questions at email@example.com and direct them to our Data Controller George Stergiopoulos.