PRIVACY NOTICE ON COMMERCIAL COMMUNICATIONS

As Vakko Investment Single Member Société Anonyme  (”Vakko”, “Controller"), we value the protection of your personal data, so we expect you to show the same attention. For this reason, it is very important for us that you read this text detailing which personal data we use for what purpose and to clearly understand the obligations of Vakko, who is responsible for the administrative and technical security of your personal data as “Controller”.  

With this privacy notice we aim to inform data subjects, persons whose personal data is processed (used), as the “Controller” who uses their data. As a Controller, we have to prove that you have been informed about your personal data we will process by explaining:

1.  What personal data we collect about you and how we obtain them

As Vakko, we collect your personal data through digital channels when you interact with our e-store, particularly when you subscribe to receive commercial electronic messages (CEMs) such as promotional offers, newsletters, or updates. This data is collected either with your explicit consent, in compliance with the General Data Protection Regulation (GDPR) and Greek data protection laws. Below are the categories of personal data we collect and how they are obtained:

• Your identity data (including but not limited to your first name, surname),
• Your contact data (including but not limited to your phone number, e-mail address),
• Your marketing data (including but not limited to contents of commercial electronic messages sent to you, date and record of commercial electronic message sent, Content of commercial electronic messages sent to you (e.g., promotional offers, event invitations, records of your interactions with commercial messages)

are obtained through the sections related to the sending of commercial electronic messages, as you provide this information based on the necessity of processing for the purposes of the legitimate interests pursued by the data controller. These interests are balanced against the fundamental rights and freedoms of the data subject, which require the protection of personal data.

2. How we use your personal data

As presented below, the purposes of personal data processing carried out within the scope of the activity in which the Privacy Notice is issued are detailed.

We will only use your personal data where we are permitted to do so by applicable law. Each personal data processing purpose is matched with the categories of personal data and the relevant legal reason relating to the purpose.

In the presence of your consent, your identity, contact and marketing data are processed for:

• Confirming that you have consented to receiving commercial messages from Vakko, such as promotional offers, newsletters, or event invitations,
• Maintaining accurate records of your consent preferences, including the date, time, and method of subscription, as well as any subsequent withdrawals or updates to your preferences,

• Sending commercial electronic messages via SMS and e-mail, or messaging platforms (e.g., WhatsApp) about Vakko’s products, services, and exclusive offers,
• Keeping records of commercial electronic messages sent,
• Retaining logs of all commercial electronic messages dispatched, including message content, delivery status, and recipient engagement metrics (e.g., opens, clicks),

for processing is necessary for the purposes of the legitimate interests pursued by Vakko (e.g., promoting products, improving customer engagement, and ensuring compliance with legal obligations), provided that such interests are carefully balanced against your fundamental rights and freedoms. We ensure our activities do not override your privacy rights and always offer clear opt-out mechanisms.

3. Who we share your personal data with

We only transfer them for certain purposes with:

• Public authorities and courts for legal duty of disclosure and limited to only information, which was requested,
• Our service providers such as customer support teams, external contact centers handling inquiries, cloud hosting providers, secure data storage and platform infrastructure for the purpose of sending commercial electronic messages,
• Our legal consultants and lawyers for fulfillment of legal purposes.

4. Which countries we transfer your personal data to

If we process data in third countries (meaning countries outside the European Union or the European Economic Area) or this occurs in the process of utilising the services of third parties or transmitting data to third parties, this will only be done for the purpose of fulfilling our contractual obligations, on the basis of your consent, due to a legal obligation or based on our legitimate interests.

In doing so, we ensure that your personal data is processed in compliance with the European level of data protection, based on special guarantees or due to corresponding contractual obligation including adequate technical and organisational measures.

5. How long we keep your personal data

We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose (for example your correspondance and any information we provide in return may be retained until the time limit for claims in respect of the communication or in order to comply with regulatory requirements regarding the retention of such data).

If your personal data is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.

Once your data is no longer needed, we:

• Securely delete the information; or
• Anonymize the information, ensuring that it cannot be linked back.

6. What rights you have in relation to your personal data and how to contact us

You have different rights listed under General Data Protection Regulation and if you wish to confirm processing of your personal data or to have access to your personal data we may have about you, you may contact us through the contact methods listed below.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Vakko might have received the data from Vakko; what the source of the information was (if you didn’t provide it directly to Vakko); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Vakko if it is inaccurate. You may request that Vakko erase that data or cease processing it, subject to certain exceptions.

You may also request that Vakko cease using your data for direct marketing purposes. When technically feasible, Vakko will—at your request—provide your personal data to you or transmit it directly to another controller.

If you have questions about this statement or about data protection at Vakko, you can contact our data protection officer directly:

You also have a right to lodge a complaint with the competent data protection supervisory authority (Article 77 of the GDPR in conjunction) if you have concerns about how the Vakko processes your personal data. If you have questions about this statement or about data protection at Vakko, you can contact our us directly:

Contact details for our company:

Customer Service: 

1.How we will update this Privacy Notice

We may change the content of our websites and how we process your personal data for commercial messages and consequently our Privacy notice may change from time to time in the future. We therefore encourage you to review them when you visit the website to stay informed of how we are using personal data.

This Privacy notice was last updated in April 2025.