Privacy Policy of
Skillos.systems
This
Policy has been adopted by the company with the name IOT SYNDESI IKE with the
trademark SKILLOS. The registered office of our company is located at: 2 Xyromerou
Street, 11526, Athens, GEMI Tax registration Number 144949901000 and Tax Registration Number 800920377 (hereinafter referred to
as Skillos), which is the controller of the personal data you provide us.
Skillos
takes all the appropriate measures to secure and maintain the confidentiality
and privacy of the users’/customers’ Personal Data in compliance with the
provisions of no. 2016/679 of the General Data Protection Regulation (GDPR) of
the European Parliament and of the Council.
1. Scope
This
Privacy Policy describes how we process and protect your personal information
that you provided us when you use or access our services, or that is otherwise
obtained or generated by us.
Your
personal data are collected during your use of (a) our website (skillos.systems)
and its e-shop and any other platforms that we will make available to the
public and (b)any services we provide in connection with one or more of the
forementioned. You shall understand that we have no relation to any links to
other websites and online services operated and maintained by third parties, in
which case we advise you to read the related privacy policies.
Please
note that you are under no obligation to provide us with your personal
information, however we may not be able to provide you with certain products
and/or services if you refuse to provide it.
2.Definitions
“Personal
data” is any information that can be used to identify an individual. Different
pieces of information, which collected together can lead to the identification
of a particular person, also constitute personal data. Personal data that has
been de-identified, encrypted or pseudonymised but can be used to re-identify a
person remains personal data.1
“User
Data” refers to the data submitted by users or collected by Skillos in order to provide its services, such as username,
contact information, etc., during the use of Skillos's products and services or
any related interaction. User Data include, but not limited, Personal Data.
“Smart
Device” refers to electronic device, such as smart home appliances etc., that
have the ability via wireless protocols to connected, interact with and
transmit data to other devices, networks or to its users.
“Cookies”
are small data files that your browser stores on your device and are used to
uniquely identify your browser and help to enhance users’ navigation through
the sites. The information that these files
is typically shared with the owner of the site and their other potential
partners.
3.
How We Collect Your Personal Data
This data can be collected either
- by telephone (e.g. telephone communication),
- online (when you register an account on our website/e-shop, or proceed
to pay for our services or via electronic mail)
- physically (e.g. following the provision of services from our
technicians at your premises
- by signing the relevant Services Agreement
Such data includes the following:
a) personal data, such as name, surname, address, contact numbers, TRN
number, copy of identity card/ passport, email address, username, password,
information about the connection package and full billing information
b) financial and accounting data, such as billing data for Skillos
services, billing data for the equipment purchased, credit or debit card data,
data related to disputes, financial debts of the customer
4. Cookies
and Similar Tracking Technologies
During
your navigation in our site, we and other service providers on our behalf, use Cookies.
Certain cookies are necessary to run our service and those cannot be declined.
We also use preference cookies, that help us to present you with a tailored
experience, and analytics cookies to measure the total number of visitors to
our site, so we can improve our services.
If you do not want cookies to be installed on your device and the as
long as the cookie is not strictly necessary, you can decline the use of
cookies following a simple procedure and, if you wish, you can change your
preferences by reseting your web browser.
We
may also HTML-based emails sent to our users to track which emails are opened
by recipients and web beacons to record the usage patterns of our users. In any
case, however, we respect do-not-track signals or similar technologies that our
systems detect and identify.
5. Purpose
and Legal Basis for Processing Personal Data
We
collect and process your Personal Data with your consent in order to provide
you our services and understand how we can improve them.
We,
also, may process your information for the following purposes:
• To provide you our products and services. We
need specific information so you can connect to the platform and control Smart
Devices through it and securely store your pictures and videos when purchasing
cloud storage services.
• To improve
our products and services, we process your device information to analyze trends
and to track your usage of our Services. Such data analysis might be useful to
us to identify usage trends and develop new products or services.
• To
create and manage accounts when you register with us.
• To
provide you with technical and customer support.
• To
communicate with you about our products and services after obtaining your
relevant consent, which you always have the right to withdraw and change your
preferences again if you wish.
• To inform
you regarding modification on our services, changes to our terms and policies
and/or other administrative information. Because this information may be
important, you may not opt-out of receiving such communications.
•
Legal Compliance. We disclose information if we are legally required by the provisions
of the law, or it was requested by the administrative, judicial, or other
competent authorities. Also, in the following cases:
o
Enforce our Terms of Use and other special agreements
and policies.
o
Perform risk management, investigate and prevent
security incidents such as breaches, hacks and any other fraudulent or
malicious activities.
If
there is any change in the purposes for processing your Personal Data, we will
inform you via a prominent notice on our website.
6. Who
do We Share Personal Data with?
At Skillos,
we value and protect your Personal Data.
We only disclose your Personal Data to third parties in the following
cases:
• To
our third-party service providers who perform, under contracts with special
provision about the data protection, certain business-related functions for us
so you can use our site and Services, including but not limited to:
o
Providers of infrastructure provision, customer
support and enterprise authentication services,
o
Providers of payment and credit card processing
services,
o
Providers of cloud, network, IT services, server and
other virtual services
o
Delivery partners so you can receive your orders.
• To our
affiliates in the course of regular business activities and in compliance with
applicable law, this Privacy Policy and other special agreements.
• To
any subsidiary or other entity in the event of any reorganization, merger,
sale, joint venture, assignment, transfer or other disposition of all or any
portion of our business, its assets or stock (including without limitation
bankruptcy or similar proceedings). In such an event, you will be timely notified
via email and/or a prominent notice on our website of any change in ownership,
and choices you may have regarding your Personal Data.
7. Security
At Skillos,
in order to ensure the integrity and security of your Personal Data, we have
taken and constantly updating our organizational safeguards and administrative
and technical security measures.
Wherever
your Personal Data is involved, we make sure that proprietary algorithms,
storage and transmission encryption protocols are used to ensure data isolation
and access authentication. Furthermore, we always process your data in
accordance with this Agreement and the applicable law, and we follow strict audit
and validation of the data. The same obligations apply to any third party who
is contracted to process your Personal Data on our behalf.
If
you have reason to believe that the data you shared with us is no longer secure,
you shall immediately notify us by emailing at support@skillos.systems.
8. Data
Subject Rights
We
respect your rights and control over your Personal Data. You may exercise any
of the following rights by emailing us at support@skillos.systems.
•
right of access to
their personal data as well as the information related to the processing (GDPR
Article 15),
•
right to correct
inaccuracies and complete any missing data (GDPR Article 16),
•
right to erasure
("right to be forgotten"- GDPR Article 17),
•
right to limit the
processing of their data for the cases expressly defined by law (GDPR Article
18),
•
right to
portability of their data in a structured, commonly used and machine-readable format
(GDPR Article 20),
•
the right to
transmit their data to another - other than Skillos- controller (GDPR Article
20), as well as
•
the right to object
to the processing of their personal data in the cases expressly defined by law
(GDPR Article 21).
We
will respond to your requests free of charge and without culpable delay within
one (1) month of receipt of the request. Please note that your request must
clearly state what information you would like to be changed, which Personal
Data of yours to be deleted from our database, or what restrictions you would
like us to place on the use of your Personal Data. In exceptional
circumstances, due to large workload and depending on the complexity of your
request, this deadline may be extended for two (2) months, after you have been
informed beforehand about the reason for the delay. To ensure the security of
your personal information, we may, at our discretion, ask you to prove your
identity before providing the requested information.
9. Data
Retention
Skillos
keeps the data in a physical/electronic file for the entire duration of the
cooperation.
The
data of inactive contracts is kept for a necessary period of 2 years after the
termination of the contract for the provision of services/products, unless
according to the law they must be kept until the final liquidation of cases, or
if a longer period is defined by other legislation period of time (e.g. tax
provisions). They are then permanently deleted without the possibility of
recovery.
When
you request us to remove your Personal Data, we will timely do so after your
request and we will no longer be retained them. If we are unable to do so for
technical reasons, we will ensure that appropriate measures are taken to
prevent any further such use of your Personal Data.
10. Amendments
We
may update this Privacy Policy to comply with the amendments of the relevant
legislation and reflect the changes in technology and our practices. When using
our services, you will be asked to review and accept this Policy and we may
record your acceptance. We encourage you to periodically review this page for
any changes, as you will be notified by a notice on this website prior to the
change becoming effective. The changes will be applicable, upon their
publication to our website.
11.
Contact Information
If
you would like to receive further information about this Policy, please contact
us:
Postal
Mailing Address: IOT SYNDESI IKE, 2 Xyromerou Street, Athens,11526, Greece.
Email
to Skillos Privacy Office at: support@skillos.systems.
In
case you consider that we have not satisfied your request sufficiently and the
protection of your personal data is affected in any way, you can submit a
complaint through a special online portal to AADE (Athens, Kifisias Avenue 1-3,
P.O. 115 23 | tel.: +30 210 6475600).
Sources
1= https://commission.europa.eu/law/law-topic/data-protection/reform/what-personal-data_en