INFORMATION REGARDING THE PERSONAL DATA PROTECTION IN THE CONTEXT OF THE “TOMMY HILFIGER LOYALTY PROGRAM”
The organizers of the “Tommy Hilfiger Loyalty Program”, that is, the companies you make transactions with (hereinafter “Organizers” and/or “We”), hereby inform you about the way we will process your personal data.
1. Processing Controller
In particular, for customers of stores in Greece (physical stores and e-shop), the organizer of the loyalty program “Tommy Hilfiger Loyalty Program” (hereinafter “Program”) is SARKK S.A, 67 Tzavella & Mesogeion Ave., 152 31, Halandri, Athens, TIN 094526950, acting as the Processing Controller.
For customers of stores in Bulgaria (physical stores and e-shop), the organizers of the loyalty program “Tommy Hilfiger Loyalty Program” (hereinafter “Program”) are the companies SARKK BULGARIA EOOD and SARKK ROM TRADING SRL, acting as Joint Processing Controllers, in cooperation with SARKK S.A., acting as the Data Processor.
For customers of stores in Romania (physical stores and e-shop), the organizer of the loyalty program “Tommy Hilfiger Loyalty Program” (hereinafter “Program”) is SARKK ROM TRADING SRL, acting as the Processing Controller, in cooperation with SARKK S.A., acting as the Data Processor.
For customers of stores in Cyprus (physical stores and e-shop), the organizers of the loyalty program “Tommy Hilfiger Loyalty Program” (hereinafter “Program”) are the companies SARKK S.A, SARKK LIMITED and HAWKEYE HOLDINGS LIMITED, acting as Joint Processing Controllers.
2. Data Collection
In our capacity as the Organizer or Organizers of the Program, based on the above and acting as Processing Controller or Joint Processing Controllers, respectively, we will collect and process your personal data, which you will provide us through the relevant subscription form in the “Tommy Hilfiger Loyalty Program”, fully complying with the requirements of the legal context for the protection of personal data (General Data Protection Regulation GDPR 679/2016, Greek Implementation Law 4624/2019, Romanian Law 190/2018, Bulgarian Law Personal Data Protection Act, Cypriot Law of 2018, L.125(I)/2016, as amended), decisions and guidelines of the Supervisory Authorities for Personal Data Protection in Greece, Cyprus, Romania and Bulgaria. In more details, we will collect your data below, depending on the subscription you will select: A. Subscription in a store (mandatory fields): Name, Surname, Email, Mobile phone number, Gender, Date of birth (day/month), Preferences. B. Subscription through the website (mandatory fields): Email, Code **Optional fields (online registration or subsequent addition through My Account): Name, Surname, Mobile phone number, Gender, Date of birth (day/month), Preferences. Moreover, throughout your participation in the “Tommy Hilfiger Loyalty Program”, we will have access to your purchase history, so that you can make use of the benefits from the “Tommy Hilfiger Loyalty Program”, based on the points you have collected.
3. Purposes and legal grounds for processing
We will process your personal data exclusively for the purposes of subscription and participation in the program “Tommy Hilfiger Loyalty Program”. The said data processing for the subscription to the loyalty program and the provision of benefits is based on the execution of the contract concluded between us and your acceptance of the terms of the loyalty program (article 6, par.1, item. b GDPR). Moreover, if you give your consent (article 6, par.1, item. a GDPR), we will process your data so we can send you general and personalized newsletters about products, services, offers, events, discounts and other promotional activities. In this context, based on your consent and aiming to send personalized newsletters, we will process the data of your purchase behavior as well as your navigation details and your preferences in the websites of our stores. In this way, we will be able to recommend products that meet your needs and interests in the best possible way.
4. Recipients of data in and out of the Organization
Access to your personal data is given exclusively to our authorized employees and/or our authorized partners, within the European Economic Area (EEA), which provide us with services and are bound in writing by obligations of confidentiality and proper processing of your data. In any other case it is requested that your personal data be transferred to third parties for a different purpose of processing, you will be informed in advance about the purposes, the recipients and the guarantees regarding the protection of your personal data. The only exceptions are the cases in which, upon a legal request, we are obliged to disclose your data to judicial, prosecuting or other public authorities, in the framework of the legal execution of their duties.
5. Retention period of data
The Organizers will retain your data for as long as you are subscribed in the “Tommy Hilfiger Loyalty Program”. Once you unsubscribe, the data will be securely deleted provided that it is not necessary for the fulfillment of other legal purposes of the company, e.g. management of the relationship with the customer if you have proceeded to transactions with the Organizers.
6. Your rights and the way to exercise them
You may exercise any of your rights pursuant to the GDPR 679/2016 and particularly the right of access to data, rectification, erasure, portability, limitation of processing, objection/ revocation of your consent, without any justification, by contacting us:
For customers of stores in Greece: SARKK S.A., 67 Tzavella & Mesogeion Ave, 152 31, Halandri, dpo@sarkk.gr, it_gdpr@sarkk.gr or through your written request submitted to any of our physical stores.
For customers of stores in Bulgaria: dpo@sarkk.bg or through your written request submitted to any of our physical stores (Attn: DPO).
For customers of stores in Romania: dpo@sarkkrom.ro or through your written request submitted to any of our physical stores (Attn: DPO).
For customers of stores in Cyprus: dpo@sarkk.gr or through your written request submitted to any of our physical stores (Attn: DPO).
Furthermore, if you have subscribed to our newsletter, you may unsubscribe at any time by choosing “Unsubscribe” in any newsletter you receive.
7. Complaint to the Competent Supervisory Authority
In case you believe that any of your rights regarding the collection and processing of your personal data is violated, you may lodge a complaint with the Competent Supervisory Authority. In particular:
For customers of stores in Greece: Hellenic Data Protection Authority / DPA, 1-3 Kifissias Ave., Zip Code 11523, Athens, (www.dpa.gr).
For customers of stores in Bulgaria: Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, https://www.cpdp.bg and National Supervisory Authority for Personal Data Processing, 28-30 B-dul G-ral Gheorghe Magheru, Sector 1, 010336 Bucharest, https://www.dataprotection.ro
For customers of stores in Romania: National Supervisory Authority for Personal Data Processing, 28-30 B-dul G-ral Gheorghe Magheru, Sector 1, 010336 Bucharest, https://www.dataprotection.ro
For customers of stores in Cyprus: Hellenic Data Protection Authority / DPA, 1-3 Kifissias Ave., Zip Code 11523, Athens, (www.dpa.gr) and Office of the Commissioner for Personal Data Protection, Kypranoros 15, 1061 Nicosia, https://www.dataprotection.gov.cy