MORACLES GROUP PRIVACY PROTECTION POLICY

Customer commitment to data protection and privacy
Protecting your personal data and privacy is a major concern of
Moracles Group. In this Privacy Statement our goal is to provide a clear,
comprehensive and transparent communication regarding the collection, use, processing, storage, etc.
of personal data concerning the customers of the Moracles Group.
According to this Privacy Statement, “Moracles Group Customer” is considered to be
a former, current and potential customer or user of a product or service that is provided by
a subsidiary of the Moracles Group or its trademarks, visitors to one of
our official websites or stores, a member of a rewards program or
part of a community.
Core Values

Moracles Group expresses its commitment to the protection of confidentialtiy and private
information, embracing the following principles.
Moracles uses personal data in a lawful, legitimate, correct and transparent manner.
Moracles collects only personal data that is necessary and for a legal purpose.
Moracles does not retain data that is not necessary or for longer than
required .
Moracles protects personal data with appropriate security measures.

Why do we process your data?
We use and process the personal data related to your actions,
for example buying our products online or in a store, a visit to our website or
a communication with customer service. Examples of personal data are
your name, address, email address, phone number, social security
number, payment information, purchase, order and usage history, IP address
the member ID and any other information related to each case (e.g.
information you provide when communicating with our customer service).
In each specific section of this Privacy Statement you will be informed of the purpose
of any relevant information processing.

The Greek company, Moracles has the main responsibility for the processing of personnal
data under this Privacy Statement.
As the Moracles Group is made up of different legal entities, the entity that will
be responsible for processing your data will depend on the situation in which
your personal data are collected. The Greek company Moracles is responsible for
processing your personal data detailed in all sections
of this Privacy Statement, except where expressly stated that it is responsible for processing
of your personal data is Moracles S.A. Under each specific section, you will
be informed about the division of responsibilities and the details about
your exercise of rights.

The following entities will act as Data Controllers in relation to you:

Identity of the controller (s) of the Moracles group:
Moracles S.A,
Sq. Mavromichali 55
565 33 Thessaloniki
Greece

Authorized representative: Maria Tosidou

Tax Identification Number: 036775915

Moracles S.A.
Address: c/o Moracles, Mavromichali 55, 565 33 Thessaloniki
TIN: 036775915

The above-mentioned controller (s) of the Moracles group are called individually or
collectively as “Moracles”, “us”, “us” throughout this Privacy Policy.

Under certain circumstances, they are responsible for your data protection and privacy
jointly with third parties, such as banking and financial institutions, postal services
or electronic communications providers. You can find more information below
each section of this Privacy Statement.

Where do we process your data?
The personal data we collect from you is mainly stored within one of the countries
within the European Union or the European Economic Area (hereinafter referred to as “the EU / EEA”), but may,
when necessary, be transported and processed to and from countries outside
of EU/EEA. Any such transfer of your personal data
is carried out in accordance with applicable laws and without prejudice to your
legal rights.
Whenever appropriate, Moracles uses standard contract terms to
ensure a similar level of protection to that provided within the EU / EEA or other
legal reasons for the transfer.

Who has access to your data?
Your personal data is available and accessible only to those who need them
to fulfill the intended purpose of the processing. To the extent that it is
necessary, your personal data may be shared between companies and
within the Moracles group, to providers and subcontractors (executors
of processing and processing subcontractors) who perform specific tasks on behalf of
Moracles and independent third parties.
Additionally, we may disclose personal information to third parties, if we
reasons to believe that the use or disclosure of such information is necessary or
recommended for: (i) conducting investigations into possible breaches of the law; (ii) recognition,
contact with or to take legal action against someone who may be violating an
agreement with us, (iii) investigating security breaches or cooperating with
governmental authorities in relation to a legal matter, or (iv) to protect our rights,
security or our property, including fraud prevention.
We reserve the right to transmit any personal data we have
for you in case we merge or are acquired by a third party, in case
we undergo some other business transaction, such as reorganization, or in the event that
such a transaction is proposed.

What is the legal framework for processing?
Moracles is not allowed to collect, process, use, store, etc.
personal data without a valid legal basis. Legitimacy can be derived from
your consent, by contract, statutory obligations or by our legal interest as
business. For each specific purpose of processing the personal data that
we collect from you, we inform you about which legal basis applies and which
rights you can exercise, whether the provision of personal data is required by
law or is required for the conclusion of the contract as well as whether it is an obligation to
provide personal data and what the possible consequences of your choice not to
provide them.

What are your rights?

Right of access:
You have the right to request information about the personal data we maintain
at any time. You can contact Customer Service which will
provide your personal data via email.

Right to portability:
Whenever Moracles processes your personal data by automated means
based on your consent or agreement, you have the right to obtain a copy of your
data in a structured, common format that can be read by a machine, which will
be transferred to you or elsewhere. This includes only our personal data that you
provided.

Right of correction:
You have the right to request a correction of your personal data if they are incorrect,
including the right to fill in incomplete personal data. In the event that you
have a Moracles account, you can edit your personal data on
the account page.

Right to delete:
You have the right to delete your personal data processed by Moracles
at any time. Your request will not be granted if it is met
with one of the following reasons:

* you have an open issue with Customer Service

* you have an open order that has not yet been shipped or has been partially shipped

you have a balance with Moracles, regardless of payment method

Right to object to processing based on a legitimate interest:
You have the right to object to the processing of your personal data which is
based on Moracles legal interest. Moracles will not continue to process your
personal data unless a legitimate legal basis for processing can be found, which
would override your interests and rights due to legal claims.

Right to restrict:
* if you oppose any processing based on Moracles’ legitimate interest,
Moracles will restrict all processing of such data pending verification
of its legitimate interest.
* if you oppose Moracles’ legitimate interest in processing, Moracles will limit any
processing of such data pending the verification of the legitimate interest.
* if you have claimed that your personal information is incorrect, Moracles will limit any
processing of such data, pending verification of accuracy
said data.
* if data processing is illegal, you can oppose deleting
and request a restriction on the use of your personal data
* if Moracles no longer needs personal data but is necessary for you in order to
defend any legal claims made by you.

How do you exercise your rights?
We take data protection very seriously. If you wish to exercise
your rights as defined above or in case you have questions about
our privacy policy or the processing of your personal data by us, you can
contact us at any time at info@moracles.gr

If you have a Moracles account, you can exercise the right of access, portability
and correction our personal information on your account page where you can
also delete your account.

Data Protection Officer:
We have appointed a Data Protection Officer to ensure that we will process
constantly your personal data in an open, accurate and legal manner. You can
contact the Data Protection Officer at info@moracles.gr adding to its
subject: DPO.
Right of complaint to a supervisory authority:
If you have any objections regarding the way in which the Moracles Group processes and protects
your personal data and privacy, you have the right to submit, at any time,
complaint to the Hellenic Privacy Protection Authority (Privacy Enforcement Authority
– ADAE)

Privacy Statement Updates:
We may need to update our Privacy Statement. The latest version of the Declaration
of our Privacy Policy is always available on our site.
The revision history is listed in the Changes section of this privacy
protection policy