PRIVACY POLICY 

EFFECTIVE DATE: 08 December 2023

This Privacy Policy governs the processing of personal data which takes place when you, the user, use our services through our APP or via any connected service (e.g. e-mail, social media). We, ZELUS P.C. respect the right to privacy and protection of personal data of our users. All our processing of your personal data done on or via the use of our application and any related service will comply with the rules set out in this Privacy Policy and will be in accordance with the requirements set out in the General Data Protection Regulation (GDPR).

Please read this Privacy Policy together with our Terms and Conditions carefully because they are an integral part of our relationship with you. In case you do not agree with our privacy policy set here, please do not use our services.

 

• DATA CONTROLLER 

When you create an account via our app and use our services, we – ZELUS P.C., having its registered seat at 43 Aisopou, Chalandri, 15238, Athens with registration number 150686103000, are in principle responsible for the processing of your personal data. 

If you have a question or request about what happens to your personal data in the provision of our services, please contact us at vong@zelus.gr

 

• WHAT PERSONAL INFORMATION WE COLLECT AND PROCESS 

When you use our services we may collect and process the following categories of personal information, depending on the use of our services you make, that can be provided by you, when using our services and/or creating an account with us or collected automatically:

User account (when you create an account with us): Name, email addresses, username and password, profile picture. Optionally: top size, bottom size, shoe size, country.

Electronic identification data and technical information (when you visit our app and use our services): IP addresses, device ID, unique device identifiers, type of browser, date and time of access, length of visits and interaction with pages, scrolling, clicks and mouseovers, operating systems and platforms.

The content that you upload or submit (user content) including photos of your clothes, shoes and accessories, your daily outfits, your styling preferences, who other users you follow, connect or interact with, other links you connect or interact with through our service.

When you use our mobile app via social networking services (SNS), the information that you have provided to the applicable SNS(such as your name, profile picture, e-mail address and other information you make available via the applicable SNS).

Location information: Some features of the service are only available by using your location information.  We may use gps technology to determine your current location, only if you want to access these particular features and you have given your consent to be geolocated by GPS. 

Metadata: We collect metadata in or about the user content, such as the date and time you created the content, the type of content (i.e., a photo, text) and technical information about your camera or other Glasses sensors related to the content.

All data requested for the use of our services is mandatory unless it is specified otherwise. Failure to provide mandatory data makes it impossible to provide you with our services. Optional data is indicated specifically when accessing our services, and you are free not to communicate this data. The possible consequences in case of not submitting optional data will be respectively indicated.

For the best operation and the provision of our services to you, we use technology (algorithm), in the following cases:  a) to recognize characteristics of the clothing items you upload and digitize (category, color, style, design, etc.), so as to speed up the categorization process and reduce the effort you need to put in, b) to remove the background of the images you share so that the clothing items can be seen more clearly and c) to identify to the best of our ability items that are not clothing. We also use algorithm to suggest you combinations of clothing items that may be of interest to you. 

 

• PURPOSE OF COLLECTIΟΝ AND PROCESSING THESE DATA

In this section we provide you with an overview of all the reasons why we collect and process your personal information. 

We process your personal data for the following reasons: 

1.   to create an account for you and to provide our services to you via the use of our mobile app;
2. to inform you about our services, news, opportunities and commercial information;

(c) to ensure functionality and improve our services;

(d) for statistical reasons;

(e) for security reasons and misuse detection, prevention and reporting;

(f) to inform any third party in the context of a possible merger with, acquisition from/by or demerger by that third party;

(g) to comply with our legal obligations as well as with any valid request from policy, judicial or governmental authorities. 

 

• WHAT MAKES THE PROCESSING OF YOUR PERSONAL DATA LEGITIMATE

The data protection laws require us to indicate to you which legal option we rely on to make the processing of your personal data legitimate. We need to clarify this for each of the purposes listed in the section above. 

For purpose (a) we process your personal data because it is necessary to perform the agreement that we have with you to provide you with our services. 

We will ask for your consent when necessary to determine your location in order to provide you with particular features of our services. Your consent will be also asked to access photos stored in your mobile device when you want to upload them to the app. You can withdraw you given consent by updating your settings.

For purpose (b) we will ask for your consent to send you commercial material, newsletters etc.

You can withdraw your consent at any time by changing your preferences at the settings. 

Until the withdrawal of your consent, when needed, the lawfulness of the processing is based on your prior consent and is not affected.

For the purposes (c) to (f) we process your personal data because it is necessary for purposes of our legitimate interest, including gaining insight in how our services are used, improve our services, security and safety interests. 

For purpose (g) we need to process your personal data to comply with our legal obligations. 

 

• RECIPIENTS OF DATA

For the performing of our services to you and the reasons stated above, your personal data may be sent to the following categories of recipients:

• yourself;
• other users: Your daily outfits and any accompanied information that you post or upload to the service is public and visible by other users that follow you;
• our service providers;
• in order to provide you with our services we use Hetzner Online GmbH (based in Germany) as our platform host (data center) and we use the europe-west1 (Belgium) data center on Google Cloud Platform to store your personal data (firebase);
• our shareholders and potential acquirers;
• governmental, judicial and other competent bodies, in accordance with applicable law or when necessary to protect our rights and interests.

We do not sell, share or lease your data with third parties. Apart from the above-mentioned categories for the purposes stated, your personal data is not shared with anyone else unless you desire to do so. 

 

•  HOW LONG DO WE RETAIN YOUR PERSONAL DATA

We only retain your personal data for as long as it is required to achieve the purposes listed above in the section “PUPROSE OF COLLECTIΟΝ AND PROCESSING THESE DATA”. 

We will delete your data when they are no longer necessary for these purposes unless there is: 

• an overriding interest of our company or any other third party in keeping your personal data;
• a legal or regulatory obligation or a judicial or administrative order that prevents us from deleting them. 

 

• DATA PROTECTION

The confidentiality and protection of your data is of vital importance to us. We take appropriate technical and organizational measures in accordance with the applicable laws to preserve the confidentiality and security of your personal data.  Access to the personal data collected is limited only to our authorized employees and data processors who need access to this information. 

We may use other IT companies to process the personal data collected. These companies are considered data processors and have strict contractual obligations to maintain the confidentiality of the processed data and offer at least the same level of security as we do.  Data processors have an obligation not to allow third parties to process personal data on our behalf and to access, use and/or keep the data secure and confidential.

In principle, we do not disclose your personal data to third parties, except for the exceptions mentioned above and under the section “RECIPIENTS OF DATA”.

We do not transfer any of your data outside the European Union. For the hosting, storing and processing we use means located all on the territory of the European Union.

 

• WHAT RIGHTS DO YOU HAVE? 

You have a right to access, correct or erase your personal data or limit or oppose the processing of your personal data. You also have a right to data portability. In this section we explain how and under which conditions you may exercise these rights. 

You have the right to request access to all personal data processed by us insofar it pertains to you and you can ask for a copy of your personal data that we process. We reserve the right to refuse multiple requests for access that are clearly submitted for causing nuisance or harm to us or others. 

You have the right to ask that any personal data pertaining to you which are inaccurate, are corrected free of charge. If a request for correction is submitted, such request must be accompanied of proof of the flawed nature of the data for which correction is asked. 

You have the right to request that personal data pertaining to you to be deleted if they are no longer required in light of the purposes outlined above. However, you need to keep in mind that a request for deletion will be evaluated by us against: – our own or a third party’s overriding interests; -legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that we limit the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings. 

You have the right to oppose the processing of personal data for the purposes (c) to (f) in section titled section “PUPROSE OF COLLECTIΟΝ AND PROCESSING THESE DATA”, but you are required to explain the particular circumstances on which your request for opposition is based. 

When the procession of your data is based on your consent, you may revoke it at any time.

Each request addressed to us can be send via e-mail to vong@zelus.gr

An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state and specify which right you wish to exercise and the reasons for it, if such is required. Please be aware that in order to verify your request, it should be dated and signed and we may ask for specific information to confirm your identity.

We will promptly inform you of having received this request. If the request proves valid, we will notify you as soon as reasonably possible and at the latest thirty (30) days after having received the request. 

If you have any complaint regarding the processing of your personal data by us, you may always contact us via the e-mail address vong@zelus.gr. If you remain unsatisfied with our response, you may file a complaint with the competent data protection authority, i.e. the Greek Data Protection Authority.

 

• THIRD PARTY LINKS – PRIVACY POLICY

Our application may contain links to other websites operated by third parties. When you click on these links or otherwise visit or use the services or websites of other parties, you should be aware that their own privacy policies apply, as well as their own terms of use. We are not responsible for the privacy policies or practices of other parties.

 

•   DATE OF PUBLICATION- MODIFICATION

The privacy policy has been adopted on the date indicated in the title of the document and it may change from time to time whenever necessary. Please check the App occasionally for any updates. In case of any policy amendment, we will post the revised policy with the date on which it is effective. If any provision of this policy is held to be illegal or invalid for any reason, it shall be regarded as not written and shall not affect the validity of the remaining provisions.