Privacy Policy

Privacy Policy

1. Introduction

The protection of your personal data is a priority for our Company under the name «airobots.ai» (hereinafter “the COMPANY”), which is headquartered in … and is legally represented, KIEFER Societe Anonyme Ε. For this reason, we adhere to this specific Privacy Policy, to help you understand why we collect your personal data and how we use it, and to demonstrate our compliance with applicable data protection legislation. This Policy sets out the terms and conditions that our Company adheres to for the protection of your personal data as Users of the Website. This policy includes the rules on the basis of which we proceed with any collection and processing of your personal data and ensure the confidentiality of this information, when purchasing and using our products or services through our points of sale (stores), by telephone, applications or our Website.

2. Definitions

2.1. For the interpretation of this Policy, the following definitions apply:

“Principle”: The Personal Data Protection Authority, which, according to article 9 of Law 4624/2019, constitutes the supervisory authority of the GDPR, Law 4624/2019 and other regulations concerning the protection of individuals with regard to the processing of personal data in the Greek Territory, is exercised by the Authority established by Law 2472/1997 (A’ 50). The Authority is an independent public authority according to article 9A of the Constitution and is based in Athens.

“GDPR”: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the transposition into national law of Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 and other provisions.

“Company” or “We”: The Company with the name ”…..”

“Website”: The Company’s business website, accessible via the domain name www…..

“Law 4624/2019”: Law 4624/2019 entitled “Personal Data Protection Authority, implementing measures of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and incorporation into national legislation of Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 and other provisions”.

“Policy”: This personal data processing policy, which sets out the terms and conditions adhered to by our Company, for the protection of your personal data as Users of the Website.

“Cookie Policy”: The policy, which sets out the terms and conditions adhered to by our Company, for the processing of your personal data as Website Users when we use cookies. For more information, please read the Cookies Policy.

“DPO”: The Company’s Data Protection Officer, who is available for communication with data subjects on any issue related to the processing of their personal data and the exercise of their rights under the GDPR by sending a message to the email address ….

“Users” or “You”: Website users

2.2. Otherwise, the definitions of article 4 of the GDPR and article 4 of Law 4624/2019 apply.

3. Object

3.1 When you make a product purchase, receive the services we offer or communicate with us or our partners, it is necessary for us to process your personal data.

3.2 When processing your data, we comply with applicable law and, in addition, we take into account your opinion and wishes, so as to understand your expectations and ensure that they are reflected in our business decisions. In this context, we respect the privacy and confidentiality of your personal data and are committed to its protection.

3.3 Our Company’s Privacy Policy provides detailed information about when and why we collect your personal data, how we use and process it, for how long we retain it and finally, under what conditions we may share it with others.

3.4 This Policy applies only to the Website. Users should note that our Website may contain links to other websites, however our Company is not responsible for the data protection practices and terms or the content of such websites.

4. Website Navigation and Use of Cookies

4.1 Our Company may process your personal data for technical operation and to improve your experience when browsing our website. For this reason, cookies are used, through which we collect your personal data. For more information, please read the Cookies Policy.

4.2 We take care to collect only the Data that is strictly necessary for your use, which is appropriate and clear for the purpose for which it is intended. This Data includes the following: Data when creating a user account on the Websites or Apps, such as name, surname, email address, telephone number, etc., internet protocol address, type and version of browser you are using, operating system you are using, website from which you may be redirected to our Website, date and time of access to our Website, your internet service provider, navigation data within the Website, details of the documents you provide or show to prove your age or identity (police or student ID or passport details) when required by law or the Company’s policies and always in accordance with the provisions of applicable legislation, purchasing behavior data, details of any complaints or comments you make, details of purchases you have made, products added to or removed from your cart, list of products you wish to purchase (wish list), coupon redemptions, websites you visit and how and when you contact us, payment information, your comments and product reviews, shopping interests and preferences, which help us recommend specific products and services that you are interested in, recording of your telephone communication with a representative of our call center, for the purposes of ensuring proof of transactions, in accordance with what is specifically defined below.

We will only ask for and use the Data we have collected to recommend products or services of interest to you and to further improve your shopping experience with us. Of course, it is always your choice whether to share such information with us.

4.3 The purposes of processing your data are as follows: Providing you with our Website, both in terms of its use and its content, collecting information about your browsing and purchasing patterns in order to improve your experience while browsing our Website, promotion of advertising messages or targeted promotion actions (targeted advertising), serving technical purposes that are necessary for the effective operation of our Website, particularly in relation to online transactions and navigation. If you choose not to share your Data with us or decline to be contacted, we may not be able to provide certain services you have requested.

4.4 The legal basis for processing your personal data for the purposes of providing our Website and its effective operation is Article 6 § 1 (f) of the GDPR, which allows us to process your personal data for the promotion of our Company and our products/services through the Website to internet users with your consent.

4.5 For the purposes of providing our Website and its effective operation, we generally retain your personal data until the end of your visit/session on our Website. For the purposes of improving your browsing experience and promoting commercial messages to you, we generally retain your personal data for a period of eighteen (18) months from your visit/session on our Website, unless a different period of time is expressly provided for in this or another of our policies, such as in the cookies policy.

5. Transactions with our Company

5.1 Our Company has a wide range of products for purchase, while providing a wide range of related services, such as product insurance coverage, installation and repair, device recycling program and customer loyalty programs.

5.2 When purchasing products and depending on the nature of the services provided, you provide us with the following data: full name, email address, home address, contact phone number, tax data, credit card details, bank account details, transaction details, service provision data (e.g. fault type data, repair data, etc.), payment data, recorded telephone calls, as long as the transaction takes place through our call center.

5.3 The purposes of processing your data are the following: Execution of our Company’s contractual obligations towards you, Proper fulfillment of the provision of our services, Tax use and use for billing and proofing purposes of our products/services.

5.4 The legal basis for processing your personal data is Article 6 § 1 (b) of the GDPR (performance of a contract), which allows us to process your personal data to the extent necessary for the provision of our products and services. With regard to data of tax interest, the legal basis for processing your personal data is Article 6 § 1 (c) of the GDPR (compliance with a legal obligation), which allows us to process your personal data to the extent necessary for our compliance with our legal obligations arising from tax legislation, as applicable at any time.

5.5 We retain your data for the following periods from the termination of the contract between us: ten (10) years regarding data of tax interest, and regarding the data of each transaction for a period of up to five (5) years from our transaction with you, regarding the remaining data of your customer relationship with us for as long as you are a customer of our Company and, after the relationship with us is terminated, for a period of up to five (5) years after your last transaction with us.

5.6 Providing your personal data above is a prerequisite for entering into a contract for the provision of products/services with us. If we do not have the required data, then we will not be able to successfully complete any transaction with you.

6. Contacting the Company to resolve issues regarding products/services

6.1 Our Company provides the ability to communicate to submit requests or resolve issues regarding products and services, at all stages of the transaction with it and through various means of communication. Specifically, the ability to directly chat with a representative (live chat), telephone contact, filling out a contact form and the online store search for in-person service is provided.

6.2 The personal data collected during your communication with the Company are as follows: full name, order number, mobile phone, email address, postal code, personal message content/customer request data, recorded telephone calls, as long as the communication takes place through our call center.

6.3 The purpose of processing your data is to communicate with you in the context of the proper execution of our services, to provide you with excellent service, as well as to resolve any of your requests or other issues within the context of our relationship.

6.4 The legal basis for processing your personal data is Article 6 § 1 (f) of the GDPR, namely our legitimate interest in providing appropriate support to our customers by responding to and communicating with them directly regarding their requests.

6.5 In the event of your telephone communication with a recording of the relevant call, we retain the relevant material for 120 days. Regarding the other categories of data, we will retain your personal data for as long as you are a customer of our Company. After you terminate the relationship with our Company, we will retain your data for a period of up to five (5) years, after your last transaction with us.

7. Creating an Account on our Website

7.1 When registering by creating an account on our Website, you provide the following data: full name, email address, mobile phone.

7.2 The purpose of processing your data is to provide you with our services, through a personalized user experience.

7.3 The legal basis for processing your personal data is Article 6 § 1 (b) of the GDPR (performance of a contract), which allows us to process your personal data to the extent necessary to provide you with our Website and our products/services in accordance with the terms of use and general terms of business agreed between us.

7.4 We generally retain your personal data for as long as we provide you with services and for five (5) years after their termination.

8. Sign up for Newsletters

8.1 When subscribing to our Newsletter, you provide us with the following data: Email address, newsletter reading data.

8.2 The purpose of processing your data is to receive our newsletters, which contain updates and advertisements about our Company’s products, services and activities.

8.3 The legal basis for processing your personal data is Article 6 § 1 (a) of the GDPR, which allows us to process your personal data with your consent.

8.4 We retain your personal data until you withdraw your consent.

8.5 You have the right to withdraw your consent at any time by using the relevant electronic application for unsubscribing from our updates, which is included in each of our messages to you. The withdrawal of your consent does not affect the lawfulness of the processing that was based on consent before its withdrawal. The withdrawal of your consent is done in the same way as when it was given.

9. Commercial Communications

9.1 By subscribing to our Company’s list of acceptable commercial communications (marketing promotions), you consent to participate in advertising campaigns via email, SMS and telephone for new products, services or offers, in competitions conducted by the Company, in customer satisfaction surveys and in promotional activities on Social Media (social media).

9.2 The personal data we process are as follows: full name, email address, contact details, customer code, contractual relationship data, customer request data, competition participation data, purchase history, customer satisfaction level, customer comments, social media usage data.

9.3 The purposes of processing are the following: information about product availability, receipt of new products or current offers, communicating via email or text message about our products and services, contests, offers, promotions or special events, information about promotional activities regarding our products and services or services offered by our partners that we believe may be of interest to you, information about promotional actions, such as sending targeted messages via social media or third-party platforms.

9.4 The legal basis for processing your personal data is Article 6 § 1 (a) of the GDPR, which allows us to process your personal data based on your consent and until it is withdrawn. We retain your personal data until you withdraw your consent, otherwise up to ten (10) years from its collection.

9.5 You may request to stop receiving promotional messages, in the same way or means that you opted in to receive them. For example, if you receive a promotional email, there is an unsubscribe option at the end of it, while if you have received an SMS you can revoke your initial consent by sending a free message. At any time you may request to reactivate the receipt of promotional messages as well as to (re)stop sending them.

10. Social Media

10.1 We use social media (Facebook, Google, YouTube, Instagram, Twitter) to promote our products and services and to inform the public about our Company’s news.

10.2 When you interact with our Company’s social media through comments, likes or follows, your personal data is processed, in principle, in relation to the name and/or user photo you use as well as your preferences. This data is redirected to our Website, ensuring the provision of personalized information. The respective social media platform provides us with anonymized aggregated data on the preferences and other information of visitors to our pages on them, but will also process this data for its own purposes, as they are stated in each case. For more information, you can refer to the respective Privacy Policies of the social media platforms mentioned.

10.3 The legal basis for processing your personal data is Article 6 § 1 (a) of the GDPR, which allows us to process your personal data based on your consent and until it is withdrawn. We retain your personal data until you withdraw your consent, otherwise up to ten (10) years from its collection.

11. Trading Profile Preparation

11.1 With your consent, we may compile a transactional profile of you for the purpose of sending you personalized updates and offers as well as evaluating, improving and/or creating new products/services that better meet the needs and preferences of our customers. Based on your transactional profile, automated processing may then take place in order to make decisions to provide you with personalized updates and offers from our Company.

11.2 For the above purpose, we basically process the following personal data: name and surname, customer code, customer satisfaction level and comments, demographic data, purchase history, such as product purchase with receipt, repeated purchase of products from a specific Company, frequency of purchases from the Company’s Stores.

11.3 The preparation of your transaction profile takes place according to the following basic criteria: (a) status as a consumer and/or professional, (b) amount, time, frequency and characteristics of transactions, (c) consumer preferences, (d) payment method used in transactions with the Company, (e) duration of relationship with the Company, (f) nature and needs of your business based on transactions with the Company.

11.4 The compilation of your transaction profile has an exclusively positive impact for you, which consists of the possible provision of personalized updates and offers to you by our Company.

11.5 The legal basis for processing your personal data is your consent pursuant to Article 6 § 1 (a) of the GDPR. We retain your personal data until you withdraw your consent, otherwise up to ten (10) years from its collection. When providing your consent for the above purpose, you will receive more specific information about the processing of your personal data, which will apply in addition to this Policy.

12. Credit Rating

12.1 In the context of providing credit when buying and selling our products, upon your consent, we will process credit rating data, data on default of financial obligations and data on your financial behavior. The purpose of processing your personal data is to assess your creditworthiness. This purpose includes debt management and preventing or limiting the possibility of defaulting on your obligations to the Company. Furthermore, upon your consent, we will gain access to and further process your above data, which was initially collected from you through the Company for the provision of credit by third-party banks collaborating with us. Sources of your data are, on the one hand, primarily you and, on the other hand, publicly accessible sources, such as business directories and lists, court registry books and registers, mortgage registries / land registry offices and GEMI, companies affiliated or collaborating with the Company under a franchise, distribution or agency agreement, as well as credit rating agencies.

12.2 The legal basis for processing your personal data is your consent pursuant to Article 6 § 1 (a) of the GDPR. We retain your personal data until you withdraw your consent.

13. Data Retention Periods

13.1. We retain your personal data for the periods described above, during which the purposes for which they are processed remain valid.

13.2. Our Company may retain your personal data even after the purposes of collecting and processing it have been fulfilled in the following limited cases: if we have a legal obligation under a relevant legal provision, for use before tax authorities as well as any other competent public authority within the legal limitation period, as required for the operation and organization of our Company, provided that your data is anonymized, to defend our rights and legitimate interests before any competent Court and any other public authority within the framework of the prescribed limitation period of the Civil Code.

13.3. After the retention period, your personal data is destroyed from our physical and electronic files in compliance with the respective policy of our Company and provided that their retention is no longer required to fulfill the purposes described above.

14. Who may be Recipients of your Data?

14.1 Subject to the following terms, our Company does not provide your personal data or link its file in exchange for financial or other consideration with any third-party private companies, natural or legal entities, public authorities or services or other organizations. To serve the processing purposes referred to in this policy, our Company may provide access to or transfer the following types of your personal data to the following processors on its behalf and at its instruction: to the retail services group, for organizational and management purposes at the group level, to service providers collaborating with us, such as providers who display advertisements for our products and services and for the products of partners, suppliers and third parties, to companies that provide us with technical support and maintenance of the software programs and applications, which we use in the context of providing our Services, to insurance companies collaborating with us in order to complete the conclusion of insurance contracts, to financial institutions for the transfer of remittances, the use of payment instruments and, in general, the execution of payments for our services, preference data and contact information to third-party marketing and advertising companies for commercial communication, marketing and advertising of our Services, if you have given your consent or for sending commercial communications, as described above, your tax data to the competent tax authorities in order to comply with our legal obligations arising from tax legislation.

14.2 In the event that we are obliged by a court or other administrative authority, as well as in any other case where we have a legal obligation to do so, our Company may disclose your personal data to the extent provided by law.

14.3 Within the framework of the provisions of articles 13 § 1 8’ of the GDPR and 4 § 4 of Law 3758/2009, as applicable at any time, in the event of an overdue debt, we reserve the right to transfer your personal data to debtor information companies as well as lawyers and law firms. The above transfer and processing of your personal data to the cooperating debtor information companies and the lawyers/law firms cooperating with the Company will be carried out by order and on behalf of the Company for the purposes of informing you of the existence of overdue debts and for negotiating the time, method and other terms of their repayment.

15. Transfers of personal data to third countries outside the EEA

15.1. The Company does not transfer your personal data to third parties outside the European Union unless the conditions of Articles 44-49 of the GDPR are met and an appropriate check has been carried out prior to the transfer, or unless the manufacturer/supplier is outside the EEA and the transfer of your personal data is necessary for the warranty. This also applies when our suppliers or service providers use equipment or resources located outside the EU and process your personal data on our behalf.

15.2. In the event of a transfer of personal data to third countries, it will continue to be subject to appropriate safeguards and will be protected in the same way as it would be within the EEA.

15.3. The safeguards and guarantees we receive for the protection of your personal data during transfers to third countries include, among other things, the adoption of standard contractual clauses of the European Commission in our contracts with the recipients of the data.

16. Security and Confidentiality of Personal Data

16.1. Our Company, in order to ensure the proper use and integrity of your personal data as well as to prevent unauthorized or accidental access, processing, deletion, alteration or other use thereof, implements appropriate internal policies, while taking all appropriate organizational, technical, physical, electronic and procedural security measures, as well as technological standards, in accordance with applicable laws and regulations.

16.2. The processing of your personal data by our Company is carried out in a manner that ensures their privacy and their physical and logical security and confidentiality, taking into account the latest developments, the cost of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity for your rights and freedoms.

16.3 The processing of your personal data is carried out exclusively by personnel or associates of the Company authorized for this purpose, who are bound by strict obligations to maintain their confidentiality (Data Protection Officer). The Processors performing the processing on our behalf have agreed and contractually committed to the Company: to maintain confidentiality, not to transmit your Data to third parties without the Company’s permission, take appropriate technical and organizational security measures, comply with the legal framework for the protection of personal data and in particular Regulation 979/2016/EU (otherwise GDPR).

17. Your Rights

Access Right: You have the right to request access to and receive a copy of your personal data held and processed by the Company.

Right to Rectification: You have the right to request the correction of incomplete or inaccurate data held by the Company, upon presentation of the necessary evidence, from which the need for correction or completion arises.

Right to Deletion: You have the right to request the deletion of your personal data, provided that there is no reason for continuing the processing. It is noted, however, that this right may in some cases not be possible for specific reasons provided for by law and which will be communicated to you at the time of submitting or processing your request.

Right to Restrict Processing: You have the right to request the restriction of the processing of your personal data, such as in cases where you wish to have the accuracy of your personal data re-defined or when you object to the use of your personal data, but the Company may have a legitimate interest in retaining it.

Right to Portability: You have the right to request the transfer of your personal data to another controller. It is noted that this right only applies to automated information, which was used with your consent or for the performance of the contract with you.

Right to Object to Processing: You have the right to object to certain types of processing (e.g. direct marketing).

Right to Object to Automated Individual Decision-Making, Including Profiling: You have the right to object to automated individual decision-making, including profiling, which produces legal effects concerning you or significantly affects you.

Right to File a Complaint with the Authority: You have the right to submit a complaint to the Personal Data Protection Authority (1-3 Kifissias Avenue, P.C. 115 23, Athens, tel. 210 6475600, contact e-mail: contact@dpa.gr), if you believe that your rights have been violated by acts and/or omissions of the Company.

If you wish to exercise your above rights, please contact us: By sending an email to: … or by letter to the address: …. Your request will be responded to within 30 days from the date of receipt of the application. The above deadline may be extended by up to two months when a request is complex or multiple requests are submitted simultaneously. We must inform you that, although the submission of your request is free of charge, a reasonable fee may be imposed in the event that a request is manifestly unfounded, excessive or repetitive. Our Company has the right not to accept any of your requests (such as the right to erasure or restriction of processing), if the conditions set out in the GDPR are not met or are not sufficiently proven. In this case, as in any of your requests, we will respond to you in writing in accordance with the above times.

18. Your Obligations

18.1. By using the Website and by providing your personal data upon consent, you acknowledge that you are obligated to provide true, accurate and complete information requested by our Company. Furthermore, you must inform our Company of any changes to this information, in order to keep it up-to-date and accurate.

18.2. By using the Website, you confirm that you are over sixteen (16) years of age. If you are under sixteen (16) years of age, you are obligated to refrain from any use of the Website as well as from any provision of your personal data without the approval of the person exercising your parental responsibility. If you do not comply with the above obligations, you must immediately notify our Company.

18.3. In any case, by using the Website you acknowledge that our Company is not liable for your breach of the above obligations to the extent that it is unable, even if it makes reasonable efforts, to verify your age or the consent of your parent or guardian.

19. Contact

If you have a question or complaint about this Policy and how we handle your personal data, please contact us:

By email to the address: support@sophea.ai

20. Policy Review

We reserve the right to revise this Policy by posting an updated version on our Website. The revision of the Policy becomes effective upon publication on our Website.

21. Personal data in the context of the operation of the Video Surveillance System.

This notice aims to provide you with information on how the company, as the Data Controller, manages your personal data, which it processes through the video surveillance system it has installed at its premises.

21.1 LEGAL BASIS AND PURPOSES OF PROCESSING: Your personal data is processed for the protection of employees, customers or third-party visitors as well as the Company’s assets and for the security of its facilities. The processing is necessary for the purposes of our legitimate interests and those of third parties, as mentioned above (Article 6 § 1 f GDPR). Our legitimate interests consist in the protection of the Company’s goods and facilities from illegal acts of third parties. The same applies to the safety of life, physical integrity, health and property of our personnel and third parties - visitors to the Company. We only collect image data and limit the capture to areas that we have assessed as having an increased likelihood of committing illegal acts, such as at the Company’s entrances and cashier, without focusing on areas where the privacy of the persons whose image is taken may be unduly restricted, including their right to respect for personal data.

21.2. PERSONAL DATA WE PROCESS: The personal data collected through the Company’s video surveillance system consists of the image of the persons moving within our facility as well as any other personal information you provide to us on your own initiative in any communication with us.

21.3. DISCLOSURE OF PERSONAL DATA: Only duly authorized employees of the Company have access to your data. We do not share your personal data with third parties, except for video surveillance system support service providers. Exceptionally, we may disclose your personal data to third parties, including the competent police and prosecutorial authorities, only if there is a relevant obligation by law, or we are obliged to do so pursuant to a decision/order of a judicial, regulatory or other competent public authority. We do not transfer your personal data outside the European Economic Area (EEA).

21.4 STORAGE PERIOD: We retain your personal data for the period strictly necessary to achieve the purpose for which it was collected and in accordance with relevant legislation. Your data is securely destroyed after fifteen (15) days from its collection. If necessary, especially in the context of investigating security incidents at our facilities, we will keep your personal data for a longer period of time, always in accordance with the specific provisions of applicable legislation.

21.5. YOUR RIGHTS: You have the possibility at any time to exercise your data rights. You have the rights of access, rectification, restriction of processing, portability, opposition, objection to automated decision-making and appeal to the competent Supervisory Authority (Personal Data Protection Authority, 1 Kifissias Ave., Athens, 115 23, complaints@dpa.gr).

21.6 DATA SECURITY: We implement appropriate organizational and technical measures to protect the security, availability and integrity of your personal data, such as indicative corporate procedures for data processing through the Company’s video surveillance system.

22 Applicable Law, Competent Courts

Applicable Law is Greek Law (L. 4624/2019), as formulated in accordance with the General Regulation for the Protection of Personal Data 2016/679/EU, and in general the applicable national and European legislative and regulatory framework for the protection of personal data. The competent courts for any disputes arising related to your Data are the Courts of Piraeus.