Privacy policy

Welcome to Fodby and our website and shop at www.fodby.gr. At Fodby, we take the protection of your Personal Data very seriously.

This Privacy Policy explains which Personal Data we collect from you via our website and shop, what we use it for, when we delete it and how your data is protected. In addition, we will inform you of the respective legal basis that allows us to process your data. Finally, we will also tell you about your rights in connection with the processing of your data.

What is Personal Data?

Personal Data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

What is Processing?

"Processing" means and covers virtually any handling of data.

 What law applies?

We will only use your Personal Data in accordance with the applicable data protection laws, in particular Cyprus, law no. 125(I)/2018 (“DPA”) and the EU's General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

Who is responsible for data processing?

The responsible party within the meaning of the DPA and the GDPR is Fodby of Aristotelous 11, Aglantzia, Cyprus, 2107  (“Fodby ”, “we”, “us”, or “our”).

If you have any questions about this policy or our data protection practices, please contact us using hello@fodby.gr or write to us at the above address.

Data collection

All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:

  • you have given your consent;
  • the data is necessary for the fulfilment of a contract / pre-contractual measures;
  • the data is necessary for the fulfilment of a legal obligation; or
  • the data is necessary to protect the legitimate interests of our company and business.

We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with the Cyprus Tax Department and Companies House and others for up to 8 years. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

Data transfers

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

a) Internal

If necessary, we transfer your Personal Data within Fodby. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to fulfil your order or to contact you in case of queries.

b) External bodies

Personal Data is transferred to our service providers in the following instances:

  • in the context of fulfilling your orders, shipping and delivery,
  • to use marketing services and to advertise our products online,
  • to communicate with you,
  • to provide our website and shop, and
  • to state authorities and institutions as far as this is required or necessary.

We usually do not transfer Personal Data to countries outside Cyprus or the EEA. However, if we do, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.

Security of your data

In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorised persons, we use appropriate technical and organisational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Your Rights and Privileges

a) Privacy rights

Under the DPA and GDPR, you can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;

b) Updating your information

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent

You can withdraw consents you have given at any time by contacting us.

d) Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The Commissioner for the Protection of Personal Data (the “Commissioner”) 1 Iasonos Street, 2nd Floor, 1082 Nicosia, Cyprus and their website can be found at www.dataprotection.gov.cy. We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner or any other supervisory authority.

Processing of your Personal Data

a) Log files

As mentioned above, we want to provide you with an optimal user experience in our online shop and with our advertisements, which is tailored to your individual needs. To this end, we work together with various service providers and technology providers and use cookies and tracking methods.

 The following data is collected anonymously for the purpose of demand-oriented design and optimization of this website:

  • Information on the device used (e.g., operating system, browser, screen resolution, language set.
  • Information on pages viewed during the website visit (e.g., category or product detail pages)
  • Information within the ordering process (e.g., order number, delivery and payment method, shipping and/or billing address)
  • Information on access data (e.g., entry via email newsletters, other websites or online advertising measures).

The scope of the stored and processed data is limited purely to the performance of statistical evaluations. Your IP address is made unrecognisable immediately after receipt, which means that it is not possible to assign usage profiles to IP addresses.

The collection of the data is necessary from a technical point of view in order to continuously optimise the functions as well as the presentation of our website on different devices, operating systems and browsers and to be able to make our offer more interesting for you as a user and is therefore based on the legitimate interest.

b) Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in Cyprus Law No. 112(I)/2004 as amended, (“ePrivacy Law”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

c) Cookie consent

Our website uses the cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

d) Hosting

We use the store system of the service provider Shopify International Limited, for the purpose of hosting and displaying the online store on the basis of processing on our behalf. All data collected on our website is processed on Shopify's servers on our behalf.

e) Contact options

We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message field itself. In addition, your IP address is processed out of technical necessity and for legal protection. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent.

f) Shopping with us

We process your first name, last name, e-mail address for the delivery of your order (digital delivery), billing address, and the data related to your contract with us data to handle the contractual relationship between you and us. Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes.

It is also possible for you to register for an account. For this purpose, you can choose a password together with your email address, both of which will enable you to log in more easily without having to enter your data again when you make a future purchase or to access your delivered product. We store the data you enter to set up a customer account through which your orders are recorded, executed, and processed. We will hold your data for further orders as long as you have your account with us.

g) Payment Data

If you make a purchase your payment will be processed via our payment service provider Shopify (Shopify Pay) and its associated payment methods. Payment data will solely be processed through Shopify and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

h) Newsletter

If you have subscribed to our newsletter, we will use your email address and, if applicable, your name to send you information about products, promotions, and news, as well as for customer satisfaction surveys. You will find the unsubscribe link at the end of each newsletter. The legal basis is your consent.

i) Marketing

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

j) Economic analyses and market research

For business reasons, we analyse the data we have on business transactions, contracts, enquiries,browsing behaviour etc., whereby the group of persons concerned may include contractual partners, interested parties, and users of our services.

The analyses are carried out for the purpose of business evaluations and market research. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarised data). 

Social Media

a) General

We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

b) When you visit our profiles and interact with us and others

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture).

Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account.  Please take care not to transmit or share sensitive data or confidential information (e.g., application documents, bank or payment data) via social media platforms; we recommend that you use a more secure means of transmission (e.g. e-mail).

Changes and Questions

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise this Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to talk to us regarding our privacy practices, please contact us using the details provided.

Effective Date

Monday, 28th of August 2023