Update for the GDPR Data
We would like to verify that for Starbucks the protection of personal data of our clients is of significant importance. For this reason we take the appropriate measures in order to protect the personal data processed, from any type of loss or leakage, potential forging or by any other way of unauthorized and unfair process securing that the process of your personal data is being applied always according to the obligations and specifications set by the current legal frame, both by the company itself and /or by third parties processing personal data on behalf of the company.
Processing Manager – Data Protection Officer (DPO)
Starbucks – Marinopoulos Coffee Company Cyprus Ltd, based in Nicosia, Themistokli Dervis 41, email: email@example.com , tel: +357 22 466462, fax:+357 22 466 463, website: http://www.starbucks.com.cy, informs that, for purposes of normal operation of its business activities, process personal data of its clients, according to the present national legislation and the EU Directive 2016/679 regarding the protection of individuals from the process of personal data and for the free circulation of these data ( General Data Protection Regulation, thus «GDPR»), as it applies.
For any issues regarding the process of personal data please contact directly the Data Protection Officer (DPO) Mr. Barmpounis Ioannis, email: firstname.lastname@example.org, tel: +357 22 466 462.
Which categories of personal data do we process?
The personal data that we collect from you and we process are the necessary needed and appropriate for the accomplishment of our pursued purposes and could be summarized in the following:
Personal Data, which you may provide us, in example:
• Identification Data (Name & Surname, date of birth),
• Contact Data (email address, land line number or mobile data number),
The personal data which we process are kept in written form or/also by digital media.
Which are the purposes of personal data process?
• In order to offer quality products and service
• In order to contact you and solve any possible questions you may express
It may be needed to contact you via email or telephone for administrative reasons, such as for example the management of your complains and generally the services provided.
• In order to inform you regarding our news and offers
In case you have consent to this under the conditions that defines the present legal frame, we will send promotion messages towards the members of the program My Starbucks Rewards regarding with current offers as well as the future actions of the company.
• In order to explore and manage possible complains you may express
Within the frames of complain management, we record any possible references you may provide, and we take care so that each one gets analyzed and solved whichever may be the issue that may address to.
• For the continuous improvement of our services as well as for the protection of company’s interests
The business goals for which we may use your information they in turn help us to improve the offered services to you and achieve a high end to your expectations.
• For the preservation of all legal interests also the protection of persons and goods
We use closed circuit TV (CCTV) and security cameras in order to be in position to protect the security of individuals as well as the materials and the facilities.
Which are the legal reasons of process of your personal data?
Starbucks - Marinopoulos Coffee Company Cyprus Ltd is processing your personal data with clarity according to the legal principles, of proportionality, confidentiality and integrity, according also to the purpose of limitation and punctuality, of the given retention time and minimization of data.
The legal basis for the process of your personal data may be:
(a) the consent under the conditions set by the present legal frame, i.e. the case of sending promotional - informing e-mails regarding offers and new products to our new clients,
(b) the necessity of the process of data in the concept of performing our contractual obligation or in the preliminary stadium before the actual application of the contract for the offer of products
(c) the necessity of process of data in the context of securing our legal interests, which may be τα οποία μπορεί να comprised i.e. of the research of client satisfaction survey and the security of individuals and facilities.
Data that concern kids
For the purposes of the present one, minors are concerned persons that have not fulfilled the 18th year of their age. In case verified that any type of personal data that might have been collected from a minor, these data would be deleted the as soon as possible.
Where your data are being shared?
Starbucks - Marinopoulos Coffee Company Cyprus Ltd shares your personal data indicatively to the following categories of recipients:
• Employees of Starbucks – Marinopoulos Coffee Company Cyprus Ltd
To the employees of Starbucks – Marinopoulos Coffee Company Cyprus Ltd, who are responsible for the evaluation of your requests as well as for the management and the recording of your complains within the frame of the relative obligations imposed by the law and the business policy. All your personal data are treated with outmost confidentiality and discretion, since the employees responsible for the process of your personal data are in an adequate and significantly high level of knowledge for their protection and have been considered as persons of moral and mental integrity.
• State authorities, Law enforcement authorities
When this is necessary, i.e. in the case of a tax control and according with the relevant procedures, as well as in the case that it would be needed to provide information to a police and/or judicial authority, provided that it will emerge any kind of litigation and in any case that is imposed to reassure the normal operation of the company and our business interests.
• Collaborates of our company (legal advisors etc.)
Starbucks – Marinopoulos Coffee Company Cyprus Ltd connects with collaborates at whom may assign the process of personal data (for example: legal advisors, company that provides CRM services). In these cases, the company still is responsible for the process of your personal data and indicates each point of the process, signs a special contract with the parties to whom assigns activities of data process, in order to secure that the process is being operated and accomplished according to the current law frame and that each individual has the right and the potential freely and with no obstacles to exercise the right that the legal frame has defined.
Forwarding your personal data to third countries
Your personal data are not being forwarded to third countries [ that is to countries outside the European Financial Area].
The storage time of the data is being decided in accordance toy the following special factors in accordance to each case:
When the process is being followed based on a contract, your personal data are being stored for as long as it is necessary to accomplish the contract and for the foundation, exercise, and/or support legal claims under the contract.
For purposes of marketing and promotion of products and offers (marketing activities), your personal data are being stored until the withdrawal of your consent. This may happen by you at any time. The withdrawal of consent does not affect the legal integrity of the process which was based on the given consent in the time being before its withdrawal.
Which are your rights in relation to your personal data
Any individual whose data are being processed by Starbucks is entitled to the following rights:
Right of Access:
You maintain the right to have knowledge and to verify the legality of the process. So, you have the right to have access to the data and to receive complementary information regarding their process.
Right of amendment:
You maintain the right to study, modify, update or amend your personal data contacting with the Data Protection Officer (DPO) for the aforementioned contact data.
Right to erase:
You maintain the right to claim a request for an erase of your personal data while we process them with your consent or in order to protect our business and legal interests. In all other cases (i.e. when this is part of a contract, when this is an obligation for a process of personal data imposed by the law or the public interest), this right is subjected to specific restrictions or is being revoked depending the case.
Right to limited processing:
You maintain the right to request limitation for the processing of your personal data in the following cases: (a) when you question the accuracy of your personal data until this is verified, (b) when you are opposed to the erase of your personal data and you claim a request of limitation of their use instead of their erase, (c) when your persona data are not needed for the purposes of process but they are however essential, for the foundation, exercise, support of any legal claims, and (d) when you are opposed to the process and until it is verified that there is a legal base that concerns us and prevail of the reasons that you oppose to the process.
Right to oppose processing:
You maintain the right to oppose at any time to the process of your personal data in the cases, as mentioned above, where this is necessary to be accomplished for purposes that serve legal rights which we seek as responsible for the data processing, as well as to the cases processing takes place for reasons of direct marketing promotion and creation of a consumer profile.
Right to portability:
You maintain the right to receive with no charge your personal data in a form and format that will allow you to have access, use and further process of them from your side with the commonly known process methods. Also, you have the right to ask from us, when this is technically possible, to forward these data directly to another processor. Thos right applies for the data that you have provided and their process is accomplished with automated means.
Right of withdraw of consent:
When the processing is based upon your consent, you maintain the right to withdraw it freely, without being affected the process that took placed based on your conset before you withdraw it.
In order to exercise any of the above mentioned rights you may address to the Data Protection Officer (DPO) Mr. Barmpounis Ioannis, Postal Address: Themistoklis Dervis 41, Nicosia P.C. 1066, email: email@example.com, telephone: +357 22 466 462.
In the aforementioned cases we will make every possible effort in order to answer to your requests in a matter of thirty (30) days, from its submission. This time frame may be extended for sixty (60) more days, if this is considered necessary, taking in count the complexity and the number of the requests, which in this case we will inform you relatively in the time mentioned of the thirty (30) days.
Right to file a complaint to the Office of the Commissioner for Personal Data Protection:
You maintain the right to file a complaint to the Office of the Commissioner for Personal Data Protection (http://www.dataprotection.gov.cy/) Tel Center: +357 22 818456, Fax: +357 22 304565, email: firstname.lastname@example.org
Security of Personal Data
Starbucks – Marinopoulos Coffee Company Cyprus Ltd applies proper technical and organizational measures targeting toy the secure process of personal data and the prevention of a random loss or destruction as well as to prevent any not authorized and/or illegal access, use, alteration or revelation of the personal data. In any case, the way of function of the world wide web and the fact that is subjected to free use by anyone does not leave any probability to provide any guarantees that non authorized third persons will never gain the opportunity to breach the applied technical and organizational measures, gaining access and proceeding possibly to use of personal data for not authorized and/or illegal purposes.
Links to other URL
The aforementioned update is being applied under the EU Directive 2016/679 of the European Parliament and the EU Board as well as the Cyprus legal frame regarding the protection of personal data that are adopted and applied under this context.