Nikos Saklabanakis understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1.Definitions and InterpretationIn this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below; “Our Site” means these websites and all its subdomains. “UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and “We/Us/Our” Means Nikos Saklabanakis, a self employed individual.
2. Information About us
2.1 Our Site, is owned and operated by Nikos Saklabanakis.
2.2 Our Data Protection Officer is Nikos Saklabanakis who can be contacted on firstname.lastname@example.org
2.3 Our registration number with the Information Commissioners Office is: Z2556909.
3. What Does This Policy Cover?
4. What Data Do We Collect?
4.1 Full Name;
4.2 Email Address
4.3 Telephone Number
4.4 Company name
4.5 Company Information
4.7 Credit / Debit card details
4.8 IP address
4.9 Web browser type and version
4.10 Operating System
4.11 A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible products and services to you. This includes:
5.2.1 Providing and managing your Account
5.2.2 Providing and managing your access to Our Site
5.2.3 Personalising and tailoring your experience on Our Site
5.2.4 Supplying Our products and services to you
5.2.5 Personalising and tailoring Our products and services for you
5.2.6 Responding to communications from you
5.2.7 Supplying you with email newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the ‘update your preferences’ link in the email or by contacting us at email@example.com
5.2.8 Market research
5.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.4 Once you have submitted your data to us, we use your data for marketing purposes which may include contacting you by email, telephone, text message with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
5.6 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6.How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, your data will be deleted if you notify us via email, telephone or post.
6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage with.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
• All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
• Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
• The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
• All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation.
6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet
7.Do We Share Your Data?
7.1 We may only share your data with wholly owned subsidiaries of Nikos Saklabanakis<
7.2 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
Third-party Name Type of data subject
Google First name, last name, email address
Adroll Email address
Facebook First name, last name, email address
Xero First name, last name, email address, company information, purchase invoices
Infusionsoft First Name, Last Name, Email Address, Telephone number, Address, Website, Company Information, Device IP Address, Credit/Debit Card Details
Dropbox First name, last name, email address
Royal Mail and Couriers First name, last name, email address
First name, last name, Company Name, Address
7.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will] be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or by emailing us to let us know your preferences).
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us using the contact details below in section 15.
12. What Cookies Do We Use and What For?
12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for advertising services. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.
12.3 All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
12.5 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.6 We do not place first party Cookies on your computer or device, however the following third party Cookies may be placed on your computer or device:
Name of Cookie Provider Purpose
Facebook Third Advertising
Adroll Third Advertising
12.7 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
12.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information. These Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
12.9 The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie First / Third Party Purpose
Google Third Analytics
12.10 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.11 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPRUnder the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14. Contacting Us
Body Vision will proudly be GDPR compliant starting May 25, 2018
Please read this statement of intent.
General Data Protection Regulation
GDPR: The EU Data Protection Law
Learn about obligations under the GDPR, and how Nikos Saklabanakis is prepared to help you achieve GDPR compliance.
We have always made security and privacy among our highest priorities.
That’s why we’ve committed not only to provide tools to facilitate your compliance with the GDPR, but to educate you on your responsibilities as a business owner. As the GDPR’s scope is broad, and the potential penalties for noncompliance are large, we’ve ensured that our tools are available to all of our customers, at no additional cost.
This page will outline some of the key GDPR principles and terms and present how they apply to your use of Nikos Saklabanakis websites. Please review this carefully and share it with your privacy team with the legal documents listed below.
Disclaimer: This guide is not and should not be considered legal advice. Please consult a legal professional for details on how the GDPR may impact your business, and what you need for compliance.
General Data Protection Regulation (“GDPR”)
The GDPR is a unified regulation that supersedes and universalises previous privacy laws in Europe, offering citizens and residents of the European Union (EU) greater transparency and controls over how their personal data is used by others. The GDPR requires the compliance of businesses which transact in Europe, or which facilitate transaction in Europe.
Controllers and Processors
There are two key roles defined in the GDPR with respect to personal data: Controller and Processor. The Controller is the business — you. As a customer of Nikos Saklabanakis, you operate as the Controller when using our products and services. You have the responsibility for ensuring that the personal data you are collecting is being processed in a lawful manner pursuant to the GDPR and that you are using processors, such as Nikos Saklabanakis, that are committed to handling the data in a compliant manner.
Processing of Personal Data
In order to process personal data, you need a lawful basis for processing. There are several methods to establish a lawful basis for GDPR compliance, but the most likely mechanisms you will rely on when communicating with your customers and leads is one of the following:
- Consent – Much of the GDPR revolves around the concept that your leads and customers have consented to you collecting their personal data, to you using (e.g. processing) their data, or to receiving communications. According to the ICO, the following criteria must be met to show valid consent:11.
- Consent must be freely given. This means giving people genuine, ongoing choice and control over how you use their data.
- Consent should be obvious and require positive action to opt in. Consent requests must be prominent, unbundled from other terms and conditions, concise, user-friendly, and easy to understand.
- Consent must specifically cover the data Controller’s name, the purposes of the processing, and the types of processing activity.
- Explicit consent must be expressly confirmed in words, rather than by any other positive action.
- There is no set time limit for consent. How long it lasts will depend on the context. You should review and refresh consent as appropriate.
In short, under the GDPR (and it’s a good idea in general), consent must be obtained by a “clear affirmative act”. In contrast to ‘clear affirmative acts’ pre-checked boxes or implicit consent are inadequate to establish consent.
If you are relying on consent as the lawful basis for processing data, the GDPR requires recorded evidence that consent has been given. You thus need in your business the ability to record proper consent for each customer and lead. When you enable the GDPR functionality in BusinessMobiles.com, you have the ability to obtain your lead’s consent at the point of opt-in, and that consent will be registered as a tag associated with that lead.
- Contract – In addition to consent, another lawful basis for processing data is if the processing of personal data is necessary for the performance of a contract. Password reset, billing notifications, and onboarding communication would likely fall under this lawful basis. In other words, if its a customer who transacts with you, there are certain processing tasks that must be undertaken for your to provide the service. Likewise, to keeps its commitments under its EULA and provide service to you, BusinessMobiles.com has to perform certain processing.
Data Subject Rights
Under the GDPR, EU data subjects are certain rights regarding their data.
The Right to Data Portability and the Right to Access:
Nikos Saklabanakis offers tools to let you answer customer queries about what data you have collected through Nikos Saklabanakis websites and what’s been done with it.
The Right to be Forgotten and The Right to Restriction of Processing
Have a lead or customer who wants their personal data out of your database? No problem! You can remove that contact from any list or sequence — or even delete them entirely. However, transactional records will remain intact for bookkeeping purposes (though personal data will be redacted (e.g. ‘blacked out’ from view).
Unless otherwise required by law, in the event that Nikos Saklabanakis receives any type of request from a data subject, we will engage the respective customer within seven days to respond to the data subject request.
Data Processing Addendum
Our data processing addendum (DPA) to our End-User Licensing Agreement formalises many of the details described on this site in specific legal language. As part of the EULA, the DPA will govern the terms by which Nikos Saklabanakis, as a data processor, processes data on behalf of its customers (who are typically data controllers) in accordance with Article 28 of the GDPR.
- sub-processors engaged in delivering our services
- countries through which the data is passed (cross-border protocol)
- security measures undertaken to ensure that your data is kept private
- breach notification protocol
Frequently Asked Questions
Does the GDPR impact businesses outside of the EU?
In many cases, Yes. Even businesses that are not based in the EU are considered to be subject to the GDPR if they are collecting personal data on EU residents. Enforcement of the GDPR outside of the EU will be by EU authorities and it remains to be seen how aggressive they will be. Consult your own legal counsel but it is widely accepted that companies that collect personal data from EU residents will be subject to the requirements of the GDPR.
Does the GDPR require data to be stored in the EU?
The GDPR does not require that data processing (including storage of data) be limited to the EU.The EU-US Privacy Shield is one of several valid lawful mechanisms to transfer data between the EU and the US. In addition to Privacy Shield, BusinessMobiles.com’s Data Processing Addendum includes the EU Model Clauses, which is also a valid mechanism for the lawful transfer of data between the EU and US.
How does the GDPR impact personal data collected before May 25th? Will I need to get consent for all of my leads again?
The GDPR applies to all personal data, even if it was collected before May 25, 2018. As your business is preparing for the implementation of the GDPR, you should make sure you can properly audit the consent records for the EU-residing members of your email list, or that you can obtain and record evidence of consent going forward.
Do you have a Data Processing Policy?
Yes! Our Data Processing Addendum to our EULA contains the details of our data processing and how we work with Controllers and Subprocessors to comply with the applicable regulations and to ensure the privacy of your data. You can obtain a copy of our DPA by making a written request by email to our Data Protection Officer.
Who is Nikos Saklabanakis Data Protection Officer (DPO)?
Nikos Saklabanakis DPO is: Nikos Saklabanakis
Email address: firstname.lastname@example.org
In accordance with Article 38 of the GDPR, members of the public may contact the DPO with regard to issues related to processing of their personal data and to exercise their rights under the GDPR – for example, to object to the processing of their data in cases where the data controller (i.e., Nikos Saklabanakis’s customer) does not provide an adequate response.
Feel free to reach out to us by emailing us at email@example.com with any questions you may have.