1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we inform you about the handling of your personal data when using our website. Personal data means all data by which you can be personally identified.
1.2 The controller for the processing of data on this website within the meaning of the General Data Protection Regulation (GDPR) is Michail Frantzeskakis, Paragogoi by FlyDropGlobal, Am Hackenbruch 68e, 40231 Düsseldorf, Germany, tel.: 015236362561, e-mail: info@paragogoi.com. The controller for the processing of personal data is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.
2.1 When you use our website purely for informational purposes, i.e. if you do not register or otherwise transmit information to us, we only collect such data as your browser transmits to the server of the website (so-called "server log files"). When you visit our website, we collect the following data, which are technically necessary for us to display the website to you:
Processing takes place in accordance with Article 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data are not transferred or otherwise used. However, we reserve the right to subsequently check the server log files if there are concrete indications of unlawful use.
2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or requests to the controller), this website uses SSL or TLS encryption. You can recognise an encrypted connection by the string "https://" and the lock symbol in your browser bar.
For the hosting of our website and the display of the page content, we use a provider that renders its services, either itself or through selected sub-contractors, exclusively on servers within the European Union.
All data collected on our website are processed on these servers, unless different data recipients are named below for specific processing operations.
We have concluded a data processing agreement with the provider which ensures the protection of our site visitors' data and prohibits unauthorised disclosure to third parties.
In order to make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your device. Some of these cookies are automatically deleted after the browser is closed (so-called "session cookies"), while others remain on your device for longer and enable the storage of page settings (so-called "persistent cookies"). In the latter case, you can find the storage duration in the overview of the cookie settings of your web browser.
Insofar as personal data are also processed through individual cookies used by us, the processing takes place in accordance with Article 6(1)(b) GDPR either for the performance of the contract, in accordance with Article 6(1)(a) GDPR in the case of consent given, or in accordance with Article 6(1)(f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.
You can set your browser so that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.
Please note that the functionality of our website may be limited if cookies are not accepted.
5.1 In the context of contacting us (e.g. via contact form or e-mail), personal data are processed – exclusively for the purpose of handling and answering your request and only to the extent necessary for this.
The legal basis for the processing of these data is our legitimate interest in answering your request in accordance with Article 6(1)(f) GDPR. If your contact is aimed at concluding a contract, an additional legal basis for the processing is Article 6(1)(b) GDPR. Your data will be deleted if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and provided that no statutory retention obligations conflict with this.
5.2 - Resend
For sending transactional e-mails, i.e. event-driven messages triggered by a specific user interaction (such as conclusion of a contract, registration or password reset), we use the following provider: Plus Five Five, Inc., 2261 Market Street, #5039, San Francisco, CA 94114, USA
On the basis of our legitimate interest in effective and user-friendly e-mail communication, we transfer the data you provide when carrying out such a user action to this provider pursuant to Article 6(1)(f) GDPR, so that it handles the dispatch of e-mails on our behalf.
We have concluded a data processing agreement with the provider which protects our site visitors' data and prohibits disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, on the basis of an adequacy decision of the European Commission, ensures compliance with the European level of data protection.
6.1 In accordance with Article 6(1)(b) GDPR, personal data continue to be collected and processed to the extent required in each case if you provide them to us when opening a customer account. Which data are required for opening the account can be seen from the input mask of the corresponding form on our website.
6.2 Publication of the producer's provider identification
A customer account on this platform is opened exclusively by producers (entrepreneurs) who operate their own storefront page via the platform. The provider data supplied by the producer upon registration – name or company name, legal form where applicable, address, e-mail address and telephone number as well as, where provided, VAT identification number or tax number and register details – are published in publicly accessible form on the storefront page of the respective producer, namely in the provider identification (imprint) and in the producer's privacy policy.
The purpose of the publication is to fulfil the statutory information obligations incumbent on the producer as a service provider (Section 5 DDG or corresponding provisions at the producer's place of establishment) and to enable interested parties to make direct contact. The legal basis is Article 6(1)(b) GDPR, since the provision of a storefront page with legally compliant provider identification is the subject matter of the contract concluded with the producer.
The published data are accessible worldwide and may be recorded by search engines. They are removed as soon as the storefront page is deactivated or the customer account is deleted. We have no influence on cached copies held by search engines or internet archives.
6.3 Deletion of your customer account is possible at any time and can be effected by sending a message to the aforementioned address of the controller. After deletion of your customer account, your data will be deleted, provided that all contracts concluded through it have been fully processed, no statutory retention periods conflict with this and no legitimate interest in continued storage exists on our part.
7.1 To process the contract, we work together with the following service provider(s) who support us wholly or partly in the performance of concluded contracts. Certain personal data are transmitted to these service providers in accordance with the following information.
7.2 Use of payment service providers
- Stripe
On this website, one or more online payment methods of the following provider are available: Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland
If you select a payment method of the provider, the payment data you provide in the course of the order process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order are passed on to them pursuant to Article 6(1)(b) GDPR. In this case, your data are passed on exclusively for the purpose of processing the payment with the provider and only to the extent necessary for this.
7.3 Order and contact requests to producers (processing on behalf)
Via our platform, you can send requests (e.g. order or product requests) directly to a producer listed on the platform. Which data are required for this can be seen from the input mask of the corresponding form. These data are transmitted to the respective producer and processed exclusively for the purpose of handling and processing your request.
The controller under data protection law for the processing of these request data is the respective producer. We process these data on their behalf as a processor within the meaning of Article 28 GDPR on the basis of a data processing agreement concluded with the producer. The legal basis for the processing by the producer is Article 6(1)(b) GDPR (performance of pre-contractual measures or performance of the contract).
To exercise your data subject rights (see section 9) with regard to these data, please primarily contact the respective producer. You can also contact us at any time; we will forward your request to the producer.
The request data are deleted as soon as they are no longer required for handling and processing the request and no statutory retention obligations conflict with this. In all other respects, section 10 of this privacy policy applies.
7.4 - AWS Bedrock
To provide our services we use AI-supported processing. For this purpose we use the Amazon Bedrock service of the provider Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg.
Via Amazon Bedrock we access a language model of the provider Anthropic (Claude model family). The technical processing takes place entirely within the European AWS region selected by us (Frankfurt am Main, eu-central-1).
The subject matter of the processing is exclusively the content that a producer enters into their own storefront page within the framework of the contractual relationship existing with them (in particular product and FAQ texts). This content may be fed into the provider's software in order to organise, analyse, aggregate, modify, evaluate or prepare it for the provision of our service — namely making the storefront page available in Greek, English and German.
The collection and further processing of this information takes place strictly for the specified purpose of performing the contract pursuant to Article 6(1)(b) GDPR. The provider does not store the transmitted content beyond the translation process, and it is not used for training models.
7.5 - Referral Partner Programme
If you apply to our Referral Partner Programme, we process the data contained in your participation request together with the data required to run the programme. These are: name or company name, address, date of birth, e-mail address, a tax number where one exists, the referral code assigned to you together with the referrals attributed to it, and the bank account to which the commission is paid.
We collect the date of birth in order to identify unambiguously the person to whom a commission is paid. Without it we cannot make a payout.
The legal basis is Art. 6(1)(b) GDPR, as the processing is necessary to enter into and perform the participation relationship. Where we retain the data beyond that in order to meet commercial and tax record-keeping obligations, the legal basis is Art. 6(1)(c) GDPR.
If you use the referral partner area (paragogoi.com/partner-portal), we additionally process: your e-mail address, to send you a one-time sign-in code; the time and hash values of the e-mail address and the IP address of each code request, to protect against misuse, which we delete after 24 hours; and, while you are signed in, a technically necessary session key in your browser, which is removed when you sign out. We inform you by e-mail about every new commission. The legal basis is Art. 6(1)(b) GDPR and, for protection against misuse, Art. 6(1)(f) GDPR (legitimate interest in secure access). Section 5 additionally applies to sending e-mails.
Data is passed to third parties only where this is necessary for payout through our bank or for compliance with statutory obligations towards the tax authorities. Your participation request reaches us by e-mail; section 5 additionally applies to that transmission channel. Section 10 applies to the storage period and section 9 to your rights.
- Cloudflare Turnstile
On this website we use the CAPTCHA service of the following provider: Cloudflare, Inc., 101 Townsend St. San Francisco, CA 94107, USA
The service checks whether an input is made by a natural person or abusively by machine-based and automated processing, and blocks spam, DDoS attacks and similar automated malicious access. In order to ensure that an action is carried out by a human and not by an automated bot, Cloudflare Turnstile collects the IP address of the device used, detection data on the browser and operating system type used as well as the date and duration of the visit, and transmits these to the provider's servers for evaluation.
The legal basis is our legitimate interest in establishing individual personal responsibility on the internet and in preventing misuse and spam pursuant to Article 6(1)(f) GDPR.
We have concluded a data processing agreement with the provider which ensures the protection of our site visitors' data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, on the basis of an adequacy decision of the European Commission, ensures compliance with the European level of data protection.
9.1 The applicable data protection law grants you, vis-à-vis the controller, with regard to the processing of your personal data, the following data subject rights (rights to information and intervention), whereby reference is made to the legal basis cited for the respective exercise requirements:
9.2 RIGHT TO OBJECT
IF, IN THE CONTEXT OF A BALANCING OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE THE PROCESSING OF THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS.
IF YOUR PERSONAL DATA ARE PROCESSED BY US FOR THE PURPOSES OF DIRECT MARKETING, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSES OF SUCH MARKETING. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE THE PROCESSING OF THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
The duration of the storage of personal data is determined on the basis of the respective legal basis, the purpose of the processing and – where applicable – additionally on the basis of the respective statutory retention period (e.g. commercial and tax retention periods).
In the case of processing of personal data on the basis of an express consent pursuant to Article 6(1)(a) GDPR, the data concerned are stored until you withdraw your consent.
If statutory retention periods exist for data that are processed within the framework of legal or quasi-legal obligations on the basis of Article 6(1)(b) GDPR, these data are routinely deleted after expiry of the retention periods, provided that they are no longer required for the performance or initiation of the contract and/or no legitimate interest in continued storage exists on our part.
In the case of processing of personal data on the basis of Article 6(1)(f) GDPR, these data are stored until you exercise your right to object under Article 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
In the case of processing of personal data for the purpose of direct marketing on the basis of Article 6(1)(f) GDPR, these data are stored until you exercise your right to object under Article 21(2) GDPR.
Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data are otherwise deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.