PRIVACY POLICY

This site is operated by "HOLMES PLACE EAST MED B.V." (formerly HEALTH & FITNESS EAST MED B.V.), established in accordance with the laws of the Netherlands, based in the city of Amsterdam, Netherlands (Leidsegracht 38-40, 10 16 CM), which has a legal branch in Greece, in accordance with the provisions of Art. 58 law 3190/1955, with its registered offices in Athens at Sekeri Street no. 5, with Tax Registration number 999868803 registered in the 4th Athens Tax Office, legally represented, (hereinafter “HOLMES PLACE”).

Your agreement to the following terms of this Privacy Policy is considered as a freely given expression of your consent to the collection, use and further disclosure of your personal data for purposes related to the use of our website as well as your personal data disclosed to the Holmes Place in general as specified below. In this respect, we encourage you to read this Privacy Policy carefully, as follows:

SCOPE OF THE PRIVACY POLICY

At HOLMES PLACE, we are dedicated to protecting the privacy of your personal information. The present Privacy Policy establishes the measures taken by HOLMES PLACE concerning any Personal Data we collect directly from you and/or through the site homeplace.gr, in accordance with the European Regulation 2016/679 (EU), supplemented by the relevant national and European legislation on the Protection of Personal Data. For the purposes of this Privacy Policy the following definitions should apply: The term “personal data” refers to any kind of information that identifies you. Such information might include your name, surname, communication details, address, e-mail, tax number. In this context, it is important to inform you about how, and by which means, we use the personal information we collect. The term “sensitive data” refers to any personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as personal information on genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

DATA COLLECTED

Visits to the HOLMES PLACE website do not entail automatic registration of any personal data that identifies you. There is, nevertheless, some information that is not personal or identifiable that may be collected and recorded in the website of HOLMES PLACE (for example, the User’s type of Internet browser, the User’s operating system to access the webpages of the HOLMES PLACE website), with the aim of improving our services such as your navigation experience and management of the HOLMES PLACE website. Furthermore, we automatically collect information about you such us your IP address and your domain name. This information may be used to offer you a more personalised experience during your visit to our site. Nevertheless, in order to use certain Contents and Services of our website you may be required to provide personal data such as: name, surname, address, e-mail address, telephone number. When you chose to become a member of HOLMES PLACE, we also may collect your tax verification number, credit card number, birth date, health status information, as well as nutrition preferences or allergies, IBAN (in case of a refund). If you are a member privileged with some specific benefits, then further to the above mentioned personal data we will ask relevant evidence (i.e team member card etc). In any case, HOLMES PLACE will provide you with the necessary information for you to be able to provide your prior consent in order to process your personal data for one or more specific purposes. You may also be requested to provide us with information on your location or aspects of your personal preferences and interests, in order to offer you more customised services. The information provided will be stored in the databases of HOLMES PLACE, manually or by electronic means. We also collect information that you provide us via your responses to our surveys, your responses to our questionnaires, your comments etc. Moreover, we may provide you with some tools for the self-assessment of your physical condition, as well as you may provide us with sensitive data regarding your health status or health problems and nutrition preferences and/or allergies, in different points of data collection such as the execution of the contract, the registration procedure, the registration of the spa facilities, or the nutrition assistance and personal training.

USE OF PERSONAL DATA

We collect your Personal Data, in order to provide you with a high level of our products and services. The Personal Data we collect serve to administer and provide products and services that you request or that you have expressed interest in, such as: • Registration to our services, as provided from time to time (e.g. Personal Training, Group Programs, Spa & Beauty etc.); • Registration to our Members Club; • Registration to our competitions; HOLMES PLACE, if it’s duly authorised by the holder of the data, may also use it for the following purposes: • Sending personalized information about new products and services; • Sending regular updates that HOLMES PLACE deems of interest for the User; • Sending requested information about products and services; • For purposes of market studies and marketing; • For internal use as part of the administration of the site HOLMES PLACE.gr/ com and improvement of the services provided. • For acts of “direct marketing”, meaning any HOLMES PLACE communication for the purpose of scheduling assessments, visits regarding available services at clubs (nutrition, physiotherapy and other), release of operational information arising from the commercial relation, notification of HOLMES PLACE events and parties, as well as subscription to training programs or personalised training. All personal data that is being collected and further processed by Holmes Place is pertinent, adequate and limited to the needs and purposes for which they are collected, and is treated in a manner that guarantees its accuracy, update and safety, including protection against unauthorised or unlawful processing, against accidental loss, destruction or damage, taking every technical and organisational measure deemed convenient for the purpose, namely in terms of encryption, ciphering, pseudonymisation and anonymisation of personal data, as well as control, monitoring and regular record of all processing . We will provide you with all the necessary information you need to express your prior consent to the processing of your personal data for one or more specific purposes by HOLMES PLACE and incorporation in the corresponding files owned by HOLMES PLACE. Whenever consent is given for automated processing of your personal data (profiling), HOLMES PLACE collects and processes information based on your personal preferences and specific interests, only in order to provide you with personalised information and/or notification about HOLMES PLACE services and activities through direct marketing campaigns. The data collected are processed automatically and aim, within the corporate group that HOLMES PLACE is part of, to establish the quality of User/Client, consequent collection of vouchers and future contacts, namely direct marketing actions. The data collected also aim at fulfilling legal obligations and use in contractual relations with Insurers, Banks and other Institutions, HOLMES PLACE committing to keep strict secrecy of all data, reserving access thereto as exclusively required for its normal activity. The contacts provided will be retained in our database and may be used to occasionally send information by e-mail or mail about products and services similar to those contracted deemed of interest thereto. If you do not wish to receive this type of information you must act in accordance with the chapter “DATA SUBJECTS’ RIGHTS’’.

COLLECTING PERSONAL PREFERENCES AND INTERESTS THROUGH THE SITE HOLMES PLACE

Besides collecting data by the means listed above, when expressly authorised, HOLMES PLACE uses technology that allows collecting information on users of the site HOLMES PLACE.gr. For example, the site server automatically collects information on which pages are visited, as well as which browser is used. Our site contains hyperlinks to other pages of our site. Technology may also be used to monitor the frequency with which these connections are used and what are the most viewed pages. When provided by the user of the HOLMES PLACE website this information may be used for purposes of direct marketing.

TRANSFER OF PERSONAL DATA

In cases in which you have provided us with your consent, your Personal Data may be shared with other companies of the same group as HOLMES PLACE Athens or said data may be disclosed to other companies that may contact you about their products or services that may be of your interest. If you are in a country different than that where the HOLMES PLACE servers are, communications may entail cross-border transfer of information. By visiting our site and communicating with HOLMES PLACE by electronic means, you authorise processing and transfer of your Personal Data as established in the present Privacy Policy.

RETENTION PERIOD

All personal data are retained for a predetermined and limited period depending on the purpose of processing, after the end of which, these personal data are being deleted from our databases. The personal data provided by you at the Holmes Place though the website is preserved during 1 year from provision or, there being a commercial relation between the user and Holmes Place, during a 2-year period after cessation of the commercial relation, after which the data will be deleted, finalising all and any data processing.

APPLICABLE LAW

In case of controversy or claim of any nature regarding this site Greek law will apply, regardless of any legal conflict applicable. All actions or legal procedures arising from or related with this Privacy Policy, its validity, application, fulfilment or breach, or the matter of this Privacy Policy, will be a competence of Greek courts, and you allow and submit irrevocably to the jurisdiction of said courts as is the case. Notwithstanding the above, HOLMES PLACE reserves the right to bring the competent judicial action before the courts of the place of violation of this Privacy Policy.

INFORMATION PROTECTION

To prevent unauthorized access, maintain data accuracy and ensure the appropriate use of information we gather about you, we have taken commercially reasonable steps to protect personal information. However, no method of transmission over the Internet or method of electronic storage is 100 percent secure. HOLMES PLACE has taken reasonable precautions to secure the personal information available through the online community.

DATA SUBJECTS RIGHTS

At HOLMES PLACE, we endeavor to protect and respect data subjects’ rights. In particular, data subjects shall always retain the right to be informed on the processing of their personal information (i.e. right of access) and to request and obtain further information on the processing applied. Furthermore, data subjects are entitled to request: (i) correction of their inaccurate personal data; (ii) deletion of personal information provided; (iii) limitation of processing; (iv) portability of their personal information; and (v) objection/opposition to further processing thereof. In these cases, HOLMES PLACE will respond in writing within 30 days of receipt and identification of the request. In addition, in the event of exercising one or more of the above-mentioned rights of correction, deletion and restriction of your data, these requests shall also be forwarded to any third-party recipient to whom the personal information may have been disclosed in the scope of pursuance of the afore-mentioned processing purposes.

CONTACT PERSON FOR DATA PROTECTION

In order to ensure that your personal information is being efficiently protected, you may address your requests and questions in relation to this Privacy Policy as follows: Name: Manolis Agapitos Telephone: 210 7475600 E-mail: Dataprotection_GR@holmesplace.com Postal address: Sekeri 5 Str., 106 71, ATHENS Website: www.holmesplace.gr In case you consider your personal data affected in any way, you may contact the Greek national Data Protection Authority, as follows: Website: www.dpa.gr Postal Address: 1-3 Kifissias Avenue, PC 115 23, Athens Call Center: +30 210 6475600 Fax: +30 210 6475628 E-mail: contact@dpa.gr This Privacy Policy may be amended from time to time. Any such changes will be posted on this page. The effective date of this policy is May 17, 2018.