Management Policy of the Website
for Sales of Goods, Services and/or Products by Creators of Cosmos S.M.P.C.

Introduction

We would like to thank you for your interest in using the services website of “Creators of Cosmos” Single Private Capital Company (hereinafter referred to as the COMPANY). The main object of the COMPANY is the operation and the fulfillment of its goals and purposes as described in detail below:

1. The design, production, installation and execution of Live Action Role Playing Games and related events, as well as their evaluation through the creation and management of complete original scenarios – products.
2. We use our scenarios in four (4) business axes: Tourism, Creative Industries, Gaming and Knowledge Economy, and in five (5) distinct categories: Tourism and Destination Management, Lifelong Learning, Professional Skills Development, Tackle of Social Exclusion, Research and Development of new products in the aforementioned fields (provision of learning development / formal – non-formal education services, support and development of the individual’s mental health, development of professional skills of individuals and / or groups, entertainment – leisure – cultural tourism at national and international level, implementation of scenarios in physical, electronic – digital, phygital and holographic environments).
3. The exclusive management and exploitation of the intellectual and commercial property rights resulting from the production of scripts, as symbolic products of the creative industry sector, in accordance with national and international legislation.
4. The creation, installation and operation of an integrated network – collectivity of craftsmen, specialized in the production of original consumables such as costumes, jewelry, usable products – props, sets, etc., which are related to the content of the scripts – products and / or consumables, which have received certification of an exact copy in accordance with the specifications set by the beneficiary of intellectual rights.
5. The creation, installation and operation of an integrated network – collectivity of professionals in the field of spectacles production such as screenwriters, directors, actors, art historians, art critics, technical support professionals (e.g. lighting, electronics, illustrators, photographers, etc.), as well as professionals in the creative industry (e.g. architects, fashion designers, musicians, composers, filmmakers, painters, writers, performing arts artists), and all kinds of creators, whose work is protected by intellectual property.
6. The development of a local, national and transnational network of professionals in the field of Live Action Role Playing gaming and related events market through the signing of cooperation agreements (public and private bodies engaged in: cultural management, spectacle production, tourism services, entertainment services, provision of developmental learning / formal – non-formal education services, mental health support services, legacy management, educational institutions, cooperative ecosystems (clusters), etc.).
7. Establish, develop and management of an international network of players in physical, electronic, digital, phygital and holographic environments.
8. The creation and exploitation of know-how methodologies concerning cultural management as it produced in the context of the business activities of the COMPANY.
9. The elaboration of studies and researches concerning sectors of activity of the COMPANY.
10. The design, participation, and implementation in all kinds of co-financed programs of national, supranational, private, and/or public bodies.
11. The operation of a non-profit organization that will aim to unite national and supranational bodies (public and private) on the subject of Live Action Role Playing games and related events, with an aim of creating the first global network of professionals in this field and the operation of the first Museum of LARP Games and their history.
12. Publications of all kinds by electronic means e.g. books, comics, movies, documentaries, as well as their respective digital media, e.g. transfer of symbolic products to the digital environment such as e-books, short videos, etc.
13. Production and sale of consumables related to the products – scenarios of the COMPANY, through physical and digital stores and any other legal and appropriate means at its disposal, e.g. bazaar, charity events, etc.
14. The purpose of the company is speculative through the development of its business activity, while the networks that operate under its supervision can be both speculative and non-profit, as defined by their respective statutes.

For the use of the COMPANY’s website, it is necessary for you to disclose personal data, which serve to fulfill the above purposes, the sale of goods-services and/or products of the COMPANY, as well as for security reasons in accordance with the General Regulation on Personal Protection. The information required to be disclosed is as follows:

1. Name
2. Last Name
3. Country
4. Housing Address (Postal Code or P.O. box only for sending goods)
5. Direct Contact Details (phone number)
6. E-mail address

The information you provide to the COMPANY is in no way disclosed to third parties and is not used for purposes other than communication related to sales of the COMPANY’s good-services and/or products to its customers, unless this has been agreed from the beginning or has been imposed by a Public Authority.

Consumer rights and interests are under the protection of the Greek State, in accordance with Law 2251/1994 on Consumer Protection as amended and in force. You can see the whole Law here.

Protection of Personal Data Policy

This policy for the securement and protection of personal data aims to inform you on the terms of collection, processing and conveyance of your personal data by the COMPANY and any third party, directly involved with the services of transport, distribution and provision of financial exchanges for its goods, services and/or products.

A) Data Collection

The COMPANY and its staff apply the ten Principles of Editing the Community Directive 2016/679 as they are included in the General Data Protection Regulation that came into full force on 25 May 2018 (legality, objectivity, transparency, limitation of purpose,  minimization of data, precision, limitation of storage period, integrity, confidentiality and accountability) in order to protect your eight rights regarding the use of your Personal Data (information, access, correction, deletion, processing limitation, portability, objection and non-automated decision making based on the users profiles, as directed by Greek legislation). The above applies without any discrimination to all processing carried out by the COMPANY and to all services provided by it.

Personal Data are conjointly and on a case-by-case basis the follow:

• Identification data: such as name, patronymic, ID / Passport Number, date and place of birth and nationality.
• Contact details: email address, contact telephone number, mailing address for invoice or proof of service paper deliverance, order delivery details.
• Health data.
• Data relating to electronic or telephone conversations, which are recorded in accordance with the requirements introduced by national and international legislations.
• Website usage and access data: Customer name / password.

Other data collected depends on the type of case-by-case relationship and the goods, services and/or products provided and is described as follows:

1. Comments

When users post comments to the WEBSITE, we collect the data displayed in the comments form, the IP address of the visitors and the usage string of their browser to help detect unwanted messages.

To this end, the COMPANY operates a Comment Moderation Policy before publication, which ultimately allows its competent officials to control and modify comments that are abusive, defamatory or/and introduce hate speech, before they are posted or even delete them whilst informing the users who attempted to post them. An anonymous string created by the email address (also called a “hash”) may be provided to the Gravatar service for possible verification. Gravatar’s privacy policy is available here: https://automattic.com/privacy/.

2. Cookies

The use of the WEBSITE and any additional function of it, includes the possibility of using cookies related to the storage of the following data:

• customer ID,
• email and IP address

These cookies remain active for one year from the date of submission of the data for the first time to the WEBSITE. Through the operation of an account at the WEBSITE, draft cookies are created for the customers that ensure the optimal operation when navigating through the content, do not contain personal data and are deleted in the browser of the customer’s computer, after completing their visit. The creation of an account also serves the function of cookies concerning possible storage of information and options for modifying the display of the screen. Input cookies last for two days and display options cookies last for one year. Once users select the “Remember me” sign, the connection remains active for two weeks. Disconnecting users from their account automatically removes any connection related cookies.

Publication and editing of comments, articles, or other types of publications within the WEBSITE, operates an additional cookie, lasting 24 hours, which is stored in the browser, does not include personal data, and concerns the post ID of user’s publications. In addition, session cookies are used, which are stored in the user’s computer memory, do not receive any document or file from the user’s computer and are used only to facilitate user’s access to specific services and for statistical purposes, in order to determine the areas in which COMPANY services are useful or popular and / or for promotional purposes. Users have the option to make adjustments so that they do not receive session cookies.

Built-in content from other websites (e.g. videos, images, articles, etc.) maintains active -in addition to the WEBSITE’s management options- all options included in third party providers of this content (third party websites in relation to this WEBSITE, which collect data, use additional cookies, incorporate additional monitoring of third party customers interactions with relevant content).

B) Ways of Collection

• By completing an application form in one of the titles of the COMPANY’s games as notified through the WEBPAGE, in order to verify the age and whether the valid contribution of both parties is allowed by law or if the consent and/or signature of the customer’s parents/custodians is required.
• By completing a purchase form for goods and products such as notified through the WEBPAGE, in order to check the age and whether the valid contribution of the two parties is allowed by law or if the consent and/or signature of the customer’s parents/custodians is required.
• With the voluntary registration of users in the communication list of the COMPANY for the receipt of informative forms, catalogs of goods – services and/or products, updates through messages on mobile telephony devices or other marketing material.
• With the voluntary renewal of users’ preferences or even during their participation in competitions, questionnaires and researches conducted by the COMPANY.
• During physical, digital, electronic and/or analog communication of customers with departments of the COMPANY responsible for serving their needs, through the recording of the content of these communications (registration form, telephone calls, mobile phone messages exchange, correspondence and any other appropriate means to serve the purposes of such communications).
• Through market research between customers for goods – services and/or products provided by the COMPANY.
• When third parties to the COMPANY submit documents, files, orders, reports, seizures, warrants, etc. such as supervisory, prosecutorial, judicial, tax authorities, banking organizations, card issuing organizations, credit card payment and credit control institutions, information companies on the creditworthiness of protecting customers against fraud or money-laundering or the fight against economic crime and cybercrime.
• Through session cookies for the recognition of the identity of the users and visitor of the WEBSITE.

C) Purpose of Collection

The COMPANY will use your information for the following legal processing purposes, namely:

• The identification of customers and the establishment of communication in any case of transaction, pre-contractual or contractual relationship between customers and the COMPANY.
• The promotion of new products and services of the COMPANY to existing and potential customers, if any where there is a case, their explicit consent.
• To complete requests, purchases and orders.
• To respond to requests, questions, provide information and/or confirm reservations, purchases of goods-products and/or services.
• To inform its customers in order to improve the quality of its goods – products and/or services but also to train its staff in relation to new customer’s requirements.
• For the distribution of results of surveys, draws, competitions that concern users who took part in them.
• For the analysis of the sizes of population movement by the WEBSITE (digital traces) and the improvement of the customer experience during the access of its content.
• For the analysis of statistical data in order to prevent fraud.
• For use, through the information systems of administration, pricing, accounting, charge, and control of these results, by the competent directorates of the COMPANY.

D) Recipients – Principles of Processing – Conveyance of Data to third parties

The use of the WEBSITE presupposes the provision of personal information to the COMPANY. The COMPANY does not convey – share personal information that comes into its possession neither between companies – partners, nor with third parties, except to the extent necessary to complete the purchase / order and to fulfill requests regarding the services provided by it (e.g. spectacle producers, travel agencies, airlines or shipping companies), or to suggest to customers ways to improve the user experience, in the context of the services provided. Exceptions regards data related to research content in collaboration with third parties and if an agreement of the customers, on how to manage them, has been obtained.

In the third parties with whom personal data may become available, the COMPANY sets contractual restrictions to ensure that they are used in accordance with this MANAGEMENT POLICY STATEMENT, European (General Data Protection Regulation 2016/679) and internationally data protection laws. However, it cannot guarantee that third parties will not use or disclose the data in breach of the terms of use imposed on their management. Therefore, the COMPANY bears no responsibility and it is the sole responsibility of the users to check the privacy practices of any third parties.

The processing of data maintained by the COMPANY may take place inside and outside the Member States of the European Economic Area on the basis of EU competence decisions, corporate binding rules, standard contracts, and approved codes of conduct. In any case, appropriate technical and organizational measures shall always be taken to ensure that personal information are transferred, stored, and processed in accordance with the terms of this MANAGEMENT POLICY STATEMENT and the applicable data protection laws.

Sharing personal data of the WEBSITE’s users to official, domestic or foreign, state and supervisory bodies (e.g. police, Bank of Greece, international tax authorities, etc.), is done after a written order of the competent body for compliance with the current legislation and the prevention of illegal actions against the COMPANY and/or its customers (e.g. fraud, money laundering, etc.).

E) Data Retention Time

According to the General Data Protection Regulation, your personal data is kept by the COMPANY only for as long as is required by the contractual terms of each service, in combination with the current financial, banking, tax, telecommunications and other legislation, based on the respective processing purpose, and are later destroyed.

The deletion of files is done after the end of their usefulness, as it is decided in the context of each project and the permanent procedures.

• Legal documents are kept indefinite.
• Questionnaires for research purposes are kept until the completion of each research.
• Personal data through physical files in the form of participation forms in games, seminars, etc. are kept until the completion of each action.
• Comments posted on the WEBSITE and their metadata are kept indefinite.

F) Users’ Rights

All users can edit and/or delete their personal data at any time. More specifically, customers may:

• Submit request to know which personal data concerning them are kept and processed, as well as their origin (right of access).
• Request the data to be corrected and/or supplemented so that they are complete and accurate, providing any necessary documentation from which the need for completion or correction arises (right of correction).
• Request a restriction on the processing of their data (right to restrict).
• Refuse and/or oppose any processing of their personal data held (right of objection).
• Request the deletion of their data from the files of the COMPANY (right to be forgotten). This right does not apply to data that the COMPANY is obliged to keep in compliance to administrative, legal or security purposes.
• Request the COMPANY to transfer the data provided to it to any other controller (right to data portability). The exercise of the right to portability does not imply the deletion of data from the COMPANY files.
• To request and receive an extracted file of personal data maintained by the COMPANY.

In any case, users can change their preferences at any time, using the registration cancellation link at the end of each e-mail they receive from the COMPANY.

The COMPANY reserves the right to refuse the request to limit the processing or deletion of customer data if the processing or compliance with the data is necessary for the establishment, exercise or support of its legitimate interest, its legal rights and/or its compliance with its legal obligations.

G) Protection and exercise of your Rights

To exercise the above rights, the customer can address:

• with a physical presence in one of our offices, completing a rights exercise form,
• electronically on the COMPANY’s website http://creatorsofcosmos.com/, filling in the contact form
• via e-mail at [email protected]
• by submitting a complaint to the Personal Data Protection Authority (dpa.gr), which is the competent supervisory authority for the protection of the fundamental rights and freedoms of natural persons against processing, if they consider that their rights are being violated in any way.

The COMPANY efforts to respond as soon as possible to the submitted requests and in any case within two months from the initial submission if this is required at the discretion of the COMPANY. The service is provided free of charge.

The COMPANY implements an information security management system to ensure confidentiality, security of the processing of customer’s data and protection against accidental or unfair destruction, loss, alteration, prohibited dissemination or access and any other form of unauthorized processing.

Transaction Management and Security

Α) Booking Service – Completion of a Transaction

For the majority of the goods – products and/or services provided through the WEBSITE, it is possible to book in advance, that is in advance commitment of an available good/product and/or service after a relevant explicit order from the respective customer. The booking order binds the customer, who in any case must pay the corresponding price unless otherwise provided, in accordance with the applicable reservation-cancellation procedure which may have been followed.

Β) Pricelist – Methods of payment

The prices listed on the WEBSITE in accordance with each good – product and/or service provided reflect the final price, including the corresponding taxes and fees, which apply at the time of completion of the transaction, unless otherwise specified in the WEBSITE.

The prices, as stated in the WEBSITE, may be modified by the COMPANY even after the completion of the reservation process, provided that the COMPANY makes a relevant notification. In any case, it is pointed out that any changes in prices after the confirmation of the reservation are made only in exceptional cases and are mainly due to an increase in the imposed tax, fees and/or duties.

The price of each good/product and/or service is paid in accordance with the manner notified to the WEBSITE. Mostly, the payment is made by cash on delivery to the bank account provided by the COMPANY, via PayPal™ or by physical means via cash and credit card use (no natural POS is available but e-pos via PayPal™ service may be used – for more information see Legal Note section of this POLICY STATEMENT).

Customer details are automatically forwarded to the payment service provider cooperating with the COMPANY that performs the credit card transaction in case of procurement of goods/ products and/or services provided by the COMPANY.

Every customer must use a credit card that is legally owned and authorized by the user. In case of use of a third-party credit card, it is required to provide documentation verifying special authorization or consent on the legal holder’s behalf.

The COMPANY is entitled, for security reasons, to reject customer orders resulting the purchases of goods – products and/or services not to be completed and/or to cancel any related transaction. The COMPANY is entitled to request at any time, in the context of the provision and charge of its goods – products and/or services, the presentation by any customer of any data deemed necessary (e.g. copy of ID or Passport and/or credit card, proof of address residence, etc.), for identification purposes between customers as legal holders of used credit cards and for any other reason deemed necessary by the COMPANY. Acquirement of any such documentation -when not possible by e-mail-, is done by submitting a physical file to the COMPANY’s offices.

In case the customers choose from the beginning a transaction for the purchase of good – products and/or services available from the COMPANY and/or just the completion of the transaction with payment through the provider of payment services of 3862/2010 Greek legislation that incorporates EU directive 2007/64 (including banks, e-money institutions, as well as physical outlets/stores operating as representatives of e-money institutions, in accordance with the provisions of the aforementioned law), these providers may charge customers with transaction costs, in accordance with their commercial policy, regardless of means or method of payment that customers will choose (e.g. cash, credit card or through the banks participating in the DIAS DEBIT service by supporting payments via cash, internet banking, phone banking and ATM).

Customers may use a PayPal™ account to pay for their orders/purchases. The PayPal™ Payment process is fully automated and usually completed within minutes. During this process no personal information (including credit card number) are stored in the WEBSITE.

If customers wish to pay the amount of purchase, of goods – products and/or services provided by the COMPANY, by deposit in a bank account, they oblige to provide a copy of the bank payment order by email to [email protected]. Upon receiving the copy, the COMPANY undertakes procedures to complete the purchase process. The reason for the deposit must indicate an order number and what it regards.

C) Cancellation Process – Refund

The COMPANY is solely responsible for determining the possibility and process of cancellation and/or change of reservation and/or supply of goods – products and/or services, in accordance to terms that have been formulated and made public on time.

Customers wishing to cancel or modify bookings or purchases must send a request to [email protected]. If there is a possibility of cancellation or change according to the terms posted, customers are informed of their application regarding the amount that may be refunded and the amount that may be withheld as a cancellation fee.

In case of automatic rejection of the reservation for security reasons, the refund is made directly to the customer. In case of cancellation of the transaction for security reasons, the refund is made to the customer in accordance with the rules of International Card Maps (suggested card forms such as VISA, MasterCard, American Express, Diners, etc.).

D) Confidentiality of Transactions

All information transmitted by the customer to the cooperating payment company PayPal™ are confidential and used only to the extent that it is deemed necessary for the purchase of goods – products and/or services selected by customers from the WEBSITE.

ONLY authorized employees have access to the information/data related to the transactions and ONLY whenever this is necessary.

1. The COMPANY does not disclose customer details and their transactions, except to the extent required to provide its goods – products and/or services selected by customers.
2. For their own safety, customers should handle all information they disclose as confidential and not disclose it to third parties without authorization.

Credit card transactions are made through PayPal™. The COMPANY does not maintain or process the data of the cards used and the payment process through debit, credit and prepaid cards is carried out exclusively by the PayPal™ system.

Transactions via PayPal ™ (online service that is widely used for online commerce) are ensured through the encryption of transactions of the same service. For more information about PayPal™ services and their security protocol visit the website: www.paypal.com.

Legal Note on the acceptance of Credit / Debit Cards

According to Hellenic Legislation 4446/2016 (Article 65) it is imposed on companies, self-employed and entrepreneurs provided with Code of Activity Numbers (CAN), as directed by the JMD 45231/20-4-2017, the obligation to accept payments by card payment means. Article 62 of the same law, as a “means of payment by card, are means available for payment which allows the payer to initiate a payment by card (credit, debit, prepaid), mobile phone banking, computer or other technological device included the appropriate payment application by which the payer is given the opportunity to initiate a card payment procedure, which is not a credit transfer or direct charge as defined in Article 2 of Regulation (EU) No 182/2011. 260/2012”.

According to the above, the acceptance of payments by means of payment by card on behalf of the obligor does not presuppose exclusively and necessarily the acquisition and installation of a traditional terminal devices (POS). On the contrary, under this statutory regime, the obligor (business or freelancer) may choose the application/technological solution (even intangible/electronic) that serves him, as long as they secure to the consumers with card payment means.

According to the above, the COMPANY accepts the payment by card -with the acknowledgement of its customers- through its website, offering PayPal™ payment means which is an online service that is widely used for commercial transactions on the internet.