PRIVACY POLICY

I. INTRODUCTION

1. General

The respect of your privacy and the protection of your personal data is a priority for the societe anonyme company with the name «MySRApp SOCIETE ANONYME», having its legal seat in Piraeus, Athens Greece, 5 Agiou Konstantinou Str.,18531, with GEMI registration no 175223307000 Tax ID Nr. 802373780, with email [email protected], telephone________(hereinafter the “Company”, “we”, “us,” “our”). The Company has the present Privacy Policy (hereinafter the “Privacy Policy” and / or “Policy”), in order to inform you about the data that we collect, store, disclose and use for you (“you”,”yours”, “User”) the users of the MySRAPP Site (hereinafter the “Site”), about the purpose and way of processing your personal data, any third parties that receive your data, your rights and options for your personal data, and our contact details in relation to your personal data.

2. Amendments

This Privacy Policy -is in force since _______2025. This Privacy Policy is governed by the European Community law relating to the protection of individuals from the processing of personal data. Any possible future change to the above regulatory framework will be incorporated in this Policy. Therefore, we reserve our right to change this Policy and to apply any change to your data and practices in relation to the collection and processing thereof, as required by law, and / or to modify or replace the whole and / or part of this Policy in our sole discretion.

If there are substantial changes to this Policy or our practices regarding your data change in the future, we will notify you by publishing the changes to the Site and / or by providing you with relevant updates. However, if you wish to have any clarification or information regarding the changes, or have any dispute, reservation or question about them (changes), you may our contact details listed in the below Section. Please note that any information / clarification about changes to this this Policy given to you the way described above does not constitute a substitution, or any modification of this Policy.

By continuing to use the Site you accept automatically and unconditionally the modified terms of this Policy. In the event that you do not agree with the modifications, you should not make any action or use of the Site, and not provide us with any of your personal data. You are entitled to terminate the contracts between us and request the deletion of your Account and your data, to the extent permitted by applicable law. For any information or clarification, you can contact us and in any case you have the right to exercise your rights as detailed in Section V below.

3. Content of the Privacy Policy

Our Privacy Policy includes:

• Information about the Data Controller, the Data Protection Officer (DPO), and the relevant contact details for any issue related to your personal data.

• The type of personal data that we collect for you and methods of collection.
• The purpose of collection and processing of personal data and the legal basis for the processing.
• Security measures that we undertake for the protection of your personal data and how long we keep them.
• Your rights and the ways to exercise them and any options you may have regarding processing of your personal data.
• Information about the protection and storage of your personal data by our Company.

II. DATA CONTROLLER AND DATA PROTECTION OFFICER

1. Who is the Data Controller?

Data Controller of your personal data is the societe anonyme company with the name «MySRApp SOCIETE ANONYME», having its legal seat in Piraeus, Athens Greece, 5 Agiou Konstantinou Str.,18531, with GEMI registration no 175223307000 Tax ID Nr. 802373780, with email [email protected]– (“Company”, “us,” “our,” and “we”).

2. Who is the Data Protection Officer?

The Company has appointed a Data Protection Officer (DPO) responsible for overseeing questions in relation to data protection. You can contact the DPO at [email protected].

3. Questions and Comments

You may communicate with us using the contact details above and submit any comment, inquiries, observations or any complaints regarding this Privacy Policy and generally the collection and processing of your personal data. You have the right to submit any claim with reference to your personal data before the Competent Authority in your country. It is our obligation to handle any thoughts or inquiries about your personal data and we are glad to communicate with you at any time.

III. COLLECTION AND PROCESSING OF PERSONAL DATA

1. WHAT personal data do we collect and HOW we collect them

We collect personal data when you subscribe to the Site and use the Site. We collect different types of personal data, either directly from you or from third parties through automated means such us (indicatively):

• Identity data: You provide us when you subscribe to the Site, meaning your username that is your email, your unique personal password, as well as your first name, surname etc.
• Communication Data: You provide us, such as your email and phone number to contact you regarding the Site and your Account etc.
• Financial Data based on the purchases that you have concluded, any refunds by the side of the Company etc. Also we collect your address and country of residence or establishment for the purpose of verifying your tax status and determining potential Value Added Tax (VAT) exemption, where applicable We do not process any data of your credit cards.
• Technical Data: IP address, browser type and version, operating system and platform etc.
• Account data any data that are in your account including your preferences such as musical instruments, skill level, frequency of course participation, photos that are uploaded to our Site under the assumption that you have granted us the corresponding permission to do so etc.
• Login Data to your account, which is your email and password.
• Course Data/Rating Data reviews that you upload in the Site regarding the quality of the provision of the Course.
• Cookies data that we collect based on our cookie policy.

Our Services are designed for users who are 18 years old or older and we collect their personal data as per this policy. If you’re under 18, please make sure your parent or legal guardian is aware of this policy and agrees to share any personal data with us on your behalf. By using the Site or Services as someone under 18, we assume that your parent or guardian has reviewed and accepted this policy and is okay with your use of the platform.

Learn more……

Personal data we collect directly from you:

• When opening your Account, you provide us necessarily your email and a password.
• When you contact us, we collect data in order to respond to your request.
• When using the Site, we collect financial data for purchases of Courses, the total number of purchases through the Site, login data such us your email and your password.

We collect from third parties the following data and information about you:

• When you rate the Course, we collect course / rating data about quality of the Course.

2. HOW and WHY do we use your personal data.

All the above personal data that you provide us with necessarily or voluntarily, or that we collect from third parties or by automated means, we use for the legal purposes referred below. However, where the European laws restrict or prohibit certain activities described in this notice, we will not use information about you for those purposes.

Subject to the above, depending on the nature of our relationship with you, we may use information about you for the following purposes:

• To subscribe to the Site and open your Account.
• To provide you the Site.
• To identify you.
• To communicate with you about your Account.
• To communicate with you about the Site.
• To manage payments.
• To help you as a User of the Site.
• To handle / process your requests, change your personal details, exercise your rights.
• To transmit documents and information necessary for the use of the Site.
• For security reasons for the transactions.
• For business analysis and enhancements, such as making our services available and optimized, optimizing your experience and service within the Site, and customizing your experience in the Site.
• For statistical analysis reasons.
• For marketing purposes.
• For other purposes that we will notify you of, or identify to you on a case-by-case basis, at the point where your information is originally collected.

The legal basis for our use of information about you is one of the following (which we explain in more detail in the “learn more” section):

– Compliance with a legal obligation to which we are subject;

– The performance of a contract to which you are a party;

– A legitimate business interest that is not overridden interests you have to protect the information;

– Where none of the above applies, your consent (which we will ask for before we process the information).

Learn more……

Purpose of processing	Data that we process for the purpose	Legal basis
Subscription to the Site We process your data: To recognize you as User. To give you access to the features and services of the Site. To use the Service / Features of the Site. Secure the access.	Identity data Log in data	Legal basis is: a) Fulfilling of our contractual obligations to subscribe and open account in our Site. b) Legitimate interest to secure your account and identify you if necessary detect any fraud etc.
Manage Your Account in the Site-Provide Courses	Identity data Communication data Financial data Account data	Legal basis is Fulfilling our contractual obligations to provide you with the Course based on your purchases.
Rating of the Courses We process your data: When you rate the quality of the Course. In order to ensure the quality of the Course and to improve the Company’s services.	Course/Rating data	Legal basis is Legitimate interest of the Company to ensure the quality of the Courses and improvement of Company’s services.
Promote the Site and the Courses Display Tutors’ images and videos on the Company’s platform. Advertisements, social media posts, email campaigns, third-party collaborations, and any other promotional materials.	Identity data Communication data Account data (your preferences that you have provided us when you enter the Site Cookie data	Legal Basis is Our legitimate interest in case you are a client/you have already purchase a Course or your consent in any other case. Your consent in case you provide us with your answers regarding your preferences for musical instruments, courses etc and also for marketing cookies.
Support, handling of your requests- Communication regarding Courses. We process your data for: Communication. Your support in general on issues related to the Company, its services, your Account. Complaints or clarifications. Generally, management and optimization of user experience in the Site.	Identity data Communication Data Course data	Legal basis for Fulfil of contractual obligations when you contract us about the usage of the Site and using a Course. Consent when you send us a request, communicate with the Company with your consent.
Statistical analysis to rate and improve Site services and procedures that includes: Rating and improvement of business processes. Responsiveness and management of your requests. Responsiveness and management of the Site. Research and / or analysis to understand needs of end users Adoption of new business and business models, programs and partnerships. Improvement of your experience. Delivery of related content. Quality surveys. Statistical analysis.	Financial data Account data Course/Rating data Cookie data	Legal basis is: a) The legitimate interest of the Company for the further processing of aggregated data for the purpose of statistical analysis to improve its products and services while complying with all the necessary safeguards to collect and process data that do not identify a particular data subject and do not affect the rights and freedoms of data subjects. b) The legitimate interest to, analyze usability and functionality of the Site, to improve our business performance for our users, to improve our partnerships, always respecting your rights, freedoms and interests for your personal data.

3. WHO do we share your information with and for what purposes?

For the operation of the Site, fulfillment of contractual obligations and for your best support as User, our Company reserves the right to cooperate with third-party service providers that provide us with their services and access only those data that are absolutely necessary for the service they offer us (e.g. subscribing to the Site and managing your account, execute our contract between us, optimization of our services, etc.). These third service providers are bound by contract not to use your information for any other purposes.

More specifically, our Company cooperates indicatively with:

(a) Α third company acting as processor and hosts data that you provide us through the Site.

(b) Data analysis companies.

(c) Research companies.

(d) Providers of technology services.

We reserve the right to disclose your personal data to a third party that we choose to transfer all or part of our business. In addition, in the event of a merge or redemption or other change in our business, the new owners, etc. have the right to use your personal data in the same way according to this Privacy Policy.

Your data may be communicated to competent judicial, police and other administrative authorities upon their request and in accordance with the applicable laws. Moreover, in case of a statutory provision, a service order or a formal preliminary examination, our Company has the right to place the relevant information at the disposal of the respective authority.

IV. PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA

1. SECURITY of your personal data

We take appropriate technical and organizational measures to protect your personal data from unauthorized disclosure, use, conversion or destruction. Where appropriate, we use encryption and other technologies that can help to secure any information you provide us. We also ask our service providers to comply with privacy and data protection requirements.

Learn more……

More specifically, your personal data are managed exclusively by specially authorized personnel of the Company under our control. In order to conduct the processing, the Company selects individuals or third parties with corresponding professional qualifications that provide sufficient guarantees in terms of technical knowledge and personal integrity to maintain confidentiality. The Company, through its respective contractual commitments and its partners, takes all necessary security measures to protect and secure confidentiality and integrity of personal data. In any case, the security is subject to reasons beyond Company’s influence, as well as to reasons resulting from technical problems of the network that are not controlled by the Company or reasons of force majeure events.

You should not disclose the data / passwords you have for your Account, which are personal and non-transferable. For personalized communication, our Company also uses appropriate mathematical and / or statistical processes to compile the profile and performs regular quality and security checks on the systems and algorithms it uses to correct the factors that lead to inaccuracies in the data.

2. HOW LONG will information about you be kept

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. Such period will vary depending on the purposes for which the information was collected. Please note that in some circumstances, you have the right to request a deletion of the information. Furthermore, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes. We may also keep it until you request its deletion, or in case of data based on your consent, until you withdraw your consent, or until you opt out for the processing for which we have legitimate interest.

To determine data retention time of your personal data, we take into account the nature of your data, the quantity, purpose, security, etc. You have the right to request from us to delete your data. To exercise your right, please visit the relevant Section in this Privacy Policy.

We reserve the right in certain circumstances to anonymize your data for research or statistical purposes, so that it cannot be associated with an identifiable person, therefore we reserve the right to use this information for an indefinite period of time. In any case, your data is stored with safety.

Learn more……

Purpose of data processing	Data retention
Management of your Account	Till the deletion / deactivation of your account.
Rating	During the cooperation with the Company, until the deletion / deactivation of your account.
Provision of Courses	We will process your data for the time required to manage / provision of the Course, including complaints or claims for the use of the it.
Financial data	We will retain your transaction data for as long as we need to complete the transfer and comply with any legal obligations (for example, for tax and accounting purposes).
Promotion of the Site/Courses	We will use your data as per above for the promotion of the Site, unless you opt out from our using it.
Contact with the Company	If you contact the Company, we will create a record and keep it as long as it remains relevant to our relationship.
Usability and quality analysis	We will process your data during the period we will perform an action or a specific quality survey or until we have anonymized your browsing data.

3. TRANSFER of your personal data to third countries

The Company generally keeps your personal data within the European Economic Area. When your data is to be transmitted to third countries outside the European Economic Area or International Organizations for which no European Commission decision is available, all the appropriate safeguards provided for in the applicable data protection legislation on the transfers to third countries.

4. YOUR RIGHTS AND YOUR OPTIONS

You may have some or all of the following rights in respect of information that we hold about you:

· Request us to give you access to it;

· Request us to rectify it, update it, or erase it;

· Request us to restrict our use of it, in certain circumstances;

· Object to our using it, in certain circumstances;

· Withdraw your consent to our using it;

· Data portability, in certain circumstances;

· Opt out from our using it for direct marketing; and

· Lodge a complaint with the supervisory authority in your country (if there is one).

We offer you easy ways to exercise these rights, by sending email at [email protected].

It may be necessary, for the security of your information, to ask for some information about you for the purposes of your identification. Your right is exercised free of charge, however, when your right is abusively used, we may ask you a fee in accordance with the conditions set by law. In any case, we respond to your requests within one month, except in exceptional cases where our response time to a request may be longer.

Learn more……

Right in respect of the information about you that we hold	Further detail (note: certain legal limits to all these rights apply)
To request us to give you access to it (article 15)	This is confirmation of: · Whether or not we process information about you; · Our name and contact details; · The purpose of the processing; · The categories of information concerned; · The categories of persons with whom we share the information; · (if we have it) the source of the information, if we did not collect it from you; · (to the extent we do any, which will have been brought to your attention) the existence of automated decision-making, including profiling, that produces legal effects concerning you, or significantly affects you in a similar way, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and · The criteria for determining the period for which we will store the information. On your request we will provide you with a copy of the information about you that we use (provided this does not affect the rights and freedoms of others).
To request us to rectify or update it (article 16)	This applies if the information we hold is inaccurate or incomplete.
To request us to erase it (article 17)	This applies if: · The information we hold is no longer necessary in relation to the purposes for which we use it; · We use the information on the basis of your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us you want us to delete all information about you in which case we will respect your wishes); · We use the information on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it; · The information was unlawfully obtained or used; or · To comply with a legal obligation.
To request us to restrict our processing of it (article 18)	This right applies, temporarily while we look into your case, if you: · Contest the accuracy of the information we use; or · Have objected to our using the information on the basis of legitimate interest; (if you make use of your right in these cases, we will notify you before we use the information again). This right applies also if: Our use is unlawful and you oppose the erasure of the data; or We no longer need the data, but you require it to establish a legal case.
To object to our processing it (article 21)	You may at any time object to any processing of your personal data, which are processed under the legitimate interest of the Company or the fulfillment of a duty performed in the public interest.
To withdraw your consent to our using it (opt- out)	This applies if the legal basis on which we use the information about you is consent. These cases will be clear from the context.
To data portability (article 20)	If: (i) you have provided data to us; and (ii) we use that data, by automated means, and on the basis either of your consent, or on the basis of discharging our contractual obligations to you, then you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible for us to do so.
To lodge a complaint with the supervisory authority	You can lodge a complaint with the supervisory competent authority in your country.
Identity card	We take into account the confidentiality of all files that contain personal data and we reserve the right to ask you for proof of your identity if you make a claim about those files.
Costs	We will not charge you for the exercise of your rights in relation to your personal data unless, as required by law, your request for access to information is unreasonable or excessive, so we may charge a reasonable fee under these conditions. We will notify you of any charges before fulfilling your request.
Timelines	We aim to respond to any valid requests within one (1) month of receipt, unless it is very complex or you have made a number of requests, so we aim to respond within three months. We’ll let you know if we’ll need more than one (1) month for the reasons outlined above. We may ask you if you can tell us exactly what you want to receive or what exactly is your concern. This will help us to act faster for your request. In any case, you should provide us with specific and truthful facts and / or facts in order to be able to answer and / or satisfy your request, otherwise we reserve the right to make any errors that are out of our control. In addition, our Company may refuse requests that are unjustified or excessive or abusive or inaccurate or generally illegal according the provisions of the law.