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Add translated Privacy Policy of CPC/CPS Mixed Billing Model
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Closes T167387
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vmank committed Mar 19, 2024
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6 changes: 4 additions & 2 deletions .../analytics/cps_privacy_policy.html.md.erb → ...alytics/cps_privacy_policy.el.html.md.erb
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---
parent: analytics
title: cps_privacy_policy
locale:
skroutz:
- 'el'
- 'en'
---

# Πολιτική Απορρήτου του Μεικτού Μοντέλου Χρέωσης CPC/CPS

<% I18n.with_locale('el') do %>
<%= partial 'partials/toc' %>
<% end %>

## Τι είναι το Μεικτό Μοντέλο Χρέωσης CPC/CPS

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236 changes: 236 additions & 0 deletions source/localizable/analytics/cps_privacy_policy.en.html.md.erb
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---
parent: analytics
title: cps_privacy_policy
locale:
skroutz:
- 'el'
- 'en'
---

# Privacy Policy of CPC/CPS Mixed Billing Model

<%= partial 'partials/toc' %>

## What is the CPC/CPS Mixed Billing Model

The CPC/CPS Mixed Billing Model is one of the billing models of Skroutz associates,
according to which the charge is made depending on the category of products either per
click or based on commission on sale.
This model, in order to record purchases made on a merchant partner’s
website, after the user navigates to them via
Skroutz.gr, uses cookies, to calculate the relevant commission. The
CPC/CPS Mixed Billing Model works in parallel with, but also partially separately from,
the Skroutz Analytics functionality, the service of exporting statistics
on the performance of participating Skroutz stores.

## How it works

When a user switches from Skroutz to an associate store
participating in CPC/CPS Mixed Billing Model &mdash; and if a relevant purchase
is actually made &mdash; browsing data about the user's session in that store
are transmitted to Skroutz.

Cookies used to support the CPC/CPS Mixed Billing Model are disabled in
any case after 15 days, in accordance with commonly accepted sales acquisition practices.

It is clarified that these "Billing" cookies are activated without
the need for user consent, as they are absolutely necessary for the
calculation and settlement of the financial transaction. If the user does not give
his/her consent to "Performance" cookies in Skroutz.gr, only "Billing" cookies are activated,
while cookies for the operation of the Skroutz Analytics service are not.

If the user gives his/her consent to the "Performance" cookies in Skroutz.gr, when visiting
a store with CPC/CPS Mixed Billing Model, the Skroutz Analytics service and related cookies
are activated, a subset of which now becomes the charge/commission mechanism of the CPC/CPS
Mixed Billing Model. In this case, given the user's consent, Skroutz Analytics cookies serve
a dual purpose: export of statistics on the use of Skroutz services and calculation of
Skroutz charges/commissions.

## What data does it collect?

When the user visits an associate’s merchant website that uses the CPC/CPS Mixed Billing Model,
their web browser sends certain information to Skroutz.

Specifically, the information recorded is:

- The transition from Skroutz to a merchant partner’s store
- Visits to pages of the merchant partner’s store
- The purchase of specific products and its details (order number, amount, products, payment method, etc.)
- Timestamp (browsing time)
- The IP address of the user
- Device-specific information (such as operating system version, app or web login, browser version)

The above is linked to an order ID, which does not directly identify the user for Skroutz. For other
categories of data collected by Skroutz when the Skroutz Analytics service is also enabled,
see more details [here](/analytics/privacy_policy/).

The information of a user that we receive from partners may be directly associated with that user's
Skroutz Account (Skroutz username), only after their own specific action (e.g., "Save my order to Skroutz").

Otherwise, data collected through the CPC/CPS Mixed Billing Model may be considered personal data by
applicable data protection laws, as it can identify a person (although they do not directly identify them).
For this reason, they are treated by us in each case and in their entirety as personal data and we apply
to them all appropriate technical and organizational security measures. Some of these measures can be found below.

## What data does it produce?

The data resulting from the CPC/CPS Mixed Billing Model are analyzed per store and per market.
If the user has also given his/her consent to the "Performance" cookies in Skroutz.gr, analyses
are also produced that capture sales statistics based on the store, the product, and each category.

## Data lifetime

The information associated with the Account of Skroutz is retained until deletion is requested.
Either through [their account](https://www.skroutz.gr/account) or by contacting the Data Protection Officer of Skroutz at <dpo@skroutz.gr> email.

The browsing data collected by Skroutz through cookies in view of the CPC/CPS Mixed Billing Model
is considered by Skroutz as contractual personal data, capable of proving the transaction and supporting
any legitimate claims of Skroutz. For this reason, this data will be kept for a maximum of 5 years.
This data will then be completely deleted or anonymized (i.e. it will no longer be considered personal data by law).

## How they are used

When a user visits websites or uses apps that use the CPC/CPS Mixed Billing Model,
we use the information we receive about purchases from those sites and apps to:

- Correctly calculate and invoice the associate for the commission from the
use of our services.
- Detect and respond to fraud and other transaction security risks in
order to protect users and partners.

## How we share data with third parties

We do not share personal information with companies, organizations, or individuals
outside our group.

As the collected and generated data of the CPS/CPS Mixed Billing Model is treated
by us as personal data of users, which is processed for common billing purposes
between the respective merchant associate and Skroutz, we are considered &mdash; based
on applicable law &mdash; Joint Data Controllers with each merchant associate using the
CPC/CPS Mixed Billing Model. Regarding our compliance with this, we undertake to
inform users and include a special mention in our contracts with our merchant partners.

## Lawfulness of data processing

The CPC/CPS Mixed Billing Model is a tool that works partially through cookies,
which aim to calculate and clear associate billing for commission from the use
of our services. The applicable legislation is in principle the e-Privacy Directive
and the Greek implementing Law 3471/2006, as in force, and the user's consent is not
required for the placement and subsequent reading of such cookies, strictly necessary
for the provision of Skroutz services to users.

In this context, we inform users in detail about the processing of their personal
data for transactional purposes, both in the [privacy policy](https://www.skroutz.gr/privacy)
and the [cookie policy](https://www.skroutz.gr/cookies) of Skroutz.gr.

Regarding the lawfulness of processing concerning the use of Skroutz Analytics,
please see more in our [Skroutz Analytics Privacy Policy](/analytics/privacy_policy/#section-8).

## Recommended compliance actions

According to the law, the user should in any case be informed about the use of cookies on his device.*

### Privacy Notice

It is suggested that you add in a separate paragraph to your Cookies Policy or
alternatively to your Privacy Policy at least the following:

> _**Skroutz Service Usage Data**_
>
> _Our company, in order to be able to evaluate and continuously improve
> the quality of the services it provides to the consumer, uses the
> Skroutz Analytics service, which works with cookies. Through this
> service, if you have previously given your consent through the Skroutz.gr,
> usage statistics are securely communicated by us to Skroutz. The data
> received by our company through this service is covered by the [privacy
> policy](https://www.skroutz.gr/privacy) as well as the Skroutz.gr's
> [Cookies Policy](https://www.skroutz.gr/cookies), at the end of which
> **you can withdraw any consent.**_
>
> _In addition, we inform you that, if you have been directed to our
> online store through the Skroutz.gr and make a purchase with us,
> data relating to your specific purchase are securely communicated
> by us to Skroutz, in the context of our commercial cooperation with
> Skroutz and your use of the Skroutz services. Our sharing of this
> data is done through cookies and is necessary for the financial
> settlement of this commercial cooperation, which you may have used.
> Due to this necessity, the law allows us not to ask for your consent
> to share this data. More information can be found in the
> [privacy policy](https://www.skroutz.gr/privacy) as well as the
> [cookie policy](https://www.skroutz.gr/cookies) of Skroutz.gr._


### Cookies Categorization

It is recommended to inform the user on your website about the cookies
used in the context of the CPC/CPS Mixed Billing Model, (hereinafter
referred to as CPS Skroutz cookies) as necessary including cookie name,
purpose, duration, as well as the access of Skroutz to them.

User consent is not required for the use of CPS Skroutz cookies, neither
on Skroutz.gr nor on your website, as these are necessary cookies for
the calculation and financial settlement of the CPC/CPS Mixed Billing Model
of the Skroutz Services.

Therefore, the following cookies should be presented as necessary on your
website, with the inclusion of the following complete list in your cookie
policy and placed independently of user consent on your website.

#### **Necessary / Necessary**

| Name | Purpose | Duration | Third party with access |
|------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------|-------------------------------|
| _b_nltcs_ss | User categorization. Recording of user purchases, following the transition from Skroutz.gr, for the operation of the CPC/CPS Mixed Billing Model pricing service. | 15 days | Skroutz |
| __b_skr_nltcs_ss | User categorization. Recording of user purchases, following the transition from Skroutz.gr, for the operation of the CPC/CPS Mixed Billing Model pricing service. | 15 days | Skroutz |
| __b_sa_session | User categorization. Recording of user purchases, following the transition from Skroutz.gr, for the operation of the CPC/CPS Mixed Billing Model pricing service. | 30 min | Skroutz |
| __b_skr_nltcs_mt | Record a user login type who makes a purchase after switching from Skroutz.gr to support the CPC/CPS Mixed Billing Model pricing service. | Until closing the browser | Skroutz |
| _b_sa_meta | Record a user login type who makes a purchase after switching from Skroutz.gr to support the CPC/CPS Mixed Billing Model pricing service. | Until closing the browser | Skroutz |
| __cf_bm | Security of the Website from malicious/automated traffic. | 30 min | Cloudflare |

<sub>
More information about Cloudflare's privacy policy can be found
[here](https://www.cloudflare.com/privacypolicy/) and in particular about
the Bot Management service we use
[here](https://developers.cloudflare.com/fundamentals/get-started/reference/cloudflare-cookies/#__cf_bm-cookie-for-cloudflare-bot-products).
</sub>

In addition, it is suggested to inform the user on your website
about Skroutz Analytics cookies as performance / analysis / statistics,
including cookie name, purpose, duration, as well as Skroutz's access to them.

No second user consent is required on your website to use Skroutz Analytics.
On the contrary, the first consent that the user has given to the Skroutz.gr
is required and sufficient. It is noted that if the user does not give
consent to the Skroutz.gr through the special mechanism of active (opt-in),
distinct (per category of cookies-here category of "Performance") and updated
(three levels of analytical information) consent, or if you withdraw any such
consent already given through the special consent withdrawal mechanism found
in the [Skroutz.gr Cookie Policy](https://www.skroutz.gr/cookies), Skroutz
Analytics is not used.

Therefore, the following cookies should be presented as performance/analysis/statistics
on your website, with the inclusion of the following complete list in your
cookie policy and placed independently of user consent on your website.

#### **Performance / Analysis / Statistics**

| Name | Purpose | Duration | Third party with access |
|-------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------|-------------------------------|
| analytics_session | User categorization. Support Skroutz Analytics and User Purchases Reporting functionality after users transition from Skroutz.gr. | 15 days | Skroutz |
| __skr_nltcs_ss | User categorization. Support Skroutz Analytics and User Purchases Reporting functionality after users transition from Skroutz.gr. | 15 days | Skroutz |
| __sa_session | User categorization. Support Skroutz Analytics and User Purchases Reporting functionality after users transition from Skroutz.gr. | 30 min | Skroutz |
| __skr_nltcs_mt | Analysis of the interaction of the users of the website, after their transition from the Skroutz.gr. The aim is to evaluate and improve our services, as well as Skroutz services, through relevant statistical analysis of usage. May be used side-by-side for user purchase reporting. | Until closing the browser | Skroutz |
| _sa_meta | Analysis of the interaction of the users of the website, after their transition from the Skroutz.gr. The aim is to evaluate and improve our services, as well as Skroutz services, through relevant statistical analysis of usage. May be used side-by-side for user purchase reporting. | Until closing the browser | Skroutz |

<sub>
* It is emphasized that the above advice does not in any way constitute
a legal opinion of Skroutz to its associates and nor should it be taken
as such. Each partner must ensure the legal and regulatory compliance
of his company, including the legislation on the protection of personal
data and privacy.
</sub>

## Skroutz Privacy Policy

More about general Privacy Policy can be found [here](https://www.skroutz.gr/privacy)
and Cookies Policy [here](https://www.skroutz.gr/cookies).

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