Steve Zafeiriou is a New Media Artist, Technologist and Founder of Saphire Labs. His work explores the boundary between perception and reality, researching the ways technology influences, shapes, and distorts our understanding of the world around us. Through a practice grounded in generative algorithms, electronic circuits, and interactive installations, Steve investigate human behavior and the illusory nature of reality, encouraging viewers to rethink their understanding of the world around them.

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Privacy Policy

Last updated: Oct 26, 2024.

Introduction

This privacy policy provides information about how SAPHIRE (“Saphire”, “we”, “us” or “our”) collects, uses, transfers and maintains the personal data of users (“user”, ”you” or “your”) when you visit www.stevezafeiriou.com and the website www.saphirelabs.com (the “Sites”), including all content, the tools, applications, functionality, subdomains and services offered on or through the Sites, their mobile applications (“Apps”), or use any of the services (the “Services”) offered by us.

The website www.saphirelabs.com and the website www.stevezafeiriou.com belongs to and has been put into operation by the sole proprietorship of Stefanos D. Zafiriou, with the distinctive title Saphire, based in Evosmos Thessaloniki (9, M. Avgeri), PO Box 56224, Greece, telephone 2314001545, (“controller”).

The management and protection of the personal data of the user of the Services is governed by the European Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), by any other European and national relevant applicable legislation and the terms of this privacy policy.

This privacy policy applies to information provided through the business and its Sites. The Sites are the company’s websites.

By accessing or using the Services, you consent to the information collection and data handling practices described in this Privacy Policy.

1. What personal data we collect about you

Personal data, or personal information, means any information about an individual from which that individual can be identified. This information includes your contact information and any other information you may provide during your request to access and use the Services, as well as any data about your use of the Services that may be collected automatically. Personal data does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

We take care to collect only your absolutely necessary personal data, which are appropriate and clear for the intended purpose and, for the best service to you and, which are provided by you voluntarily in the context of our communication and/or for the completion of the contract service provider.

When you visit the Sites or use the Services through the Sites, we may automatically collect certain information about your device, including information about your web browser, IP address, geographic location, time zone, and some of the cookies that are installed on your device. In addition, as you browse the Sites, we may use cookies to collect information about the individual web pages or products you view, which sites or search terms referred you to the Sites, and information about how you interact with the Sites. We refer to this automatically collected information as “Device Information.”

In addition, we collect certain personal data about the services you use, your purchases and the transactions you make through the Sites, which includes your name, address, email, telephone number, payment information (including credit card numbers and PayPal accounts), information necessary to complete the service contract and for communication purposes, username and password, only for those who wish to create an account on our Sites. We refer to this information as “Order Information”.

When we talk about “Personal Data”, or “Personal Information” in this Privacy Policy, we are talking about both device information and order information.

For more information about cookies and how to disable cookies, visit www.allaboutcookies.org. Please note that some of our Services require certain cookies to be enabled. If all cookies are disabled, not all Services may be available to you. Other than the information described, Saphire does not collect any other personal data from users of its Sites or Services.

In case you were directed to our website via a link from other websites, we are not responsible for the terms of management and protection of the personal data you provide during your visit to these websites. This Privacy Policy for personal data does not apply to information collected through any other website.

The Services may contain links to third-party websites or applications, including for the purpose of providing account connection services or payment services. Saphire does not control the privacy practices or the content of any such websites or applications. Accordingly, we are not responsible for the practices used by websites or services linked to or from the Services, including the information or content contained therein. Please remember that when you use a link to go from the Services to another website or applications, our Privacy Policy does not apply to third-party websites or services. You should review the applicable privacy policy and terms of service of third parties when visiting other websites or applications and before providing any Personal Information to such external websites or applications. Your browsing and interaction with any third party website or service, including those that have a link or advertisement on our website, is subject to that third party’s rules and policies.

3. How we use your personal data

We only use your personal information to the extent permitted by law. We process your personal data when entering into a contract with you or for specific purposes, including:

  1. For the purposes of technical management and development of the website and our business.
  2. To diagnose or resolve technical problems and issues related to our Services.
  3. To determine usage patterns and how we can customize our Services to better meet your needs.
  4. To analyze trends and track your use of and interactions with the Services to improve your experience and the services we provide.
  5. To provide you with our Services and to fulfill the contractual relationship.
  6. To contact you in order to inform you about our Services, to answer your related questions, for purposes of completing the contract, or to provide you with any other relevant information.
  7. To create a user account on our website, only for those who wish to do so.
  8. To prevent fraud or criminal activity, misuse of our products or services, and to ensure the security of our IT systems, architecture and networks.
  9. To comply with legal obligations and legal processes.
  10. To respond to any requests from public and government authorities, including public and government authorities outside your country of residence.
  11. To support, protect and manage our operations.
  12. With your consent. We may use or share your personal information with your consent to provide you with promotional information or marketing communications by email, text message, or telephone about products and services that we believe may be of interest to you. You have the right to withdraw your consent to marketing at any time by notifying us through our Sites.
  13. To track aggregate metrics such as total visitor numbers, traffic and demographic patterns.

In this process, we may use cookies, log file, device identifiers, location data and clear gif information. We may analyze your information in aggregate form to operate, maintain, administer and improve the Services. This aggregate information does not identify you personally.

Legality of the processing of your data by the business

The data protection regulation sets out the reasons why the company can collect and process your personal data. These reasons are:

  1. Serving the legitimate interests of the company.
  2. The performance of the contract to which you are a party.
  3. Compliance with the company’s legal obligations.
  4. Your consent, for the purposes for which it is provided.

4. Who are the recipients of your data

We do not share your personal data that you provide us with other organizations or other third parties without your express consent, except as described in this Privacy Policy. We may disclose your personal data to third parties under the following circumstances:

Service Providers and Professional Consultants. Some of your personal data may be transferred to our third party partners. These recipients may include third party companies and individuals who may process your personal data on our behalf (such as website hosting, data processing support providers, customer support, email delivery, data storage services and database management services). Recipients of your personal data may also be other third party partners of ours, such as lawyers, accountants, bankers, auditors and insurers, but on the condition that they undertake to maintain confidentiality, take appropriate security measures and comply with the legal framework for the protection of personal data. We only share personal data that enables them to provide their services to us or to facilitate the provision of their services to you.

Compliance with laws and law enforcement. Protection and Security. We may also share your personal data where required by law or subpoena, or if we reasonably believe such action is necessary to (a) comply with the law and lawful requests by governmental, regulatory, administrative, insurance, tax or other public authorities, (b) to enforce our terms of use or to protect the security, quality or integrity of our Services, and/or (c) to exercise or protect intellectual and other rights, property or the personal safety of Saphire, our users or others.

We may also use:

  1. Google Analytics to offer you an optimized user experience. You can find more information about Google Analytics’ use of your Personal Data here and here. You can also opt out of Google Analytics here.
  2. WooCommerce to power our business-to-business online store – you can read more about how WooCommerce uses your personal information here.

5. International Transfers

Saphire has service providers and other external third parties in the United States and other countries. Personal data or Personal information that we collect or receive may be stored and processed in the United States or any other country in which our service providers and/or other external third parties maintain facilities. Your personal information may be transferred to other third parties cross-border and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other areas with laws governing the collection and use of data that may differ from EU law, please note that we may transfer information, including personal data, to a country and jurisdiction that does not have the same privacy laws as your jurisdiction, and you consent to the transfer of your personal data to the US or any other country in which our service providers and/or other external third parties maintain facilities, and to the use and disclosure of your personal data your data, as described in this Privacy Policy.

6. Security of your personal data

We take appropriate technical and organizational safeguards to prevent the accidental loss, use or access of your personal information in an unauthorized manner, its modification or disclosure and any other form of unlawful processing. Your connection is secure because it uses SSL (Secure Socket Layer) technology. Some of the safeguards we use are firewalls and data encryption, access control, lan segmentation, antivirus, In addition, we limit access to your personal data to those employees, agents, contractors and other third party partners us who have a business need to come into contact with your personal information. Your personal data will only be processed taking appropriate security measures and subject to a strict confidentiality obligation.

However, the security of information in our website environment is subject to reasons beyond our control, as well as reasons due to technical or other network weaknesses beyond Saphire’s control, or force majeure or fortuitous events. Therefore, Saphire cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Services cannot be accessed, disclosed, altered or destroyed.

The transmission and exchange of information is done at your own risk. Although we take steps to protect against unauthorized disclosure of information, we cannot assure you that the personal information we collect will not be disclosed in a manner inconsistent with this Privacy Policy.

7. Your Rights

You can exercise the rights you are entitled to in relation to your Personal Data by contacting Saphire at any time – see the ‘Contact Us’ section below.

Rights of Subjects

In accordance with the provisions of national, EU and international law, for the protection of subjects against the processing of personal data and for the free movement of data, you have the following rights, as defined in the General Data Protection Regulation of the European Union (EU) 2016/679 (GDPR) and you can ask us to take the following actions in relation to your personal information that we hold:

  1. Access and Update: You have the right to obtain information about your personal data, which is or has been processed by us and we give you access to your personal data.
  2. Correction: You can request the update (completion of incomplete and/or correction of inaccurate data) in your personal data.
  3. Deletion (“right to be forgotten”): You can request the deletion of your data or the removal of any information from your data, provided that this does not contravene legal provisions. An erasure request can only be refused if an exception applies.

    If you wish to exercise any of the rights listed above, please contact us at info@saphirelabs.com. We may request certain information from you to help us verify your identity and process your request. Applicable law may require or permit us to refuse your request. If we decline your request, we will tell you why, subject to legal restrictions.

    To delete your data you should send an email to our email address info@saphirelabs.com with the subject “DELETE DATA FROM YOUR SYSTEM” from the account (email) you want to delete.
  4. Restriction of Processing: You have the right to request the restriction of the processing of your personal data.
  5. Data Portability: Upon your request, we will provide directly to you or to a third party of your choice (where technically feasible), your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you have initially given your consent for us to use or where we have used the information to perform a contract with you.
  6. Objection: You have the right to object at any time and to object also for reasons related to your particular situation, as you believe it affects your fundamental rights and freedoms, to the processing of personal data concerning you. You also have the right to object to the processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds for processing your information that override your rights and freedoms.

The above actions are carried out by us, once your request and identity are identified, and within a reasonable period of time, which will not exceed 30 days. Make sure you have all the necessary documents together with your application. When a request is complex or numerous, this can be extended up to two months.

Right to withdraw your consent. You have the right to withdraw, at any time, any consent you have given us regarding the processing of your personal data. However, this does not and will not affect the lawfulness of any processing carried out on your personal data that was based on your consent prior to its withdrawal. We will comply with your request within a reasonable time. If you withdraw your consent, we may not be able to provide you with certain services or products. We will let you know if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights listed above, please contact us at info@saphirelabs.com. We may request certain information from you to help us verify your identity and process your request. Applicable law may require or permit us to refuse your request. If we decline your request, we will tell you why, subject to legal restrictions. If you wish to make a complaint about the way we process your personal data or the response to your requests, please contact info@saphirelabs.com. If you are not satisfied with our answer or believe that we are not processing your personal data in accordance with the law, you have the right to submit a complaint to a data protection supervisory authority in your jurisdiction (competent Greek Personal Data Protection Authority – www.dpa.gr, Kifisias1 -3 Athens, 2106475600). EU citizens can find the data protection regulator here.

In addition, if you are an EEA resident, we note that we process your information to pursue our legitimate business interests as set out above, to provide our services to you, to comply with the law for our legal coverage in the event of a dispute, to optimize of our website and for our website security, compliance, fraud, prevention and security purposes and these processing activities are our legitimate interests. We take care to consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are outweighed by any adverse impact on you (unless we have your consent or are otherwise required or permitted by law). We will process your personal information for marketing and sales activities based on your consent where this is stated on our website at the time of collection of your personal information or further due to our legitimate interest in promoting our services. Please note that your information will be transferred outside of Europe, including the United States.

8. Data Retention

How long do we keep your personal data?

We retain your personal data only for as long as is reasonably necessary to fulfill the purposes for which we collected it, including the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you.

Please note that under certain conditions, you can ask us to delete your information. We will grant your deletion request ONLY if the conditions are met.

We may reserve the right to anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.

9. Protection of personal data of minors

The Sites and Services are not intended for persons under the age of eighteen (18) and Saphire does not knowingly collect data from or solicit information from persons under the age of 18 or knowingly permit such persons to register as users.

10. Cookies and similar technologies

Cookies

The Sites uses “cookies” to allow you to log in to our services and to track your traffic patterns. A cookie is a file containing an identifier (a string of letters and numbers) that is sent through a server and stored in the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies make our online experience easier, faster and much less complicated. Cookies help us personalize and make improvements to our website so you can have a pleasant and productive experience. Cookies usually do not contain information that can identify the user, but your personal data that we hold may be linked to data stored or retrieved by cookies. You can set your browser to reject all or some browser cookies or to notify you when websites set or access cookies. Check your browser for instructions on how to handle cookies. If you disable or reject cookies, please note that some parts of the Services or the Website may not be accessible or may not function properly. For more information about the cookies we use, see our Cookies Policy.

Tracking technologies in general

Regular cookies can generally be disabled or removed by tools available as part of most commercial browsers and in some cases blocked in the future by selecting certain settings. For more information, see the Cookies Policy.

Google Insights

You can exercise choices about Google Analytics’ use of cookies by clicking here and downloading the Google Analytics opt-out browser add-on.

Behavioral advertising from Steve Zafeiriou, Saphire and others

As described above, we use your Personal Information to provide you with targeted advertising or marketing communications that we believe may be of interest to you.

Similarly, third parties use cookies to serve advertisements for companies outside of Saphire to you on the Internet, whether you are on the Saphire Sites or other websites, based on your visits to the Saphire Sites and other websites. These cookies help third parties recognize the pages you view, the links and ads you click on, other actions you take on those web pages, and the website you came from before reaching a web page.

For more information on how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page here.

If you wish to opt out of this program, please visit the Network Advertising Initiative (“NAI”) opt-out page located here.

You can opt out of targeted advertising using the links below:

  1. Facebook
  2. Google
  3. Bing

In addition, you may opt out of some of these services by going to the Digital Advertising Alliance opt-out portal here.

“No Tracking” signals

Please note that while you may be able to opt out of targeted advertising via the www.networkadvertising.orgchoices link above, you may be able to control the use of cookies through your browser as described in subsection “Cookies” above, some web browsers may allow you to enable a “do not track” setting that sends a special signal to websites you encounter while browsing the web. This is different from disabling some forms of tracking by rejecting cookies in your browser settings, as browsers with the “do not track” setting enabled are still able to accept cookies.

The Sites does not respond to the “do not track signals” web browser at this time. If we do so in the future, we will describe how we do so in this Privacy Policy.

11. Choices and Changes

Access, update, correct and delete your information

You can access your personal data that you have voluntarily provided through your account on the Services, review and correct or delete it, restrict or object to its processing, and receive your personal data in a structured , commonly used, machine-readable format, or transmit them to another controller by sending a request to info@saphirelabs.com. You can request to change your communication options, opt out of sharing with others, and update your personal information and your preferences.

Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may update this privacy policy from time to time to reflect, for example, changes in our practices or for other operational, legal or regulatory reasons, and we will post any changes on the Services as they become effective. We encourage you to periodically check this page for the latest information about our privacy practices.

You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed.

Any changes to this Privacy Policy will be effective upon the posting of the new terms and/or the implementation of the changes on the Sites (or as otherwise indicated at the time of posting). In any case, your continued use of our Sites or Services after any amended Privacy Policy is posted will indicate your acceptance of the terms of the amended Privacy Policy.

12. Applicable Law

Applicable law is Greek, as formulated in accordance with the General Regulation for the Protection of Personal Data (EU) 2016/679 (GDPR) and in general the current national and European legislative and regulatory framework for the protection of personal data.

13. Contact us

If you have any questions or comments about this Privacy Policy, or if you wish to update the information we have about you, please contact us by email at info@saphirelabs.com.