Privacy Policy

Last update: May 31, 2019

Constantinos Koulakmanidis respects and is committed to protecting your personal information. His privacy policy reflects current global principles and standards on handling personal information – notice and choice of data use, data access and integrity, security, onward transfer and enforcement/oversight.

As part of his privacy and cookies policy he will obtain personal data about you such as your name and address whenever you complete an online form. For example, he will obtain your personal data when you contact him for any reason. He may also obtain sensitive personal data about you if you volunteer it during the completion of an online form. If you volunteer such information, you will be consenting to his processing it for the purpose of dealing with your request.

He may monitor your usage of this website. This may include monitoring how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. This information helps him to build a profile of his users. Some of this data will be aggregated or statistical, which means that he will not be able to identify you individually. Please see further the section on ‘Use of cookies’ below.

How he may use your personal data

He will use your personal data for the purposes described in the data protection notice that was given to you at the time your data were obtained. These purposes include:

  • to help him identify you and any accounts you hold with him

  • administration

  • statistical analysis

  • customer profiling and analysing your purchasing preferences

  • marketing – see ‘Marketing and opting out’ below

  • fraud prevention and detection

  • customizing this website and its content to your particular preferences

  • improving his services

Marketing and opting out

Unless you have asked him not to do so, he may contact you by mail, telephone, SMS, text/picture/video message, fax, email) about any of his services which may be of interest to you. If you prefer not to receive any further marketing communications from him, you can opt out at any time. See further ‘Your rights’ below.

Sharing your data with Third Parties

He will never sell your Personal Data to any third party. He don’t trade, share or transfer your personal data to third parties except in the following limited circumstances:

  • He may share your personal data with our parent companies, subsidiaries, and affiliates;

  • He may share your personal data with third-party service providers to permit such parties to provide services that helps him with his business activities, which may include assisting him with marketing, customer support, data analytics, advertising his product/service offerings, or providing, maintaining and improving the features and functionality of the Offerings, among other things. For example, he may provide personal data to his service providers for direct emailing of his newsletters or notifications of his product/service offerings;

  • He may share your personal data when he have a good faith belief that access, use, preservation or disclosure of such data is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to his rights, property or safety, or that of his users or the public as required or permitted by law;

  • He may share your personal data with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;

  • He may share your personal data with his business partners who offer a service to you jointly with him, for example when running a cross-promotion;

  • He may share and/or transfer your personal data if he become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of his assets; and

  • He may share your personal data with a third party if he have your consent to do so.

  • He may also share aggregated or anonymized data with third parties for other purposes. Such data does not identify you individually but may include usage, viewing and technical data such as the types of Offerings his customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which he collected through his technology. If he are required under applicable law to treat such data as personal data, then he will only disclose it as described above. Otherwise, he may disclose such data for any reason.

Keeping your data secure

He is committed to protecting your personal information against unauthorized use or disclosure.

He implement a variety of security measures to maintain the safety of your personal information when you access your personal information. he does not sell, trade or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist him in operating his Website, conducting his business, or servicing you, so long as those parties agree to keep this information confidential. He may also release your information when he believe release is appropriate to comply with the law, regulation or legal request; enforce his site policies or protect his or others rights, property or safety or to detect, prevent, or otherwise address fraud, security or technical issues. However non-personally identifiable visitor information may be provided to other parties for marketing or other uses. He may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy.

Whilst Constantinos Koulakmanidis will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason he cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.

Information about other individuals

If you give him information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

  • give consent on his/her behalf to the processing of his or her personal data

  • receive on his/her behalf any data protection notices

Your Controls and Choices

He may provide you with the opportunity to “opt-out” of having your personal data used for certain purposes when he ask for this data. If you decide to opt-out, he may not be able to provide certain features of the Website to you.

Communication Preferences
If you no longer wish to receive his newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Website. Please note, however, that customers cannot opt out of receiving transactional emails related to their account with him.

Blocking Cookies
You can remove or block certain cookies using the settings in your browser but the Offerings may cease to function properly if you do so. For more information, please see Constantinos koulakmanidis’ Cookie Policy. Please note, however, that you may be unable to block certain service-related cookies.

How He Responds to Do Not Track Signals
Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Website does not respond to this type of signal.

Accessing and Updating Your Personal Data

When you use the Offerings, he make good faith efforts to provide you with access to your personal data upon your request and either provide you the means to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your data at any time. To do so, please contact him at with your name and the data requested to be accessed, corrected or removed. He may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning data residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where he provides data access and correction, he performs this service free of charge, except if doing so would require a disproportionate effort.

He may retain your data as necessary to operation function of his Website, comply with his legal obligations or resolve disputes.

Your Rights under General Data Protection Regulation (GDPR)

  • Withdraw your consent at any time. You have the right to withdraw consent where you have previously given it to the processing of your Personal Data.

  • Object to the processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent.

  • Access your Data. You have the right to learn if data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.

  • Verify and seek rectification. You have the right to verify the accuracy of your data and ask for it to be updated or corrected.

  • Restrict the processing of your data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, Constantinos Koulakmanidis will not process your data for any purpose other than storing it.

  • Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your data from GrowthRocks.

  • Receive your data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

  • Lodge a complaint. You have the right to bring a claim before a data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Constantinos K or for the purposes of the legitimate interests pursued by Constantinos K, you may object to such processing by providing a ground related to your particular situation to justify the objection.

You must know that, however, should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether Constantinos Koulakmanidis is processing Personal Data for direct marketing purposes, you may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise your rights can be directed to Constantinos Koulakmanidis through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Constantinos Koulakmanidis as early as possible and always within one month.

International Transfer of Data

He may from time to time transfer your personal data to other countries outside the EU and make it accessible to his partners, subsidiaries, affiliates, and third party service providers internationally. He will protect your personal data in accordance with this Privacy Policy wherever it is processed.

Changes to this Privacy Policy

He may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. If He makes any material changes he will notify you by posting the revised Privacy Policy on his Websites. Your continued use of his Websites, and/or continued provision of Personal Data to him will be subject to the terms of the then-current Privacy Policy.

Contact Him

If you have questions or need to contact him about this Privacy Policy, please email him at