Last updated: 8 May 2025

1. Data Controller

Niki Smirni, Athens (GR), email: info@nikismirni.com. nikismirni.com

2. Personal Data We Collect

Context	Data	Legal Basis (GDPR)
Newsletter sign-up	name, email	Consent Art. 6 (1)(a)
Contact form	name, email, message	Legitimate interest Art. 6 (1)(f)
Retreat enquiries (redirect to Travelgems)	name, email, booking details	Contract performance Art. 6 (1)(b)
Site analytics	IP (pseudonymised), device data	Consent / Legitimate interest
Social embeds	account IDs, interaction data	Consent

3. Purpose of Processing

• Provide and improve the Site
• Respond to enquiries and send newsletters
• Market retreats, events and THE METHOD book
• Comply with legal obligations

4. Retention

We store contact records for up to 24 months after last interaction, unless longer retention is required by law (e.g., invoicing).

5. Data Sharing & Transfers

Email marketing is handled by Mailchimp (USA – covered by EU-US Data Privacy Framework).
Analytics may be processed by Google LLC (USA). Standard contractual clauses are in place for any transfers outside the EEA.

6. Your Rights

You may: access, correct, erase, restrict or object to processing, and request data portability. Withdraw consent at any time without affecting prior lawfulness. Lodge a complaint with the Hellenic Data Protection Authority.

7. Security

We use HTTPS, server firewalls and least-privilege access to protect your data. No online method is 100 % secure, but we strive for industry-standard safeguards.

8. Automated Decision-Making

We do not use automated profiling that produces legal or similarly significant effects.

9. Children

Our services are not directed to children under 16. We do not knowingly collect data from minors.

10. Changes

Updates will appear here; significant changes will be emailed to subscribers.