Privacy Policy of CPC/CPS Mixed Billing Model

Table of Contents

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 — and if a relevant purchase is actually made — 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.

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 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 — based on applicable law — 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 and the cookie policy of Skroutz.gr.

Regarding the lawfulness of processing concerning the use of Skroutz Analytics, please see more in our Skroutz Analytics Privacy Policy.

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 as well as the Skroutz.gr's Cookies Policy, 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 as well as the cookie policy 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

More information about Cloudflare's privacy policy can be found here and in particular about the Bot Management service we use here.

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, 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

* 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.

Skroutz Privacy Policy

More about general Privacy Policy can be found here and Cookies Policy here.