COMPANY’S PRIVACY STATEMENT - COMPLIANCE WITH GDPR REGULATION
 
1.Introduction

For our Company the privacy and security of our Website Users and Visitors, as well as our End Customers and External Partners is of the utmost importance. Our Company is committed to protecting the personal data you share with us. This privacy policy includes the ways in which our Company processes information that may be used to directly or indirectly identify an individual ("Personal Data") collected due to the use of its website and other means of our Company.
Our website is in compliance with the General Regulation 2016/679 of the European Parliament and the Council of April 27, 2016 regarding the protection of natural persons against the processing of personal data and the free movement of such data ("GDPR Regulation "), which is a directly binding legislative act. The GDPR Regulation creates some new rights for natural persons and strengthens some of the rights that already existed under Directive 95/46/EC. Directive 95/46/EC was repealed on May 25, 2018, when the GDPR Regulation came into force.
The terms of this policy refer to:

1. SUBSCRIBERS – CUSTOMERS. Users who have purchased at least one product or service from our Company are defined as subscribers-customers. In this case the data processing is necessary for the observance of the contract with the contracting party.
2. VISITORS – USERS. Visitors or users are defined as visitors who make use of our website and/or some of the possible free features such as newsletter registration etc.

Any processing of personal data carried out by our Company is treated in such way as to ensure its confidentiality. All information is stored securely and access to it is allowed only to authorized personnel. Our Company implements and develops the necessary technical and organizational measures to protect the Personal Data of Users/Visitors, End Customers  as well as External Partners (all of them deemed as "Subjects" of personal data) from unauthorized or illegal processing and use as well as against possible loss, destruction, damage, theft or illegal access.
 
2. Collection and Use of Personal Data

2.1 The legal ground for the use of your personal data

Our Company collects the personal data deemed necessary in order to satisfy our contractual obligations as derived from the current legal framework and relevant binding decisions of competent authorities. Whenever additional, optional information is sought, you will be informed of this at the time of data collection and your prior consent to processing may be required.
We apply the current legal framework and process personal data only if we have a legal ground for it. Personal data is processed on one or more of the following grounds:
 

• Consent: You may occasionally be asked for your consent in order for us to process some of your personal data. The processing of your data will be carried out in this way only if you expressly agree to such processing (Article 6, Paragraph 1a of the GDPR Regulation).
• Execution of a contract: In these cases, the processing of your personal data is necessary for the fulfillment of our Company's obligations, as derived from the contract concluded between us (Article 6 paragraph 1b of the GDPR Regulation) or your relevant written assignment to our Company .
• Legal obligation: This happens in cases where we are required to process your personal data in order to comply with a legal obligation, such as: a) to keep records for tax purposes, b) to provide information to a public body, which has the relevant authorization by the Law (e.g. tax authorities and insurance bodies), c) to comply with the requirements of a legislative or regulatory provision or a judgment (Article 6 paragraph 1c of the GDPR Regulation).
• Protection of your vital interests: In this case the processing of your personal data is necessary to protect your vital interests (Article 6 paragraph 1d of the GDPR Regulation).
• Fulfillment of a task performed in favor of the public interest or in the exercise of public authority: This occurs in cases where the processing of your personal data is deemed necessary for the fulfillment of a task performed in favor of the public interest (Article 6 paragraph 1e of the GDPR Regulation).
• Legitimate interest: Your personal data may be processed when this processing is a legitimate interest of our Company in the execution of the legitimate professional activity, in order to ensure the continuity of this activity. This processing, in any case, cannot and will not exceed your interests, freedoms and fundamental rights (Article 6 paragraph 1f of the GDPR Regulation).

Our Company collects personal data of special categories, as defined in article 9 of the GDPR Regulation, when the natural persons themselves, without our own demand, provide us with this data or when the data is required or their collection is permitted by Law.

The concept of personal data of "special category" includes personal data relating to a person's race, nationality, political beliefs, trade union membership, religious beliefs, philosophical beliefs, physical or mental health, sex life and orientation, data on criminal convictions and criminal acts. Our Company rarely processes this type of data and only if it is absolutely necessary in the context of the above grounds.

2.2 Ways of collecting your Personal Data.

Regarding the collection of your personal data, the Company collects your personal data when:

• You purchase or lease (online, via phone or in person) products or services from us.
• You register to purchase or lease a product or provide a service.
• You subscribe to services in order to receive digital newsletters.
• You request information about a product or service, or contact us with questions or complaints.
• You participate in any surveys or contests or webinars.
• You visit or navigate the Company's website and in general make use of the company's electronic and/or digital products and services, e.g. cookie identifiers, Internet Protocol addresses (IP addresses) or other identifiers, in accordance with the specific terms of use of the company's applications.
• You contact our Company via company's applications support methods (e.g. via telephone, in person, via electronic applications), in accordance with the legal conditions.
• You visit the Company's premises and store(s), in which case we may collect CCTV data for security and crime prevention purposes.

In any case required by the applicable legal framework, you will be asked for your expressed consent for the processing of your personal data, as collected by our Company.
Your consent is completely optional but in some cases it may not be possible to provide the services or supply the products without the required processing.

2.3 Which personal data we collect.

The information we collect about you depends on the Company's products and services you subscribe to or you make use as well as your communication with the Company in general. The information we collect about you includes, but is not limited to, the following:
 

• Name, address, Tax Identification Number, telephone number, date of birth, occupation and e-mail address. We collect this data directly from you and/or from publicly accessible sources.
• Your preferences for specific products, services or activities, provided you disclose them to us or we infer them from the use of our products and services and your navigation on our Company's website and the general use of its electronic and/or digital products and services of the company, e.g. cookie identifiers, Internet Protocol addresses (IP addresses) or other identifiers, in accordance with the specific terms of use of the company's applications.
• Information and personal data that may be disclosed by you in the context of communication between us, such as for example from the registration or recording of a call you make to our call center, whenever this is prescribed by law, an e-mail, a letter or any other form of communication you attempt.
• Information related to your account, such as payment dates, transaction behavior, subscription to services in use or any other information associated with an account.

It is clarified that the above collection of data also includes the collection of data by a third party acting on your behalf (natural or legal person).

2.4 Use of your personal data

In the Company we process your data for different purposes, such as:
 

• Processing the products and services you purchase or lease from us and keeping you informed about the progress of your order.
• Informing you generally about new products and services (unless you have opted out of receiving promotional messages).
• Providing you with products and services tailored to you. This processing refers to services, which are not part of the contract between us, services that use information regarding your location while using mobile devices (location data) as well as communication with messages about changes in products or services.
• Contacting you with offers or promotions based on the use made for our products and services. Use includes calls and texts, location data and navigation information (note that you will not receive such messages if you choose not to).
• Billing you for the use of our products and services or completing payment of your bills.
• Responding to your questions or concerns regarding the use of our products or services.
• Informing you about the products and services of other companies that we think will be of interest to you (including discounts and offers that we have secured for our customers).
• Understanding how you use our products and services. In this way, we can develop more interesting products and services, tailored to your needs as well as personalize the products and services we provide to you.
• Preventing and managing fraud or other crimes, collecting debts and claims from our debtors.
• Providing aggregated reports to third parties (such as reports that do not include personal identifiable information).
• Providing information to the competent authorities to deal with emergency situations.

Our Company collects aggregated data related to traffic on its website, including the number of Visitors and the number of visits, geographic location data, time spent on the website, and the number of clicks on its links.
Additionally, our Company may process personal data using advanced technologies to safeguard our legitimate interests (e.g. digital signature).

Finally, our Company, for all the above categories, can process personal data when this processing is necessary for the purposes of the legal objectives it pursues, unless interests or the fundamental rights and freedoms of the subjects prevail over these interests while applying protection of personal data.

2.5 The use of the website – The acceptance of the terms on your behalf.

By visiting our Company’s website, you consent to the collection, use and processing of your Personal Data, as described in this Policy.
If you do not agree to the terms set forth herein, please do not continue browsing our website.
Our Company may collect record and process the data of its website visitors. We may record your IP address and use cookies as described below.
Our Company may add information collected through the page view activity. In addition, our Company may collect and process any Personal Data that you voluntarily provide to us on our website forms, such as when you sign up for information and newsletters.

2.6 Cookies

Cookies are small text files that are stored in the browser while you browse the internet. Their purpose is to notify the website that the user is visiting of his/her previous activity. Cookies are not used to run programs or install viruses on your computer.
With your explicit acceptance, you agree to the use of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience while browsing our website will be satisfactory.
We may also use third-party cookies for operational and marketing purposes. The use of cookies is widespread and benefits the Visitor.

2.7 IP Addresses

The IP address (IP address - Internet Protocol address) is a unique number used by devices to identify and communicate with each other in a computer network that uses the Internet Protocol Standard. An IP address is, in other words, a number assigned to your computer every time you access the internet. It allows computers and network service computers (servers) to identify and communicate with each other. The IP addresses from which visitors appear to originate may be registered for information technology security and systems diagnostic purposes. This data may also be used in aggregated form in order to perform an analysis of trends and performance for the Company’s website.

2.8 Links to other sites (links)

Our Company may not be held liable for the content or privacy policy of these websites.

3. RETENTION AND DELETION

Our Company will not retain data for a longer period of time than is necessary to fulfill the purposes for which they were collected or as required by the applicable legal framework. Users' data will be kept for at least 5 years after the termination of the legal relationship between our Company and the Customers (execution of the contract), since, among other things, the purpose of collecting them, according to the above-mentioned, is also the promotion of new products and services of our Company. In some cases, certain personal information may be retained beyond this period of time, due to possible legal obligations, legitimate interests of our Company, etc. Such cases are, indicatively, those related to each legal sector (tax, civil, criminal, etc.).

4. ACCEPTANCE OF THESE TERMS

We assume that all Visitors to our website have carefully read this Privacy and Personal Data Protection Policy and agree with its content. If anyone does not agree with it, they shall not use the website and the contact platform with us. Our Company reserves the right to modify the Privacy and Personal Data Protection Policy according to its needs. In any case, we are available for any further clarification.
 
5. SUBJECTS' RIGHTS

The new GDPR Regulation provides you with the following rights regarding the processing of your personal data:
 

• Right to Access: You may request access to your personal data. Thus you are provided with the option to receive a copy/s of your personal data maintained by our Company.
• Right to Correction: You can request correction of your personal data. In this way you are given the option to verify the accuracy of the new data you will provide us.
• Right to Deletion: You can request the deletion of your personal data. This enables you to request that we delete or remove personal data where there is no reason for us to continue processing it. Please note, however, that this right of yours may in certain cases not be granted for specific legal grounds that will be communicated to you, on a case-by-case basis, at the time of submitting your request.
• Right to Restriction of Processing: You can request restriction of the processing of your personal data. In particular, you may request us to stop processing your personal data in the following cases:

1. If you want us to update the accuracy of your personal data,
2. when you consider that the use of your data is abusive however you do not want us to delete your data,
3. when we need to retain your data, even if we no longer require it from you, in order for you to be able to use it in the event that you exercise your rights.

• Right to Object: You can object to the processing of your personal data at any time. However, our Company may not be able to satisfy your right, as long as there are compelling and legitimate grounds for processing that override your interests, rights and freedoms or  establish, exercise or support legal claims, as indicatively, in the cases that the processing of your data is based on the fulfillment of a duty performed in favor of the public interest or by exercising public power (case e of paragraph 1 of article 6 of the Regulation), or if the processing fulfills the purposes of the legitimate interests of our Company or third party (case f of paragraph 1 of article 6 of the Regulation).
• Right to Portability: You can request the transfer of your personal data to you or to a third party. We will provide you or your indicated third party with your personal data in a commonly used, machine-readable format. Please note that this right of yours only applies to automated information that you initially disclosed to us with your consent to use it or we used that information to execute a contract with you.
• Right to withdraw Consent: You may withdraw your consent at any time, in cases where you have already provided your consent to the processing of your personal data. However, this will not affect the lawfulness of any processing that took place prior to the withdrawal of your consent. If you withdraw your consent, our Company may not be able to offer you some of its products or services. You will be informed about this at the time of submitting your request.
• Non- automatic decision-making: Automatic decision-making occurs when an electronic system uses personal data to make a decision without human intervention. In this case you have the right not to be subject to decisions made solely through automated processing including profiling, which produces legal effects for you or which significantly affect you in a similar way, unless you provide us with your consent, or it is necessary for the conclusion or execution of a contract between you or as otherwise prescribed by law. You also have the right to challenge decisions made for you by the above process.

Furthermore, we inform you that you have the right to submit a Complaint to the competent Personal Data Protection Authority in case you consider that your rights have been violated by the processing of your personal data by our Company.
 
6. LEGAL OBLIGATION FOR DISCLOSURE OF PERSONAL DATA

We may disclose the User's personal data, without their prior consent, only when we have reason to believe that the disclosure of such data is necessary  for the verification of identity, communication or the initiation of legal proceedings against a person or persons suspected of acts infringing or jeopardizing the property rights of the Company or other persons who could be harmed by the activities of these Users or regarding persons who could (intentionally or otherwise illegally) commit similar ILLEGAL acts. It is clarified that the disclosure will be made in accordance with the criteria and conditions prescribed by law.
 
7. OUR COMPANY'S PERSONAL DATA PROTECTION

The processing of personal data is carried out in a way that ensures its privacy. In particular, it is carried out exclusively and only by authorized staff for this purpose, while all appropriate organizational and technical measures are taken for the security of the data and their protection against accidental or unlawful destruction, accidental loss, alteration, prohibited dissemination or access and any other form of unfair processing. Particularly:

• Confidentiality

 

•  Integrity

 

• Transparency

 

• Personal data breach notification

NOTE: Internet communication (such as e-mails) is not secure without encryption application. Your communications may involve the transfer of data through various countries due to the nature of the internet. The Company assumes no responsibility for any unauthorized access or loss of personal data that is not under its direct control.

8. RECIPIENTS

The personal data we collect may be transmitted to third parties, provided that the eligibility of the transmission is justified.
Furthermore, as long as the eligibility of the transfer is justified, your personal data may be shared with the following categories of recipients:

 We may share data related to you with:
 

• Partners and associates, who participate in the process of providing the products and services you have ordered or in use.
• Companies that have undertaken to provide services in the name or on behalf of the Company.
• Law firms/lawyers or debt management companies or organizations with relevant activity.
• Police and supervisory authorities, administrative bodies, judicial or other public authorities to whom we are either required to provide information or are authorized by law to request it.
• Additionally:
• We will disclose data as necessary for protection against fraud in order to protect our customers and defend our rights and property.
• In the event that our Company is merged with or sold to another organization, we may transfer the personal data we hold about you to the new organization.
• We may transfer your data to companies or service providers in countries outside the EEA (European Economic Area) under the conditions of applicable legislation. This will happen if our partners or suppliers are located outside the EEA or if you use products and services while visiting one of these countries.

9. MODIFICATIONS TO THE PRIVACY POLICY

We strive to constantly review and update this Privacy and Personal Data Protection Policy in order to comply with legislative and regulatory requirements while providing the best possible protection for your personal data. Any update will be communicated to you via the current website.

10. PERSONAL DATA PROTECTION OFFICER

Our Company has a "Personal Data Protection Officer", who is responsible for matters related to the protection of the privacy of individuals as well as the safe and correct processing of Personal Data. The competent protection officer is the legal representative of our company (Stavros Papastavrou).
If you wish to receive more information or clarifications regarding the data we collect and process, please contact us by the telephone number: +30 2109249350 and by the email address [email protected].