Last Update: 30 May 2018
2. Applicable Law.
The applicable data protection law (hereinafter the “Applicable Data Protection Law“) consists of the applicable national and European legislation on the collection, use and disclosure of your personal data by us, including Regulation (EC) 2016/679 of the European Parliament and the Council, adopted on 27 April 2016 and put into effect on 25 May 2018 (hereafter referred to as the “Regulation“).
3. Definition of Personal Data.
5. Special notice for minors.
Minors under the age of 16 and partially disqualified persons, according to the applicable in their case jurisdiction, are prohibited from communicating to Us through the Website, by telephone, or in any other way, their Personal Data without the prior consent of the person or persons who exercise the parental custody. We ask those persons not to submit information to Us. In the event that users of the Website are under the age of sixteen (16) years and continue to disclose their Personal Data via the Website, it shall be deemed by Us that such persons have obtained the prior consent of the person or persons who exercise the parental custody.
6. You disclose to Us Personal Data in the following occasions
- When you use our Services: In order to provide our Services and conclude a binding agreement with you, you will be asked for certain personal information, such as your full name and full details, your home and work address, your e-mail address, as well as certain Special Category Data, whose disclosure is necessary for the performance of the contract between us. For the disclosure of these Personal Data, and the maintenance and processing thereof, you provide us with your express consent, in accordance with the specific terms of the agreement we sign with you.
- For sending newsletters, activities, actions and promotions when you subscribe to our newsletter: If the Company decides to send you a newsletter, it will request your prior explicit and free consent for this purpose.
- If you wish to create a personal account by registering on the Website: If the Company provides its customers in the future with the ability to create a personal account through the Website, and provided that we obtain your prior consent, you will be asked for some personal information, such as your name and surname, your e-mail address, your date of birth, and possibly other data that can be used for your personal identification.
- If you contact (in writing or orally) the Company’s Customer Service Department: We may store/register your correspondence, as well as any information requested and are deemed necessary for your best service and/or proof of our contractual relationship.
7. Information we collect automatically when you visit the Website or make use of the Services
Website: We may collect information from the Website and how you use it. When you visit the Website, your web browser sends data to our servers. With this information we can optimize our Services, personalizing and improving your experience when using the Website. This information may include the following:
- your IP address
- the date and time of your visit to the Website
- the referring URL (ie the website the user came from)
- the pages you have visited on our website
8.Information regarding the Personal Data collected by other websites – Advertising through third parties.
9. Use of your Personal Data
We use your Personal Data for the following purposes outlined in brief:
- Services provided by the Company: In order to provide you with the agreed services, in accordance with the contract we have entered into with you.
- Marketing/promotion: To send you e-mails with news and updates regarding our Website and Services, to provide you with and send you information that addresses your interests by obtaining your prior consent to use your Personal Data for such purposes.
- Use of the Website: To update and adjust the content of the Website, and to analyze the use of the Website.
- Other services offered by the Company: Also, we may use your Personal Data in order to give you information for products and services provided by third parties after having received your prior explicit and free consent.
- Other purposes: To the extent required by law, we will ask for your consent when we want to use your information for purposes other than those listed above.
- To comply with any legal obligation: When required by any court or authority and always in accordance with the Applicable Data Protection Law.
Providing to Us your Personal Data is voluntary. Nevertheless, in certain occasions, if you do not grant to Us access to your Personal Data, you will not be able to access all or certain of our Services.
10. Disclosing your Personal Data.
We do not sell your Personal Data to third parties, neither we grant licenses to them for using same for their own benefit. However, in the course of our business activities we may share certain of your Personal Data with:
- a limited number of our staff and employees to the extent necessary to provide you with the Services,
- or in any case as permitted or required by the Applicable Data Protection Law.
10.1 Service Providers.
10.2 Disclosure according to the law.
We may disclose your Personal Data as permitted or required by law. For example, we may be obliged to reveal and disclose your Personal Data following the implementation of a court decision, a prosecutor’s order or according to the decision of a person or administrative body with jurisdiction of the law to compel the disclosure of such information. In case that we reasonably believe that your Personal Data could be useful for the investigation of improper or illegal activity, we may disclose such information to the competent state authorities or other investigating agencies and only to the extent required.
11. Right to be informed, right to access, to object and to erasure.
11.1 With respect to your Personal Data, you retain, amongst others, the rights to be informed, to access, to object and to erasure (“right to be forgotten”) as specifically defined in articles 13-22 of the Regulation. In this context, you may have access at any time to your Personal Data that we maintain in databases in order to modify, correct or update this data, even to object – at any time and for any reason – to the processing of Personal Data relating to you, as well as to revoke your consent with regard to such processing or to request their permanent deletion from the Company’s records (where possible). To do this, please follow the steps described each time in the message you receive via the relevant means of communication (such as e-mail).
11.2 If you have given us your consent to send newsletters and to use your Personal Data for marketing, product and/or service purposes and you wish to withdraw your consent, then you can use the unsubscribe link ( 'unsubscribe') as indicated in the messages you have received. Alternatively, you can contact our Customer Service department via e-mail email@example.com or by phone at +30 2106810300. Please note that we may need to ask you to verify your identity before proceeding with your request.
11.3 Also, you can at any time request that your Personal Data that we keep in our files be permanently deleted, after contacting our Customer Service department via e-mail firstname.lastname@example.org or by phone at 210-6810300. We, for our part, will respond within thirty (30) business days of receiving your request. In the event that we do not respond or our response is not considered satisfactory by you, you have the right to appeal to the Personal Data Protection Authority and request a review of our response or failure to act.
In the event of a deletion request from you:
a) We will stop using and making available your Personal Data (unless otherwise provided or required by law).
b) We will delete all your Personal Data from our databases, except for that contained in electronic messages, correspondence or other documents that we may retain in order to be able to prove the terms of our contractual relationship with you or as otherwise provided by the current legislation.
c) Taking into account available technology and implementation costs, we will take reasonable technical and organizational measures to inform other processors who process your Personal Data on our behalf as specifically mentioned above, that you have requested deletion from them (the processors processing) of any links to that data or copies or reproductions of your Personal Data in question.
Please note that it is not possible to delete your Personal Data, which we must retain or continue to process for the performance of the contract concluded between us and for as long as this contract is in force or is required for our compliance with the requirements of the applicable legislation.
Please also note that we may need to ask you to verify your identity before proceeding with your above request.
12. Summary of your rights under Applicable Privacy Law.
As part of respecting your privacy/personal life, we endeavor to ensure that your Personal Data is held in accordance with the Applicable Personal Data Protection Law, as well as in accordance with any other applicable relevant legislation. In this context we guarantee that your Personal Data will:
(a) They are processed fairly and lawfully. In particular, we will demonstrate transparency regarding the processing of your Personal Data.
(b) They are collected only for clear and legitimate purposes and are not further processed in a manner incompatible with these purposes. In the event that we decide to further process your Personal Data, then your express consent is necessary.
(c) They are relevant, appropriate, and no more than is required in view of the purposes of the processing. We will collect and retain your Personal Data as long as this is necessary to fulfill operational and administrative requirements or to comply with any legal obligation.
(d) It is accurate and, if necessary, updated/corrected at your request.
(e) They will be kept in a form that allows you to be identified and for no longer than is necessary for the purposes for which they were collected or for the purposes subsequently processed.
(f) Processed in accordance with the rights of the subject of Personal Data as such rights are established by the Applicable Law on the Protection of Personal Data (right to be informed of the processing undertaken, right of access to Personal Data, right to object/restrict use /processing of Personal Data, right to temporary judicial protection, right to submit a complaint to a supervisory authority, right to portability and restriction of processing, right to information in case of automated decision-making/profiling of the user of the Services).
(g) Appropriate technical and administrative measures will be applied against the arbitrary or illegal processing of your Personal Data and against the accidental loss or destruction or damage thereof in the context of the Company's activity.
(h) Your Personal Data will not be transferred by Us to countries outside the European Union, unless you have given your consent and only if an equivalent level of protection of the rights and freedoms of Personal Data subjects has been established and implemented in relation to the management of the exported data.
(i) Right to data portability: In accordance with article 20 of the Regulation, as the subject of your Personal Data and since the processing is carried out by automated means, you retain the right to data portability and specifically the right to receive the Personal Data you concern and which you have provided to Us as the controller, in a structured, commonly used and machine-readable format, as well as the right to transfer said data to a new controller without our objection, in accordance with the specific provisions of article 20 of the Regulation. In such a case, we bear no responsibility for the processing of the data by the new controller to whom your Personal Data will be sent, nor for the quality of the data that will be transferred, beyond what we are obliged to do under the Regulation. As the controller we will need to verify your identity before proceeding with the above. The right to portability - if exercised - does not negate the other rights provided by the Regulation and the Applicable Personal Data Protection Law.
The website of the Personal Data Protection Authority offers information and assistance regarding the rights according to the Regulation and the relevant legislation (www.dpa.gr). In summary, your basic rights are the following:
- The right to be informed what information is held about you in electronic form and in paper records.
- The right of access and information regarding the purpose of the processing of Personal Data, for the recipients or for the categories of recipients.
- The right to be informed of possible changes that have taken place in the way of processing since our last notification to you.
- The right to be informed about the methodology applied in the automatic processing of Personal Data.
- The right to be informed about the security measures imposed by the Controller for the security of your Personal Data.
- The right to be informed about the relevant transfer of your Personal Data to third parties.
- The right to take measures to stop the processing of your Personal Data if the processing is likely to cause you to suffer significant damage or significant moral harm, when this is unjustified.
- The right to object to the processing of your Personal Data, as well as to demand that your Personal Data is not used to promote services.
- The right to prevent decisions made about you based solely on automatic processing (profiling).
- The right to request the rectification or destruction of Personal Data that is incorrect or that you no longer wish to be processed.
- The right to restrict the processing of your Personal Data, as well as the right to its portability (when the processing concerns identifiable personal data and is based on consent and contract performance).
- The right to be able to object at any time to the processing of your Personal Data, as well as the right to withdraw your consent to their processing at any time and to request their permanent deletion from the Company's databases.
- The right to lodge a complaint with a supervisory authority.
- The right to claim compensation if you have suffered damage and moral harm as a result of the violation of the provisions of the Regulation.
13. Duration and location of storage of your Personal Data.
We keep your information for as long as we need it and for the purpose for which we keep it, to respond to your needs or to comply with our legal or regulatory obligations, and to be able to manage our rights (for example, to assert our claims before the Courts) or for statistical or historical purposes.
When we no longer need to use your Personal Data, we delete it from our systems and files or anonymize it so that you can no longer be identified from it.
14. Dispute Resolution.
15.1 For your better service and convenience in using the Website we use "cookies", a technology that, using alphanumeric codes, installs a small amount of information on the computer of a Website user, so that it is possible for the Website to recognize the user's future visits using the same computer/device. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to offer personalized content of the Website and information about its use, and to facilitate your experience on it. You may choose to reject cookies on your first visit to the Website and later by selecting the corresponding link on the Website, however this may affect your use of the Website and your ability to access certain features and transactions. More information about deleting or controlling cookies is available at www.aboutcookies.org.
15.2 Types of cookies we use.
15.2.1. NECESSARY COOKIES They are technically necessary for the operation of the Website and therefore you cannot reject them. They help you navigate the Website and view certain features or use basic functions. These cookies are stored for the entire duration of your browsing session.
15.2.2. STATISTICS COOKIES Statistics Cookies are used directly by the Website administrator to collect information about user activities performed on the Website, they are collected anonymously and for statistical purposes only.
15.2.4. MARKETING COOKIES Marketing Cookies are used to track website visitors. The intent is to display ads that are relevant and engaging to users and therefore more valuable to third-party publishers and advertisers.
15.3. If you do not want cookies. Regarding non-necessary cookies, you have the option to change your browser settings to delete or prevent cookies from being stored on your computer or mobile device without your express consent. The "help" section of your browser will provide you with information on how to manage your cookie settings.
16. Tracking information.