PERSONAL DATA PROTECTION POLICY

The following privacy policy provides you with information about the processing of personal data by the company "Proto Thema S.A.", (hereinafter the "Company") and describes how the Company protects personal information and the procedure by which you as a natural person can exercise your rights. The Company processes your personal data always with respect to the fundamental rights of natural persons in accordance with the existing European and Greek legislation (including the General Regulation (EU) 2016/679, the Greek law 4264/2019 and any other relevant applicable legal text).

DATA CONTROLLER

The company with the name EKΔOSEIΣ ΠPOΣEIΣ ΠPOΣTO THEMA EKΔOYTIKI ANΔOYTIKI ANONYMEH EΠAίMIA, located in Maroussi, at 5, Agrafon and Patmos streets, is the controller of the processing of personal data. Contact details of a contact person for queries regarding personal data can be found at the end of this privacy policy.

PERSONAL DATA

Any information relating to an identified or identifiable natural person ("data subject") (e.g. name, surname, email address) .
Special categories of personal data are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic data, biometric data, data concerning an individual's health, sex life or sexual orientation.

PROCESSING OF PERSONAL DATA

Processing of personal data is any operation or set of operations which is performed, whether or not by automated means, on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

WHAT PERSONAL DATA DO WE PROCESS?

The personal data we process are those strictly necessary for the purpose we are pursuing. In particular, we may collect, by way of example and not limitation, the following:
Identity data: e.g. name, surname
Contact Data: e.g. telephone number, email address
Data which you further declare in the contact form
Data collected through the use of Cookies: e.g. IP address
Image data via the video surveillance system
Data relating to possible position coverage/recruitment: e.g. CV

WHAT ARE WE PROCESSING PERSONAL DATA FOR?

We process your personal data only for the purpose we are seeking. By way of example and not limitation, we use your personal information for:
-to contact you in order to answer any question you have asked us or to fulfil any request you have made.
-to send you updated content via "push notification" notifications
-manage our website and app and enable us to provide you with our services to the best extent possible
-ensure the protection of persons and property through our video surveillance system

APP APPLICATION

When downloading our app on your mobile device we collect the following data: unique identifier, MAC address - other device identifier, location.

POST COMMENTS ON ARTICLES

When you provide personal comments on articles published on our website, the information, the comments you post and your personal information are publicly accessible and may be processed by third parties of which we are not aware. For this reason, we urge you to be careful in your comments and postings, as we cannot guarantee the privacy of your personal information.

WHAT IS THE LEGAL BASIS FOR US TO PROCESS YOUR PERSONAL DATA?

We only process your personal data if there is a legal basis for doing so, such as:
Consent: where required, we may process your personal data if you have given us your consent for the purpose in question. You can withdraw your consent at any time.

Legitimate interest of the Company.

Performance of a contract: we may process your personal data in order to fulfil contractual obligations.
Legal obligation: in some cases we need to process your personal data to comply with a legal obligation.
Vital interests: the processing of personal data is necessary to protect the vital interests of the data subject or another natural person.
Public interest: processing is necessary for the performance of a task carried out in the public interest.

WHO IS THE RECIPIENT OF YOUR DATA?

Your personal data are processed internally in the Company by the staff absolutely necessary for this purpose, who observe a confidentiality condition.
If we use a third-party supplier or commercial partner who will process personal data on our behalf and in accordance with our instructions, we will have ensured that the third party carrying out the processing for us will have the appropriate security and privacy measures in place as required by law and will only process the personal data for the purpose of carrying out their contractual obligations to us and always in accordance with the instructions we have given them and for no other reason.

In some cases your personal data may be transferred to the competent police or judicial authorities for the defence of our legitimate claims and only in cases where required by the applicable legislation.

PERSONAL DATA SECURITY

We take care to take all necessary technical and organizational measures and procedures to prevent unauthorized access and misuse of information and personal data. The measures we take include preventive security procedures, technical and physical mechanisms for restricting access, and controls for granting access rights to authorized personnel.

IS YOUR DATA SENT TO COUNTRIES OUTSIDE THE EU?

Your personal data is not being sent to countries outside the EU/EEA to our knowledge. If your data is sent to such countries, we will take all necessary measures to ensure an adequate level of protection of personal data in accordance with applicable law. In the event that we are informed and/or suspect that data is being sent or processed outside the EU/EEA by one of our partners or a third party and in the context of ensuring the lawful processing of your personal data, we will make every effort to investigate the matter quickly and act accordingly as soon as possible. At the same time, where appropriate and as part of the proper exercise of your rights, we will ensure that we inform you of the above actions by any means the Company deems appropriate.

FOR HOW LONG ARE YOUR DATA STORED?

We process your personal data only for as long as necessary to fulfil the relevant purpose, unless there is a legal provision for further retention or we need it to meet and fulfil our legal claims.

MEANS OF SOCIAL NETWORKING

Our Company has its own social media pages (Facebook, Instagram, Twitter). We remind you that these pages are publicly accessible and any content, comments, personal information you provide will be visible to the general public and for this reason we recommend you to be careful with the content of the information you provide.

Information about the processing of personal data by the relevant social media can be found in their privacy terms.

COOKIES

Cookies are small text files that are stored on your computer or mobile device when you visit a website.

The cookie policy provides further details on the use of cookies and ways in which you can delete or prevent specific cookies from being stored on your computer or mobile device.

WHAT ARE YOUR RIGHTS AS DATA SUBJECTS?

As a data subject, you have the following rights:
Right of access.
Right of rectification.
Right to erasure: You can ask us to delete your data if there is no reason to justify our failure to do so.
Right of portability: You can ask us to receive in a readable format the data you have provided to us or request that we transfer it to another controller.
Right to restriction: You can ask us to restrict the processing of your personal data for as long as any objections to the processing are pending.
Right to object.

HOW CAN YOU EXERCISE THE OTHER RIGHTS?

You may exercise your rights at any time through the Data Subject Rights Request [Request Form] and the Company will respond to you within thirty (30) days from the date of receipt and confirmation of your identity, unless the request is unusually long and complex, in which case, upon notification, the response may be delayed for another sixty (60) days.

In principle, the satisfaction of a request is free of charge. However, where a request is manifestly unfounded or excessive, a reasonable fee may be imposed.
In any case, if we do not respond to your request, you have the right to complain to the Personal Data Protection Authority (PPA) : 1-3 Kifissias Street, Athens / www.dpa.gr, tel. 2106475600.

CONTACT THE COMPANY

Individuals may contact the Company for any information or clarification regarding the processing of their personal data by the Company either by post to: To the attention of the Data Protection Officer, Proto Thema, 5 Agrafon and Patmos, P.O. Box 15123, Maroussi, Attica, or electronically at: dpo@protothema.gr.

AMENDMENTS TO THIS POLICY

From time to time it is necessary to adapt the content of this information on data protection. Therefore, we reserve the right to change it at any time for the future. We will also publish the modified version here. If you visit us again, you should therefore read the data protection information again.

COMMUNICATION AND DISCLOSURE OF PERSONAL DATA

The website undertakes not to sell, rent or in any way publish and/or disclose the personal data of website users to any third party.

PUBLICATION DATE: 24/09/2020