GDPR

PERSONAL DATA PROTECTION POLICY

The company with the name "POLYZOGOPOULOS ANDREAS & CO. OE", 55 Thessaloniki Street, Nea Filadelfia, P.O. 14342 (hereinafter the "Company"), informs you that the processing of your personal data is carried out in accordance with the Law. With this protection policy (hereinafter the “Policy”), we provide you with information about the collection, storage, processing and use of your personal data. The Policy may be amended / supplemented / updated at any time by the Company, with the aim of harmonizing it with the currently applicable Legislation. It is recommended that you regularly update yourself on any changes.

What is the GDPR Regulation:

It is Regulation (EU) 2016/679 of the European Parliament and Council, of 27/4/2016, on the protection of natural persons against the processing of personal data and on the free movement of such data, as applicable from time to time, including legislation and amendments, through which it is incorporated into the Greek legal order (hereinafter the "Regulation").

What is personal data:

It is data-information that concerns you and makes you an identified or identifiable person, such as indicative name-surname, address, contact information, etc. (hereinafter the “Data”).

What is sensitive personal data:

This is data-information that reveals racial or ethnic origin, religious or philosophical beliefs, membership in a trade union, genetic or biometric data, as well as data related to health (hereinafter the "Data of special categories").

What is data processing:

Processing means any operation or series of operations carried out with or without the use of automated means on Data and/or Data of special categories, such as the collection, registration, organization, structure, storage, adaptation, alteration, retrieval, search, use, communication with transmission, dissemination and any form of disposal, association, combination, restriction, deletion or destruction (hereinafter the “Processing”).

What data we collect:

The Company collects and processes only the Data that is absolutely necessary for the fulfillment of each purpose. The Data is limited to what you have provided to the Company, either in the context of your respective contractual relationship (hereinafter the "Contract"), or during your communication with the Company (written, telephone, electronic), or during the use of this website, including information contained in forms, applications, reports, etc. and specifically:

·         Identity data (e.g. first and last name, patronymics, date of birth, ID number).

·         Contact data (e.g. home and/or work address, postal address, e-mail address, fax number, telephone number/s).

·         Identification data (e.g. IP address).

·         Other Data (eg online identifiers, location data, voluntarily disclosed information).

How we use the Data:

The Company will process the Data for as long as necessary, based on compliance with legal deadlines and the principles of data minimization, storage limitation and rational file management.

The Data will be processed by electronic and manual means in accordance with the procedures and practices related to the respective purposes and will be accessible by -authorized for this purpose- the Company's staff and the respective partners (e.g. those performing the processing , protection officer, technical staff), who are bound by corresponding confidentiality and non-disclosure agreements, as defined by the Law.

The Company will take all necessary measures, using advanced technologies, procedures, technical and organizational measures, in order to ensure the security of the Data, the avoidance of unauthorized access, loss, illegal or irregular use and its general compliance with the provisions of the Regulation.

For what purposes we process the Data:

The Company will process the Data in order to:

·         its compliance with - in each case - legislation, judicial and other decisions of the competent authorities, European, Community and International Regulations and legislation in general.

·         the exercise and vesting of individual legal claims and rights.

·         our communication for the improvement of its products and services, the adaptation of the website to your interests and wishes and the provision of information (telephone, written, electronic, by sending messages, etc.) in relation to new products, special offers or other information that may be useful to you,

·         handling your requests or reports of adverse events;

By accepting the Policy you provide your express consent to the Company to process the Data for the aforementioned purposes. In case of processing the Data for another purpose, beyond those mentioned above or below, the Company must obtain your prior permission and provide you with all necessary information for the purpose of the processing.

What is the legal basis of the processing:

The legal basis for the processing of your Data is defined on a case-by-case basis:

·         your express consent for the intended purposes.

·         the execution of the Agreement.

·         the Company's compliance with its legal obligation.

·         the pursuit of the Company's legitimate interest, under the conditions of the Regulation.

Who are the recipients of the Data:

In the sense of the Regulation, recipients are the natural or legal persons, public authorities, agencies or other bodies, to whom the Data is disclosed (hereinafter the "Recipients"). Recipients are defined as: (a) public authorities and services, as well as third parties (natural or legal persons) to whom the Data will be disclosed based on the applicable legislation, (b) subsidiaries and affiliated companies of the Company and Group companies , (c) partner companies, third parties and providers of professional or technical services, for the realization of the stated purposes.

The Recipients who receive Data, will process them - as the case may be - as controllers, processors or persons authorized for this purpose, in accordance with the applicable legislation.

Apart from the Recipients mentioned in the Policy, the Company will not transmit, communicate or grant the Data to third parties, unless it is made mandatory by the current legislation or is required by public/judicial bodies/authorities. By accepting this, you provide your express consent to the Company for the transmission of the Data to the designated Recipients.

How we secure Data:

The Company declares that the Data:

·         They will be lawfully and legitimately processed in a transparent manner.

·         They will be collected for specified, explicit and legal purposes and will not be further processed.

·         They will be appropriate, relevant and limited to the extent necessary in relation to the intended purposes.

·         It will be accurate and will be updated upon relevant information.

·         They will be kept in an identifiable form only for the required period of time.

·         They will be processed in a way that guarantees their appropriate security, including their protection against unauthorized or illegal processing and accidental loss, destruction or deterioration, using appropriate technical or organizational measures.

Data Transfer to third countries:

Your Data is only transmitted to entities within the European Economic Area (EEA), therefore subject to the strict legislation of the European Union for the protection of personal data or to entities outside the EEA. as long as they have the necessary certifications and commitments for their compliance with corresponding European safety standards or fall under the conditions of the Regulation.

Update:

As a data controller, within the meaning of the Regulation, is the company “POLYZOGOPOULOS ANDREAS & CO. OE”, Thessaloniki Street 55, Nea Filadelfia, P.O. 14342, E-mail address: info@emw.gr, Tel.: 213-0287107-8.

What are your rights:

Based on applicable law, you retain the following rights:

·         access to the Data, in the sense of confirming any processing thereof by the Company, the categories of Data, the purposes of the processing, the Recipients, the period of processing, receiving a copy of the Data and an updated list of the Recipients.

·         correcting inaccurate Data, in the sense of updating it following your relevant notification to the Company.

·         filling in incomplete Data, including through a supplementary statement.

·         deletion of the Data by revoking your consent to the Company, provided that the Data is no longer necessary to comply with an obligation that imposes the processing based on the legal order and/or for the execution of a Contract and/or for the establishment, exercise or support legal claims.

·         restriction of processing, when you question the accuracy of the Data and for a period of time that allows the Company to verify its accuracy, or when the processing is unlawful and you object to its deletion, requesting, instead, the restriction of its use, or when the Company no longer needs the Data for the purposes of processing, but the Data is required to establish, exercise or support legal claims. The Company will communicate any correction, completion, deletion of Data or limitation of its processing to each Recipient to whom it was communicated, unless this proves to be impossible or if it involves a disproportionate effort.

·         portability of the Data, in the sense of transferring it to another controller in accordance with the conditions of the Regulation.

·         objection to the processing (including objection to a specific form of communication), under the conditions of the Regulation, unless there are legitimate reasons for the processing or for the establishment, exercise or support of legal claims.

·         withdraw your consent at any time, without prejudice to the lawfulness of the processing based on the consent prior to its withdrawal.

·         filing a complaint with a competent supervisory authority.

You can exercise your aforementioned rights by contacting the Company in writing at the above stated contact addresses or respectively with the competent Data Protection Authority.

Use of Automated Decision Making – Profiling:

The Company does not make decisions, nor does profiling based on an automated process when processing your Data, except in the case of using "cookies" on the website.

Third Party Data:

Your disclosure of Third Party Data (e.g. on a legal entity: staff members) simultaneously includes: (i) the permission to the Company for the processing of the disclosed Data and (ii) your assurance that you have secured the Law required consent of third parties and in fact both for the disclosure of their Data and for the provision of the granted permission to process them, in accordance with what is stated in this Protection Policy.

Contract:

In case of your contractual relationship with the Company (e.g. customers / suppliers / partners), in addition to the above, the following apply (and / or):

The concept of Data also includes:

·         Individual business data (e.g. name, registered office, GEM no., details of legal representative),

·         Financial transaction data (e.g. bank account number(s),

·         Tax data (e.g. A.F.M., D.O.Y.),

·         Details for the execution of the Agreement or the exercise of legal rights or obligations from it.

·         Details of the communication between us, such as e.g. the recording of a call to the Company's call center (as long as it is allowed by the current Legislation and under the respective conditions), registration of e-mails or letters.

·         By accepting this, you provide the Company with your express consent to the processing of the Data, with additional purposes:

·         our communication under the Agreement and

·         the Company's compliance with the more specific Legislation governing the Contract. In this case, the processing of the Data is carried out for the execution of the Agreement, the harmonization with the legislative requirements and the exercise of individual rights and obligations.

Public authorities and services, as well as third parties (natural or legal persons) to whom the Data will be disclosed for the execution of the Agreement or the exercise of special rights and obligations (e.g. accounting software companies, crm etc.) are defined as Recipients.

The Company will process the Data for as long as the Contract exists and/or after its termination or expiration in any way, as long as it is required for the execution/exercise of individual contracts/rights or the harmonization with the obligations of the current legislation .

Withdrawal of consent, deletion, portability of Data and opposition to processing may have consequences if the Company can no longer comply with its legal or contractual obligations.

Resume:

In case you send your resume to the Company or its legal representative, in addition to the above, the following apply (and/or):

Data includes information that you voluntarily include in your CV (e.g. employment history - including job titles and company names, education, work qualifications, financial information, special category data, work preferences, etc.) .

The purpose of processing is defined as the communication to investigate the conditions of any recruitment / employment of you in the Company, a subsidiary or a company connected with it, in the wider future, after a relevant evaluation.

The Data will be processed by the Company until the consent is revoked.

Liabilities:

By accepting this, you accept your obligation: (a) to maintain secrecy and confidentiality regarding what comes to your knowledge, because of or on the occasion of the Contract or your communication with the Company. Any item or information in relation to Third Party Data [i.e. personal data and data of special categories under the aforementioned concepts], which concern a third party (including employees of the Company, partners, legal representatives, etc.) and/or financial, commercial, business etc. practices of the Company, is considered to be of an absolutely confidential nature, any processing, notification or disclosure thereof is prohibited, especially to anyone and in any way, (b) for not keeping a file of documents or any elements in general that contain Third Party Data, including electronic or photographic , (c) to inform the Company in any case of unauthorized or illegal processing of Third Party Data and/or accidental loss, destruction or damage thereof, (d) for your compliance with the Data Protection Regulation.

Website:

In the event of a simple visit to the website without your sending a message / request / report etc. the processing of Data will be limited to browsing data, i.e. data that is automatically collected for technical reasons, such as the IP address, which the Internet access provider has on your computer for connecting to the Internet or in connection with the browser on internet you use, as well as technical or other parameters for connecting to the website. Said technical information may, in individual cases, constitute personal data. As a general rule, the Company uses the information received only to the extent necessary for technical reasons in general, including the operation and protection of the website against abuse, attacks or illegal actions.

The website may contain links to third party websites. Given that the Company is not responsible for the protection measures of the included links, it disclaims all relevant responsibility and asks you to be informed about the protection policy of external websites before using them.

Cookies

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The website uses cookies in order to improve it and adapt it to the needs of users / customers.

Overall, cookies help EMW to better provide its services through the website. Cookies do not give EMW access to your computer or any information about you, other than the data you choose to share.

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