PRIVACY POLICY

PERSONAL DATA PROTECTION POLICY

  1. INTRODUCTION
  2. General Respect for your privacy and the management, protection and security of your personal data are for SERCOM TRADING “Company”«SERCOMTRADING.COM»“We” , “Us” ) priority. The Company has established this Privacy policy, which also includes as a single text and an integral part thereof (hereafter referred to as “Data Policy” or “Policy”), to inform you about the kind of data it collects or generates for you visiting or buying from SERCOMTRADING.COM (hereafter «E-shop» , “E-shop” or “Website” or “SERCOM TRADING” ), or you become a member or you are a member of our newsletter recipients list, or in any other capacity you make use of SERCOM TRADING services or participate in promotional or other actions, or use social media Media) of sercomtrading.com, or otherwise, (hereafter “You”“Your” ) for the purpose of collecting and processing your data and how to process these data and recipients, your rights and choices in your personal data, and how to contact us for any matter any concerns about your personal data.
  3. Amendments: This version was updated on May 25, 2018. You can contact us for older versions. This Policy replaces all previous disclosures we may have previously provided about our disclosure practices. This Privacy policy is governed by both the relevant provisions of Greek and Community law relating to the protection of individuals from the processing of personal data. Any possible future change to the above regulatory framework will be the subject of this. We therefore reserve our right to change this statement and to apply any change to your data and practices in relation to the collection and processing thereof, as provided by law, and / or to modify or replace the whole and / or part of this Policy in our sole discretion. If there are substantial changes to this Policy or our practices regarding your data change in the future, we will notify you by publishing the changes to our Site. However, if you wish to have any clarification or information regarding the changes, or have any dispute, reservation or question about them (changes), you may contact us with the information listed in the Section below. Please note that any information / clarification granted to you in connection with any changes to this Policy does not constitute a substitution, substitution or any modification of this Policy. Continuing your navigation on our Site, or using our Services and / or buying through our Online Store, also implies the automatic and unconditional acceptance of the modified terms of this policy on your behalf. In the event that you do not agree with the modifications, you must not make any action or use of the Site or purchase, and more so in the provision of personal data, you are entitled to terminate the contracts between us and request the deletion of your Account and Data your. In any case for any information or clarification, you may contact us and in any case you have the right to exercise your rights as detailed in Section V below.
  4. Content: This Privacy policy includes:

Information about your Data Processing Officer and your Data Protection Officer, as well as our contact details for any matter relating to your data.

The kind of data we collect for you and the collection methods.

The purpose of collecting and processing your personal data and the legitimate basis for processing.

What security measures do we take to protect your data, how long do we keep it?

Your rights and how you access them, and your choices regarding the collection and processing of your data.

Protect and store your data from SERCOMTRADING.COM.

 

  1. RESPONSIBLE PROCESSING AND DATA PROTECTION MANAGER 1. Who is the Editor? Person responsible for processing your personal data is the company with the name “Kareem Akleh’’ and the distinctive title “SERCOM TRADING”.
  2. Who is the Data Protection Officer of the Company? The contact details of the Data Protection Officer (DPO) are: email: info@sercomtrading.com, tel. 0030 694 593 1441.
  3. Questions and Comments You may contact us with the contact details listed above and provide us with your comments, queries, comments or any complaints regarding this Policy and the general collection and processing of your personal data. You have the right to submit any complaint regarding your privacy issues that may arise from the processing of these by the Company to the Hellenic Data Protection Authority, which is the supervisory authority in our country. See the following link for details www.dpa.gr . However, we consider it our duty and duty to manage any concerns about your personal data we process, so we will be happy to contact you.

 

III. COLLECTION AND DATA PROCESSING

1.What data we collect for you andHOWwe collect them When you navigate to our Online Store, or when you place an order, open your Account, register and receive our newsletter and use our other services, participate in your actions SERCOMTRADING.COM or otherwise, we collect various types of personal data for you, either directly from you, by third parties or by automated means such as:

Identity Data that you grant us when submitting your order or when registering as a member of SERCOMTRADING.COM with the opening of an Account, your participation in competitions,

Communication Data which you give us both obligatory and optional, such as when submitting an order or opening an Account or in the context of receiving commercial communication from our Company or in the course of your participation in various actions of our Company (eg competitions, etc.) .

Financial data you are required to submit your order (eg card details or bank account etc), credit balances. Refunds, etc.

Transaction Data we collect when purchasing or using our services, for example when sending newsletters (what you open and their content), type of purchase, place of delivery, time of purchase, withdrawal, complaints, purchase history, shopping cart,

Consumer Behavior Data: Consumer preferences based on shopping products, gift redemption, purchase frequency, way, purchase time, purchase type etc

Technical data such as the IP address, login information, browser type and version, operating system and platform, and other technology on the devices used to access our Web site,

Connection Data in your Account, which is your username and password.

Profile Data which is derived from the information you provide to us, whether mandatory or optional, when purchasing or registering as a Member, or using the Newsletter (eg how much and what newsletter you open and when) from information derived from your browsing Shop, from your purchases (kind, time, cost,) from your feedback during the market research that the Company is conducting from time to time, from your participation in our competitions, from your comments and questions to us or from any complaints , from your interaction with SERCOMTRADING.COM Social Media, from the information that you voluntarily post to Social Media, information collected from the cookies we use,

Demographic data: age, sex, place of residence, etc.

Cookie data: number of visits to eshop, time of stay, interaction of the visitor with the eshop (see in detail the Policy Cookies ).

We do not knowingly collect any information from anyone under the age of 15. Our services are aimed exclusively at people who are at least 15 years of age or older. If you are under 15, do not use or provide any information to us, do not register as a Member or our list of recipients, do not make any purchases and do not give any information about your face to us, including the name , your address, or contact information (phone, email, etc.). If we find that we have collected or received personal data from a child under the age of 15, we will delete them immediately unless consent has been given to a parent or guardian. If you think we may have information from or for a child under 15, please contact us. We collect directly from you the following personal data:

When submitting your order, whether you are electronic or telephone, you must provide us your full name, product shipping address, email address, contact phone number (mobile or fixed) and payment details (credit / debit card, etc.).

When opening your Account, you must provide your full name, email address and a contact number that you are pretending to be mobile or fixed, and optionally gender, date of birth, and contact information for commercial purposes.

When you subscribe to our newsletter list, we grant you your email.

When you sign up for competitions that our Company makes from time to time, we grant you your personal information specified by case.

When using our Company Social Media (FB), we grant you personal information, such as your email, on a case-by-case basis.

When you communicate with us (in addition to the case of the telephone order), we collect your personal information you provide on a case-by-case basis.

Collect with me automated means the following data and information for you.

By using cookies and other related technologies, we collect and / or create data about your preferences, such as the products you visit, the duration and frequency of some products, the type of newsletter you open or not, their content, and your interaction with us after every newsletter, your Wishlist, the type of products you buy, the search terms you’ve entered, or the links you clicked on the Site, the products you place in the cart and do not complete market,

From your purchases, we create data about your purchases, history of your orders and purchases, your preferences, your purchasing frequency by type, the value of the products you buy or are interested in, the time you buy ………

Data about the devices through which you visit our Site, such as the IP address, login information, browser type and version, operating system and platform, and other technology on the devices used to access the Our Web site, etc.

Data about the page from which you signed up and the page you transferred when you left,

We collect from third parties the following data and information about you:

We may receive your personal information, such as your full name and e-mail address, from a third friend who told you to receive a SERCOM TRADING  Sales card from us.

We may collect profile information in general (such as your preferences on our products and your satisfaction with us) from social media that you voluntarily post them to.

2.HOW and WHYwe use your personal information. All of your above personal data, which as mentioned or is provided to us by us or on a voluntary basis, or we collect them from third parties or are produced by automated means, we use them for the following legitimate purposes. Please note that if Community or national law restricts or prohibits certain actions of the Company for which we use your data, we will discontinue the use of your information for these purposes. In particular, your personal data is used by us for the following aims:

to receive your orders, process them, and ship the products to you and communicate with you about issues relating to the sale of our products to you.

For handling and processing and processing your payments, including the security of our financial transaction.

For your service as a Member on SERCOMTRADING.COM by opening your Account with us.

For creating, keeping and maintaining a database with our client base and analyzing it.

To send to you commercial communications through newsletters, sms, or other media that relate to our Company news, products, promotions and / or promotions and / or to send you personalized updates based on your preferences and your profile to and to understand and analyze the results of our ads and promotions.

To handle your requests, such as withdrawal, replacement etc, and the exercise of your rights.

For security of transactions

for business analyzes and improvements, such as marketing and optimizing our products, optimizing your experience and service from us in our Online Store, managing Loyalty programs, as well as and to adapt your experiences to our Online Store.

For market research, statistical analyzes, marketing strategies and marketing campaign management and let us or our partners inform you about possible opportunities to participate in SERCOMTRADING.COM’s marketing or promotional initiatives.

for other purposes for which we will notify you, or will be identified on a case-by-case basis, at the point where your information is originally collected

OR legal basis to use the information about you is one of the following (we provide more detailed explanations in the “learn more” section):

compliance with a legal obligation to which we are committed,

the performance of a contract to which you are a party,

the legitimate business interest over which your information protection interests do not override,

if none of the above apply, your consent (which we will ask for before processing the information).

Purpose of Processing Data we process for this purpose        Legitimate Processing Base

Member Registration – Create Account – Account Management at SERCOMTRADING.COM: We process your data for:

to recognize you as a user.

give access to the functions and services of the Member Account.

To use your Account’s services / features (Purchase history, Address management, etc.)

  1. A) Your personal data that you tell us about creating your account at SERCOMTRADING.COM: Required:

Name Surname

e-mail

password

Optionally:

 

sex

age

  1. B) Transaction Data C) Cookies data for Wishlist

 

The legal basis for the treatment is: a) Your consent for your registration and the creation of an Account at SERCOMTRADING.COM and the voluntary release of your data that is optional for this purpose. b) our legitimate interest for security of your account and your identification wherever it is, and it is to your advantage to avoid fraud or security incidents. c) execution of terms that govern the creation – management and operations of your Account.

Download, Manage and Run your order submitted to SERCOMTRADING.COM via e-shop or by phone:

ordering by the customer

order entry

product pricing

payment management, fees and charges

delivery of products to the customer

retiring or returning a product for another reason

processing and in general order management

Contact with customer for updates, notifications regarding the order

Enable mechanisms to prevent fraud against you or against us.

To ensure the use of your gift vouchers, etc.,

  1. Your personal data that you declare to us when submitting your order:

Name

Last name

Mobile or fixed phone (optional)

e-mail

product delivery address

payment and card details

In case the call is recorded, you will be notified beforehand by a relevant audio message. B) Transaction Data C) Purchase Data

 

The legal basis for the treatment is: (a) performance of the contractual relationship that the Company undertakes to perform to you under the purchase and sale agreement. (b) compliance with the company ‘s legal obligation to comply with tax arrangements and provisions, (c) a legitimate interest in collecting a purchase price, detecting any fraud that benefits you also if someone attempts to cheat you eg using your payment data,

Pre-Sale or After-Sales Customer Service and Management including:

Communication by the client in the Company’s media (conventional media, email or call center, or multimedia communication eg viber or other media eg Social Media)

Communication by the Company at customer’s request to the data provided by the customer.

Serving in general on issues related to the company, e-shop, products, services, order, account, programs or competitions that he / she implements at any time, any guarantees he / she can provide, the social media of the company .

Complaints or clarifications

Exercise of rights

Generally managing and optimizing the experience and service of the user in the e-shop

The processing for this purpose includes the absolutely necessary data that you give us when submitting your request, that is

Identity Data

Communication Ties

Market Data

Transaction Data

Information that you grant us related to request your

Whether we are developing data for you. In case the call is recorded, you will be notified beforehand by a relevant audio message

 

The legal basis for the treatment is: (a) Compliance with the Company’s legal obligation to adopt pre / post-sale customer service tools / instruments to respond to your queries related to the exercise of your rights. b) the company’s legitimate interest in responding to your requests through various communication channels, optimizing customer service and customer service and providing customers with the ability to communicate with them and manage any of their issues in the best possible way, based on their needs, which are of benefit to the subject and which is reasonably expected by the subjects. Any user may opt-out at any time by accessing his / her personal information for that purpose, such as for his shopping card data to serve it, declaring it to its customer service staff or communicating with the Company in all media for any of the above. c) Performing a contract if you contact us specifically to manage issues related to your order d) the customer’s consent to receive communication from the Company for this purpose when he asks the Company to contact him

Advertising & Marketing

Administering the SERCOMTRADING.COM newsletter subscription list.

Send general and personalized newsletters.

Send direct commercial communication via email, sms, vider or other media, push notifications, etc.

Conducting promotions such as organizing competitions, activating old customers, rewarding good customers, loyalty etc.

Purchase suggestions and market incentives based on your preferences.

Voluntary participation in competitions

Investigating the degree of customer satisfaction from the services provided by SERCOMTRADING.COM.

Direct commercial personalized communication with personalized updates based on customer preferences.

For the purpose of advertising & marketing, the company processes identity and communication data, purchase and transaction data, profile data, demographic data, cookie data, and / or a combination of the above. For example, our company is processing data about the type of products you buy, your recent purchases, market value, purchase frequency, purchase history, and so on.          The legal basis for the treatment is: (a) Company’s legitimate interest in processing customer data that was granted to us as part of a purchase or other transaction with us for the purpose of direct commercial communication for related products or purposes. In these cases, you can ask for an opt-out by pressing the unsubscribe button on your email or mobile message or by contacting us In addition, we believe that we have a legitimate interest in setting up a profile with the information we have about you (eg, history of your purchases, your preferences when browsing the e-shop), but also based on your purchases and your interaction with newsletters, age, gender, place of residence, as we understand that processing this data is also beneficial to you as you improve your experience at SERCOMTRADING.COM and at the same time you gain access to information that interests you. b) consent when you voluntarily give us your data, authorize us to send you newsletters and personalized information via email, sms, viber, and other media when you accept push notifications.

Business analyzes and improvements for:

Uninterrupted operation of e-shop

technical excellence and security of transactions

optimization of technical systems

technical issues

compiling reports and keeping data

The information we process for this purpose is a combination of information that you provide to us (for example, account details, data we receive through cookies and similar technologies.     The legal basis for the treatment is: (a) compliance with a legal obligation on information security and confidentiality b) a legitimate interest in network security and the prevention of fraud and unauthorized access to data, our business continuity, the upgrading of our systems and partners, the development of our business activities and the management and optimization of techniques systems, our commercial processes, processes that override the rights and freedoms of subjects that they reasonably expect to be processed for this purpose. You have the right to oppose the above treatment per treatment case. It should be noted, however, that the Company is entitled to demonstrate overriding and legitimate reasons for the processing that overrides the interests, rights and freedoms of the subjects

Statistical analysis to evaluate and improve e-shop services and procedures including:

Evaluation and improvement of business processes

Better responsiveness and e-shop management

Research and / or analysis to better understand the needs of e-shop customers

Research and evaluation to improve existing products and / or services and develop new ones

Evaluation for the creation of new programs, promotions etc.

Adoption of new business and business models, programs and collaborations.

Promote our Company, our products and our services.

Distribution and marketing of our products to other countries.

Disposal and marketing of new products and services.

Advertising and promotion of our Company.

Improve your experiences

Delivery of related content

Quality surveys

Statistical analyzes

All data collected in the context of previous processing purposes as aggregated statistical data, taking all necessary safeguards that do not allow the identification of the subjects. Also, data collected from the corresponding cookies that perform such processing will also be used.         The legal basis for this treatment is (a) the Company ‘s legitimate interest in the further processing of aggregated data for the purpose of statistical analysis for the improvement of its products and services, with all the necessary safeguards to collect and process data that do not identify a particular subject and do not affect rights and freedoms of data subjects. b) a legitimate interest in placing our products on the market, analyzing the usability and functionality of the e-shop, the level of satisfaction of our customers, our customers’ preferences regarding the offered products, improving the business our performance to improve our partnerships, always with respect for your rights, freedoms and interests with respect to your personal data.

  1. WHO I NOTIFY YOUR PERSONAL INFORMATION AND WHY? In the context of e-shop operation, the fulfillment of our contractual obligations and your best service, our Company reserves the right to cooperate with third-party service providers that provide us with support and access only to what your data is absolutely necessary for the service they offer us (eg registering you in the e-shop and managing your account, executing the contract between us and the general provision of our services to you, the functional and mechanical nografiki organization SERCOMTRADING.COM website, optimization of our products and services, etc.).These third party service providers are bound by contract not to use your information in any way other than to help us provide you with the products and services we agree to. In particular, our Company cooperates: (a) With a third company which, as we perform the processing on behalf of and on behalf of our Company, hosts and manages our e-shop. (b) With a third Call Center company acting on behalf of and on behalf of you, as processor, having taken over your telephone orders and your telephone service. (c) With third party courier companies which, as you process the order and on behalf of our Company, manage and process the shipments of your orders and collect the money on our behalf if you pay by cash on delivery. They also execute the receipt and delivery to you of products that you return due to a withdrawal or return. (d) With third-party email marketing companies acting in the name and on behalf of us to send you the newsletter. (e) Advertising and marketing companies (f) Data analysis companies (g) Research companies (h) Financial Institutions to collect the purchase price (i) Fraud Detection and Prevention Organizations, (j) Providers of technology services, We reserve the right to disclose your personal data to a third party in which we reserve the right to choose to transfer all or part of our business. Furthermore, in the event of a merger or redemption or other change in our business, the new owners, etc. have the right to use your personal data in the same way as this privacy statement. Your retained data may be communicated to the competent judicial, police and other administrative authorities upon their request and in accordance with the applicable laws. Moreover, in the case of a statutory provision, a service order or an official preliminary examination, the Company has the right to place the relevant information at the disposal of the respective service IV. PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA 1. SAFETY of your personal data We apply appropriate technical and organizational measures to protect the personal information we hold from unauthorized disclosure, use, conversion or destruction. Where appropriate, we use encryption and other technologies that can help safeguard the information you provide. We also ask our service providers to comply with stringent privacy and data protection requirements. In particular, the data you submit to the Company is managed exclusively by specially authorized personnel of the Company under our control, respectively, at our sole discretion. In order to conduct the processing, the Company selects individuals or third parties with corresponding professional qualifications that provide sufficient guarantees in terms of technical knowledge and personal integrity to maintain confidentiality. The Company, through its respective contractual commitments and its affiliates, takes all necessary security measures to protect and ensure the confidentiality, confidentiality and integrity of personal data. In any case, their security in the platform environment is subject to reasons beyond their sphere of influence,as well as reasons due to technical or other weakness of the network that is not controlled by the Company or reasons of force majeure or force majeure. You must not disclose the data / codes you have entered to open your Account, which is personal and non-transferable. For personalized communication, our Company also uses appropriate mathematical and / or statistical processes to compile the profile and performs regular quality and security checks on the systems and algorithms it uses to correct the factors that lead to inaccuracies in the data. 2. RESTORE of your personal data We will keep your personal data for as long as you continue to interact with us (you maintain an Account, you are registered to receive commercial communication from us, make a purchase from our online store, contact our customer service points, take part in a competition etc.) and are necessary for the fulfillment of the purposes we have collected and processed, as described in detail above, or for the length of time that liability could arise from processing in accordance with the applicable law. or if these goals are eliminated, we do not have to keep them under a law, for example, for tax purposes. We also maintain them until you ask for their deletion, or what we maintain and process as part of your consent,until you get it, or until you oppose their processing by us on which we rely on our legitimate interest. To determine the retention time of your personal data, we take into account the nature of your data, its quantity, its purpose, its security, etc. You have the right to ask us to delete your data. To exercise your right, please visit the relevant section in this Policy. We reserve the right in certain circumstances to anonymize your data for research or statistical purposes, so that we are no longer associated with an identifiable person, therefore we reserve the right to use this information for an indefinite period of time. In any case, your data is stored securely

 

Purpose of processing Preservation Time

Manage Your Account           Until your Account is deleted

Receipt of order, order fulfillment     We will process your data for the length of time required to manage the purchase of the products or services you have acquired, including any refunds, withdrawals, complaints or claims relating to the purchase of the particular product or service. Some of your information that you may have to keep us alive will keep them until you tell us to stop storing them.

markets           If you buy products, we will retain your transaction details for as long as we need to complete the sale and comply with any legal obligations (for example, for tax and accounting purposes).

Customer service        If you contact customer service, a relevant record will be created (including details of your inquiry and our response) and will be retained for as long as it remains relevant to our relationship. Temporary files may not be useful until more permanent files exist and will only be retained on a temporary basis.

Market Research         If you have not registered with us for other purposes (e.g., promotions,) and we use your public information to understand your purchase or preferences, we will keep your information for a short period of time to complete that particular domain market research.

Usability and quality analysis We will process your data during the period during which we will take an action or a specific quality survey or until we have anonymized your browsing data

Marketing       Until your deletion from the newsletter, or until you get your consent, if it has been granted or until you oppose processing, or the longer for five (5) years. However, some elements of your promotional profile, such as records of how we interact with you, are natural to cease to apply after a period of time, so we automatically delete them after a specified interval (usually 3 years) depending on the purpose for which we have collected them. If we have no communication with you for a long time (usually 3 years), then we will stop sending you promotional announcements and we will delete the history of your responses. This will happen, for example, if you never click on our Newsletter, if you never log in to a digital contact point or if you never contact us or do not make a purchase, or contact customer service during that space. The reason is that, in these cases, we assume you prefer not to receive announcements.

Business Analyzes      Business analytics data is typically collected automatically when you use SERCOMTRADING.COM contact points and are immediately anonymized / aggregated.

  1. TRANSMISSION OF YOUR PERSONAL DATA TO THIRD COUNTRIES The Company generally maintains your personal data within the European Economic Area. In the event that data is to be transmitted to third countries outside the European Economic Area for which there is no European Commission decision or International Organizations, all the appropriate safeguards provided for in the applicable data protection legislation on the transfers to third countries and the relevant information will be posted on the company’s website at SERCOMTRADING.COM. V. YOUR RIGHTS AND OPTIONS With respect to your personal data we have and we process, you have the following rights:

 

ask us to access them to confirm that we process them according to your law and / or your own commands and preferences

ask us to correct incomplete, unannounced or inaccurate data we hold for you. Of course, we also have the right to ask you to update your information at regular intervals.

ask us to delete them , since of course the law does not oblige us to the contrary.

to ask us to limit their use, under certain circumstances,

to oppose their use, under certain circumstances,

to withdraw your consent with regard to their use,

have the right to data portability , under certain circumstances,

ask them not to be used for direct marketing and

to submit a complaint to the country’s supervisory authority.

We offer you easy ways to exercise these rights, such as Unsubscribe, or Phone Service Monday to Friday from 9.00 to 17.00, or by sending an email to info@SERCOMTRADING.COM Some mobile apps we offer they may also send you unsolicited messages about, for example, new products or services. You can disable these messages through the settings in your phone or app. For the security of your information, we may request some information for you to identify you. Your right is exercised free of charge, however, when your right is abusively used to claim a fee, in accordance with the conditions laid down by law. In any case, we respond to your requests within one month, except in exceptional cases where our response time to a request may be longer.

 

Access (a. 15) You can ask us to:

Confirm that we process your personal data.

to give you access to any data you do not have at your disposal

to provide you with other information about your personal data, such as what data we have, why we use it, who we are notifying, whether we pass it abroad and how we protect it, how long we keep it, what rights you have, how you can submit a complaint, from where we took your data to the extent that no information has already been provided to this Policy.

Correction (a.16)        You can ask us to correct inaccurate personal data. We can seek to verify the accuracy of the data before we fix it.

Deletion (a.17)            You may ask us to delete your personal information:

whenever they are no longer needed for the purposes for which they were collected or

when you unsubscribe from the eshop (which will anyway be deleted immediately) or

have been illegally processed

We do not need to comply with your request to delete your personal data if processing of your personal data is necessary:

 

to comply with a legal obligation

for the fulfillment of another legitimate purpose or other legal basis; or

for the establishment, exercise or defense of legal requirements.

Restriction (α 18)

You may ask us to limit (ie keep but not use) your personal data when:

their accuracy is being challenged (see Correction) so that we can verify their accuracy or

processing is illegal but you do not want to delete it or

is no longer necessary for the purposes for which it was collected but we still need it to establish, exercise or defend legal requirements, or there is another legitimate processing purpose or other legal basis

Portability (a.20)         When processing is based on consent and is done by automated means, you may ask us to provide your personal data in structured form that is widely used in the form of mechanical readings, or you may request them to be transferred directly to another processor. However, this right, according to the law, concerns only data that have been provided by the subject itself and not those obtained by the controller on the basis of the data provided by the subject

Opposition (a.21)        You may at any time object to any processing of his or her personal data which has as its legitimate basis the legitimate interest of the Company or the fulfillment of a duty performed in the public interest.

Opt-out            You are entitled to your consent, where consent is obtained as a basis for processing. The lifting is done for the future.

Supervising Authority You have the right to file a complaint with the local supervisor about the processing of your personal data. In Greece, the supervisory authority for data protection is the Data Protection Authority – AIDCP ( www.dpa.gr ).

ID card            We take full account of the confidentiality of all files that contain personal data and we reserve the right to ask you for proof of your identity if you make a claim about those files.

Costs   We will not charge you for the exercise of your rights in relation to your personal data unless, as provided for by law, your request for access to information is unfounded or excessive, so we may charge a reasonable fee under these conditions. We will notify you of any charges before completing your request.

Timetables      Our goal is to respond to any valid requests within one (1) month of receipt, unless it is very complex or you have made a number of requests, so we aim to respond within three months. We will let you know if we will need more than one (1) month for the reasons outlined above. We may ask you if you can tell us exactly what you want to receive or what is exactly what you are concerned with. This will help us to act faster on your request. In any case, you must indicate specific and truthful facts and / or facts in order to be able to answer and / or satisfy your request accurately, otherwise we reserve the right to make any errors that leave our control. In addition, our Company may refute requests that are unjustified or excessive or abusive or inaccurate or in general unlawful, within the framework of the provisions of the law.