Privacy Statement of the limited liability company under the name “SIDERIS Ltd” and the distinctive title “DELPHICAMP”

21/04/2018

The limited liability company under the name “SIDERIS Ltd” and the distinctive title “DELPHICAMP” (hereafter the “Company”, “we”) is committed to protecting your privacy and handling your personal data in an open and transparent manner. The personal data we collect and process are dependent on the product or service requested and agreed upon in each individual case.

This Privacy Statement:

• Provides an overview of how the company collects and processes your personal data and informs you about your rights under the local data protection law and the EU Data Protection (GCCA) General Regulation,
• is addressed to natural persons who are existing or potential clients of the company or who are authorized representatives or agents or actual beneficiaries of legal or natural persons who are existing or potential clients of the company,
• is addressed to natural persons who had such a business relationship with the company in the past,
• contains information on when your personal data will be shared / exchanged with other companies and other third parties (for example, our service providers or our suppliers).

In this privacy statement, your data is sometimes referred to as “personal data”, “personal data” or “personal information”. Sometimes you may collectively refer to handling, collecting, protecting and storing / retaining your personal data, or any such action as “processing” of this personal data.

For the purposes of this statement, personal data means any information relating to you that identifies you or can be identified, including, for example, your name, address, or identity number.

What personal data we process and where we collect it

We collect and process different kinds of personal data that we receive from our (existing and potential) customers in person or through their representative or via our alternative channels of communication, such as our website, in the context of our business relationship with them.

If you are a prospective customer or an authorized representative / agent or a beneficial owner of a prospective legal or natural person, the relevant personal data we collect may include:

Name, address, contact details (phone, email), identity card, date of birth, place of birth (city and country), marital status, if you are employed / self-employed, verification data [e.g. signature].

When we agree to provide services to you or to the legal entity you represent, additional personal data will be collected and processed, which may include:

1. Data relating to children

We understand the importance of protecting privacy in relation to children. We collect personal data with respect to children only on condition that we first obtain the consent of the parents or their legal guardian unless otherwise permitted by law. For the purpose of this Privacy Statement, “children” are considered to be under the age of eighteen (18) years.

2. Whether you have an obligation to provide us with your personal data

In order to be able to engage in a business relationship with you, you must provide us with your personal data that is necessary for the required start and execution of a business relationship and the fulfillment of our contractual obligations. In addition, we have to collect this personal data to verify your identity before entering into a contract or business relationship with you or the legal entity of which you are the authorized representative / agent or beneficial owner. You must therefore provide at least your ID / passport, your full name, place of birth (city and country) and your residence address so that we comply with our statutory obligation.

Please note that if you do not provide us with the required information, we will not be allowed to start or continue our business relationship with you as an individual or with you as an authorized representative / agent or real beneficiary of a legal entity.

3. Why do we process your personal data and on what legal basis

As stated above, we are committed to protecting your privacy and handling your data in an open and transparent manner and we therefore process your personal data in accordance with the data protection law for one or more of the following reasons:

1. To carry out a contract

We process personal data in order to offer services under contracts with our clients, but also to be able to complete our acceptance process in order to enter into contracts with prospective customers.

The purpose of the processing of personal data depends on the requirements for each service and the contractual terms and conditions provide more details about the relevant purposes.

1. Compliance with a legal obligation

There are a number of legal obligations arising from the applicable laws that apply to us (eg Tax Legislation). There are also various supervisory authorities (central government, local government, etc.) whose laws and regulations we have to implement. Such obligations and requirements impose the necessary personal data processing activities for audits, identity verification, compliance with court rulings, reporting obligations of tax or other legislation and audits.

1. For reasons of protection of legitimate interests

We process personal data to ensure the legitimate interests of ourselves or of third parties. A legitimate interest exists when we have a business or commercial reason for using your information. But even then, you should not improperly oppose what is right and best for you.

Examples of such processing activities include the following:

• Installation of surveillance systems (closed circuit cameras – CCTV), to prevent criminal acts or fraud.
• Company risk management.

1. Because you have given your consent

If you have explicitly given us your consent to processing (other than the reasons mentioned above), the legitimacy of this processing is based on that consent. You have the right to withdraw your consent at any time. However, any processing of personal data made prior to the receipt of your recall is not prejudiced.

4. Who are the recipients of your personal data?

In fulfilling our contractual and legal / regulatory obligations, various service providers and suppliers may receive your personal data in order to fulfill our obligations. These service providers and suppliers enter into contracts with the company, under which they undertake to maintain confidentiality and data protection in accordance with local data protection law.

We should point out that we may disclose data about you for any of the reasons mentioned above or in case we are bound by law to that, or are authorized under our contractual and regulatory obligations, or have given your consent.

5. How do we handle your personal data for marketing activities and whether profiling is used for such activities

We may process your personal data to inform you of products, services, and offers that may be of interest to you.

The personal data we process for this purpose consist of information you provide to us and data we collect and / or conclude when using our services. We study all this information to form a view of what we think you may need or what you may be interested in. In some cases, profiling is used, that is, we process your data automatically for the purpose of evaluating certain personal information in order to provide you with targeted product information.

We may use your personal data to promote our products and services to you only if we have your explicit consent to this or if in some cases, we believe we have a legitimate interest in doing so.

You have the right to oppose at any time the processing of your personal data for marketing purposes, including profile training, by contacting the company at any time, either in person or in writing.

6. How long do we keep your personal information

We will retain your personal data as long as we have a business relationship with you [as an individual or in relation to our transactions with a legal entity that you are authorized to represent or are the beneficial owner).

Once our business relationship with you is complete, we may maintain your data for up to two (2) years.

We may retain your data for more than 2 years if we can not delete it for legal, regulatory or technical reasons.

For personal data of prospective clients [or authorized agents / agents or real beneficiaries of a prospective client of a legal entity], we will retain your personal data for 6 months from the date of disclosure.

7. Your data protection rights

You have the following rights with respect to personal data we hold for you:

• Access your personal data. This allows you, for example, receive a copy of the personal data we hold for you and check that we process it legally. To receive the copy, you can send us your request to our corporate email: info@delphicamp.gr.
• Ask for the correction of personal data we hold for you. This allows you to correct any inaccurate or inaccurate data we hold for you.
• Ask for the deletion of your personal information. This allows you to request that you delete your personal data when there is no valid reason to continue processing it.
• You oppose the processing of your personal data [known as the ‘right of objection’] when we rely on a legitimate interest but there is something special about your situation that makes you want to oppose treatment for that reason. You also have the right to oppose instances where we process your personal data for direct marketing purposes. This also includes profiling, insofar as it relates to direct marketing.
• If you oppose processing for direct marketing, we will stop processing your personal data for these purposes.
• Ask for the limitation of the processing of your personal data. This allows us to ask us to restrict the processing of your personal data, that is to use only in certain cases if:
• is not accurate,
• have been used illegally, but you do not wish to delete them,
• no longer needed, but you want to keep them for use in potential legal claims,
• you have already asked us to stop using your personal data but expect to confirm if we have legitimate reasons to use it.
• Ask to receive a copy of your personal data in a structured format to pass this data to other organizations. You also have the right to request that your personal data be transferred directly from us to other organizations you will name [known as data portability rights].
• You withdraw the consent you have given us regarding the processing of your personal data at any time. Please note that any revocation of consent does not affect the legality of consent-based processing before it is withdrawn or revoked by you.
• In order to exercise any of your rights or if you have any other questions regarding the use of your personal data by us, you can contact us or visit us.

We strive to respond promptly to all your requests.

8. Right to file a complaint

If you have exercised some or all of your rights to data protection and you still feel that your concerns about the way we use your personal data have not been addressed satisfactorily by us, you have the right to submit a complaint. You also have the right to file a complaint with the Personal Data Protection Office.

9. Changes to this Privacy Statement

We may occasionally change or modify this privacy statement.

We will duly notify you when we make changes to your privacy statement and will change the review date listed at the top of this page. We recommend, however, that you review this statement periodically so that you are always aware of the way we process and protect your personal information.