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Privacy Policy

"CONARTIA EE", distinctive title "CONARTIA", Information technology design and development services for applications No. G.E.MI 156752306000, Tax Identification Number 801434557, 19-21 Georgiou Gennimata Street, 55535 Pylaia, Thessaloniki.

CONARTIA is active in three areas of technology: the distribution and installation of sports measurement and analysis systems, the provision of integrated IT solutions to businesses and the creation of sales campaigns based on personalized messages on mobile phones.

Our Company conducts its business activities in accordance with the principles of privacy, applying ethical and responsible practices.

Applicable law sets out our standards for managing and protecting your Personal Data to provide you with the utmost security. These principles to ensure the protection of your personal information apply to all types of our activities that involve collecting and processing information about individuals, including, but not limited to, research, corporate support and data transfers.

Indicatively, this Policy applies to:

  1. Corporate support: recruiting, managing and compensating employees / conducting assessments of employee performance and talent / providing training / managing ethical and privacy issues / managing and securing our assets and infrastructure / sourcing and paying for products and services / fulfilling our environmental, health and safety commitments / communicating with the media.

  1. Online presence: for the use of our website www.conartia.com, with the mechanisms and characteristics described in the relevant chapter below, related to privacy.

This Policy applies to all natural persons whose data we process. Accordingly, each employee of the Company, and third parties who process data about our company, are responsible for understanding and complying with their obligations under this Policy and existing laws.


 

Principles followed

The privacy principles described below summarize the standards and basic conditions for the collection and processing of individuals' personal data by our company. Personal data: (a) are processed lawfully and fairly in a transparent manner in relation to the data subject ('lawfulness, objectivity and transparency'), (b) are collected for specified, explicit and legitimate purposes and are not further processed in a manner incompatible with those purposes ('purpose limitation'), (c) are appropriate, relevant and limited to what is necessary for the purposes for which they are processed (d) it is accurate and, where necessary, it is kept up to date ('accuracy'), (e) it is kept in a form that allows the identification of the data subjects only for the time necessary for the purposes of the processing of the personal data ('limitation of the storage period'), (f) it is processed in a way that ensures the appropriate security of the personal data, including its protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by using appropriate technical or organisational measures ('integrity and confidentiality').


 

  1. Legality, Objectivity and Transparency

We do not process Personal Data in ways that are unfair to the individuals to whom the data relates. We determine whether the proposed collection, use or other form of processing of Personal Data constitutes a risk of actual or unspecified harm to individuals, always aiming to prevent them. If the nature of the data, the types of people or the activity involve an inherent risk of actual or unspecified harm, we ensure that this risk does not outweigh the corresponding benefits to those individuals. Where it is necessary to process Special Categories of Personal Data ("sensitive"), this is only done with the explicit consent of the individuals or as expressly required or permitted by applicable laws. We record the risk analysis and design any mechanisms required to obtain and record evidence of consent to assistive technologies. We do not process Personal Data in ways or purposes that are not transparent. All individuals whose Personal Data is processed in accordance with this Policy will have the right to a copy of this Policy, which is posted on our website. The Data Controller will provide digital and/or physical copies of this Policy upon request to the addresses listed below.

 

  1. Collecting data for specified, explicit and legitimate purposes

When Personal Data is collected directly from individuals, the

We inform through a prominent and easily accessible privacy notice or similar means by providing them with the following information:

-the identity and contact details of the controller

-the purposes of the processing

-if the processing is based on legitimate interests of the controller, what are those interests.

-the recipients of the personal data

-any data transfer

-the period of time for which the data will be stored

-the existence of a right to submit a request to the controller for access to and rectification or erasure of personal data or restriction of processing;

-where the processing is based on the consent of the subject, the existence of the right to withdraw his consent at any time, without affecting the lawfulness of the processing based on the consent before its withdrawal;

-the right to lodge a complaint with the Personal Data Protection Authority

- the legal nature of the benefit

-the possibility of automated decision-making

If new reasonable business purposes are identified for Personal Data that has already been collected, we ensure that either the new business purpose (including a substantially similar purpose) is compatible with the purpose as described in the privacy notice or other transparency mechanism previously provided to the individual, or we obtain the individual's consent for the new use of their Personal Data.

We are responsible for maintaining the security of the privacy of Personal Data when it is transferred from or to other organizations – businesses.

We transfer Personal Data or allow it to be processed by third parties only if the following conditions are met, for which we are responsible.

If the third party's role is to process Personal Data on behalf of or in pursuit of vital interests of the company, before the third party receives the Personal Data, we:

(a) we complete legal due diligence to assess the privacy practices and risks associated with these third parties;

(b) we attempt to obtain guarantees through a written agreement from these third parties that they will process Personal Data in accordance with our company's instructions, and in accordance with this Policy.

(c) We ensure that they inform us in a timely manner of any Security Incident and that they agree to cooperate when necessary.

(d) If the role of the third party is to provide Personal Data to our company, before we obtain the Personal Data from the third party, we ensure that the Transparency requirements for the collection of Personal Data from sources other than specifically under the supervision of our company are met, and we obtain guarantees through a written agreement from the third party that they do not violate any Law or the rights of any third party by providing Personal Data to our company.

(e) If the role of the third party is to receive data from our company for processing that is not specifically under our company's supervision, before we hand over the data to the third party, we ensure that the third party will only use the data for the business purposes set out in the agreement and in accordance with existing legislation.

  1. Necessity – minimization of data – limitation of storage period

Prior to collecting, using, or distributing Personal Data, we determine and record the specific, legitimate business purpose served. We determine and record the length of time for which Personal Data is used for the specified business purposes, which is defined on a case-by-case basis depending on the nature and type of activity. We do not collect, use, or share more Personal Data than necessary, and we do not retain Personal Data in an identifiable form for longer than is necessary for the specified business purposes. We anonymize data when operational or legal requirements make it necessary, and when information about the activity or process is required to be withheld for a longer period of time. We ensure that these necessary requirements have been incorporated into any assistive technologies and that third parties supporting the activity or processing have been informed.

We retain your Personal Data for as long as necessary to fulfill the purposes set out in this Privacy Policy, unless a longer retention period is required by applicable law. Your Personal Data related to product purchases is retained for a longer period in order to comply with our legal obligations, tax and commercial laws and for warranty purposes. At the end of this retention period, your data will be completely deleted or anonymized, for example by aggregating it with other data, so that it can be used in an unidentifiable manner for statistical analysis and business planning. If your order included a warranty, the relevant personal data will be retained until the end of the warranty period.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorized a third party to make a request on your behalf, we will ask them to demonstrate that they have your permission to act for this purpose.


 

  1. Data Accuracy, Integrity, and Confidentiality

We keep Personal Data accurate, integral and up-to-date and in accordance with its desired use. We ensure that periodic data review mechanisms are integrated into supporting technologies to validate the accuracy of the data. We ensure that Sensitive Data is validated as accurate and up-to-date before it is used, evaluated, analyzed, reported or otherwise processed, which carries the risk of injustice to individuals if inaccurate or outdated data is used. In the event of a change in Personal Data, the subject bears the responsibility to inform our company so that necessary modifications can be made. We incorporate safeguards to protect Personal Data and Sensitive Data. We have implemented a comprehensive information security program and security controls based on the sensitivity of information and the magnitude of the risk of the activity, using the best practices of modern technology. Policies to protect against loss, misuse, unauthorized access, disclosure or destruction include, but are not limited to, business continuity and disaster recovery standards, identity and access management, information classification, information security incident management, network access control, physical security and risk management.

We clarify that the provision of Data to our Company may be necessary to achieve the purposes specified in this Privacy Policy or be optional. If you refuse to provide the data marked as mandatory, it will be impossible to achieve the main purpose of collecting the specific Data, and may, for example, make it impossible for our Company to fulfill the sales contract or provide the other services available. The provision of additional Data to our Company, in addition to those marked as mandatory, is optional and does not entail consequences regarding the main purposes of data collection, but their provision serves to optimize the quality of the services provided.

You may also be asked for copies of the documents you provide to prove your age or identity when required by law (such as a copy of a police or student ID). For example, these copies may include details of your full name, address, date of birth and facial image (photo). If you provide a passport, the data will also include your place of birth, gender and nationality. Remember, if you choose not to share the Data with us or refuse certain communication rights, we may not be able to provide some services you have requested. For example, if you have asked us to let you know when a product is back available, we cannot serve you if you have withdrawn your general consent to receive updates from us.

Our Company processes your Data in order to fulfill its contractual relationship, to process the order of products and/or services, to provide customer service services, to comply with legal obligations, to contest, raise or exercise legal claims. If we do not collect your Data at the completion of the order either from our physical stores or from our online store, we will not be able to process your order and comply with our legal obligations. It may be necessary for your Data to be transferred to third parties for the supply or delivery of the product or service you have ordered. In addition, we may retain your Data for a reasonable period of time in order to fulfill our contractual obligations, such as product returns, as provided for by relevant legislation.

Our Company uses your Data to respond to your requests/queries, refund requests and/or complaints. The information you share with us enables us to manage your requests and respond to you in the best possible way. We may also keep a record of your enquiries/requests to us in order to better respond to any future communications. We do this based on our contractual obligations to you, our legal obligations and our legitimate interests in order to provide you with the best possible service and to be able to improve our services based on your own personal experience.

Rights of Data Subjects (Access, Rectification, Deletion, Portability, Restriction of Processing and Objection to Processing)

– You have the right to access your personal data. This means that you have the right to be informed by us if we process your Data. If we process your Data, you can request to be informed about the purpose of the processing, the type of your Data we keep, to whom we give it, how long we store it, whether automated decision-making takes place, but also about your other rights, such as rectification, deletion of data, restriction of processing and filing a complaint with the Personal Data Protection Authority.

– You have the right to have inaccurate personal data corrected. If you find that there is an error in your Data, you can submit a request to us to correct it (e.g. correct a name or update a change of address).

– You have the right to erasure / right to be forgotten. You can ask us to delete your data if it is no longer necessary for the above-mentioned processing purposes.

– You have the right to portability of your Data. You can ask us to receive the Data you have provided in a readable form or ask us to transmit it to another controller.

– You have the right to restrict processing. You can ask us to restrict the processing of your Data for as long as the examination of your objections to the processing is pending.

– You have the right to object to the processing of your Data. You can object to the processing of your Data or withdraw your consent and we will stop processing your Data, unless there are other compelling and legitimate reasons that override your right. To exercise your rights you can send us a relevant request,  describing the right you wish to exercise either at the Company's postal address (DA11/OT40 Industrial Area of Thessaloniki 57022 SINDOS) with the indication "Exercising the right of access/ correction/ correction/ deletion/ restriction/ objection", or through the contact form that you will find on our website (https://www.conartia.com), entitled "Exercising the right of access/ correction/ deletion/ restriction/ objection", with a description of your request and we will make sure to examine it and respond to you as soon as possible. We respond to your requests free of charge without delay, and in any case within one (1) month from the date we receive your request. However, if your request is complex or there is a large number of your requests, we will inform you within the month if we need to receive an extension of another two (2) months, within which we will respond to you. If your requests are manifestly unfounded or excessive, especially due to their repetitive nature, CONARTIA EE may impose the payment of a reasonable fee, taking into account the administrative costs for providing the information or performing the requested action, or refuse to follow up on the request. You have the right to lodge a complaint with the Personal Data Protection Authority (postal address 1-3 Kifissias Street, Athens / www.dpa.gr), if you consider that the processing of your Personal Data violates the applicable national and regulatory legal framework for the protection of personal data.


 

Use of Website

Below we will inform you about the way and purposes for which we manage your personal data on the above-mentioned website of our company. The controller of the management of personal data is "CONARTIA EE Information Technology Design and Development Services for Applications No. G.E.MI. 156752306000, A.T.M. 801434557, DA11/OT40 DI.PE.Thessaloniki Street, 57022 Sindos with the distinctive title "CONARTIA".

This website uses the SSL (Secure Sockets Layer) protocol which uses methods of encrypting the data exchanged between two devices (most commonly Computers), establishing a secure connection between them, via the internet, which results in the protection of your personal data, as well as other sensitive data (e.g. orders or surveys of the controller). You can recognize that you are in a secure connection by seeing the characters https:// and by the lock symbol that appears in the address bar of your browser.

A) Data Collection

When you visit the website only for information, i.e. you do not provide any of your personal data (e.g. contact form), then the only data we collect are those that your browser transfers to our server, the so-called server log files, and specifically:

· Date and time at the time of entry into the website.

· The amount of data sent in bytes.

· The browser you used when you entered the website.

· The operating system you used when you entered the website.

· Your IP address (Internet Protocol address) when you enter the website.


 

The processing of data is carried out in accordance with article 6 par. 1 par. f' of the General Data Protection Regulation (GDPR) based on our legitimate interest in improving the stability and functionality of our website. The data will not be transferred or used in any other way. However, we reserve the right to check the server log files, if specific indications of illegal use are found.


 

Β) Cookies

Cookies are small text files that are sent to your device when you visit a website. Cookies are then sent to the originating website on each subsequent visit or to another website that recognises this cookie. Cookies act as memory on a web page, allowing that web page to remember your device on your next visits. Cookies can also remember your preferences, improve your user experience, and tailor the ads you see to match what interests you. For more information about cookies, including how to see the cookies set on your device and how to manage and delete them, visit www.aboutcookies.org website.

Types of Cookies

– Temporary and persistent cookies. We may use temporary cookies, which exist until you close your browser. We may use persistent cookies, which are kept for a longer period of time.

– Third-party cookies. Our website may allow the installation of third-party cookies that appear on our website. These third-party cookies are not under our control. For further information about their use, you can visit the relevant third-party website for further information. Details about potential third-party cookies are presented in the table below.

– Cookies used on this website.

Below is a summary of the cookies used on our website.

Name Cookie Login Session cookie

Purpose Necessary for the user's browsing

Termination Upon leaving the website, it is deleted

Google Analytics and Google Tag Manager cookie name

Purpose: Record statistics for the website

More information at the link

https://policies.google.com/technologies/types

You can set your browser in such a way that you are informed about the setting of cookies, and you can either decide individually or as a whole, or block the acceptance of cookies in certain cases. Each browser differs depending on how it manages its cookie settings. This is described in each browser's help menu, which explains how you can change your cookie settings. Follow the links below depending on the browser you are using:

Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Firefox: https://www.mozilla.org/en-US/privacy/websites/#cookies

Chrome:https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en

Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Opera: https://help.opera.com/Windows/10.20/en/cookies.html

Please note that the operation of our website may be limited if cookies are not accepted.

C) Contact form

In the context of the communication between us (e.g. through the contact form or e-mail), personal data is collected. The data collected in this case is exactly what you fill in the specific form. This data is stored and used exclusively for the response to your request or for contact and technical management by us. The legal basis for the processing of this personal data is our legitimate interest in responding to your request, which is applicable to Article 6 par. 1 of the General Data Protection Regulation (GDPR). If the communication is aimed at concluding a contract between us, then the additional legal basis is based on Article 6 par. 1 par. b of the General Data Protection Regulation (GDPR). Your data will be deleted after the final processing of our communication. This will happen if the circumstances can show that the communication has been completed, provided that there are no legal claims to store this data.

Changes to this Policy

This Policy may be revised from time to time, in accordance with the requirements of existing legislation. Our company is constantly expanding, updating and improving its website and will update this policy accordingly. We recommend that you read this process at regular intervals in order to be informed of any changes to the content of this privacy policy. This policy will be amended from time to time without prior notice to users.


 

General Terms

The applicable Law is the Greek Law, as formulated in accordance with the General Data Protection Regulation 2016/679/EU, and in general the applicable national and European legislative and regulatory framework for the protection of personal data.

The competent courts for any disputes arising in relation to your Data are the Courts of Thessaloniki.

In order to exercise your rights, you can submit a relevant request to the Data Protection Officer Mr. Baba Dimitrios contact email dimitrios.bampas@conartia.com

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Nov 2020

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Conartia

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