2. DATA CONTROLLER
3. TYPE OF PERSONAL INFORMATION WE COLLECT
“Personal Data” means any information or data which relates to you or which identifies you (whether directly or indirectly) as a natural person. We only collect and process Personal Data that is necessary when engaging with our Company and for a specific purpose and/or when you use our services as a customer and/or necessary information for the adequate performance of our services to you, considering that without such information, we may not be able to provide you with all the services you have requested from us.
Generally, the following Personal Data are collected:
- Name and surname;
- Telephone number;
- Email address; and
- Any other information that you may provide to us which may be necessary for our legitimate business interests and/or to comply with applicable Law and/or to respond to your request or query.
4. USE OF PERSONAL DATA/INFORMATION
4.1. Necessary to Carry out our Business
We will only collect and process your Personal Data where we have a legal basis and/or a legitimate business interest to do so as a company in order to offer a service and to carry out our business, subject to the Data Protection Legislation. We will use and/or process your Personal Data for the following main purposes:
- To issue invoices and/or receipts to customers for services provided;
- To advertise our materials and/or services and/or to give you information about any of our new materials/services we offer (marketing communication). For further information in relation to Marketing Communication, please see paragraph 4.5. below.
- To process your transactions; and
- Respond to your questions and requests.
4.2. Legally Required or other Legitimate Business Interests
We may also process Personal Data to third parties if we are legally required to do so by Law or where we need to comply with our contractual duties, or for any other legitimate business purposes (always acting in good faith) for reasons which include the following:
- Where you have given your explicit consent for one or more specific purposes pursuant to the services offered to you;
- Necessary to use your information so that we can perform the agreement/contract we have with you;
- Necessary to protect the legitimate interests of the Company and/or to protect and defend the rights or property of the Company including any related entities/affiliates of the Company;
- Necessary for maintaining legal records, accounts, audit, security as required pursuant to the applicable Laws;
- To detect and prevent fraud, spam, abuse, security incidents and for the purposes of reporting potential crimes and other harmful activity; and
- Because you have otherwise consented for us to use your information for a particular purpose (i.e. marketing communications).
In any event, the Company would be available to clarify the specific legal basis that applies to the processing of your Personal Data and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement to enter into a contract/agreement with us, pursuant to our services offered to you.
4.3. Other Third Party Sharing of Personal Data/Information
We do not sell, lease, rent or otherwise disclose your Personal Data to third parties unless otherwise stated below:
- Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment;
- Legal and other professional legal advisers required to enforce or apply any contract with you (where applicable and/or required); and
- Trusted third party service providers assisting our Company with executing its services successfully (i.e. suppliers, contractors etc.).
4.5. Marketing Communications
Subject to obtaining your explicit consent, we use your Personal Data for marketing purposes in order to notify you of our services, promotions and offers.
You can change your mind from receiving any marketing communications and/or change what marketing communications you receive. If you decide that you would no longer like to be sent marketing communications, you can withdraw your consent by contacting us in the contact details found in paragraph 10 below.
5. HOW WE SECURE YOUR PERSONAL DATA
PANTELIS PASHIAS CO. LIMITED takes appropriate security measures to prevent unauthorised access, disclosure, modification or unauthorized destruction of your Personal Data. We have implemented and follow strict security systems and procedures particularly in the storage and disclosure of your Personal Data, in order to protect it against unauthorized destruction, accidental loss, damage or unauthorised access by third parties. The Personal Data you provide us is protected using approved industry standard methods of encrypting personal information which includes the SSL CERTIFICATE and cookies analysis (paragraph 11). The SSL CERTIFICATE consists of a secure link between a website and a visitor's browser by ensuring that all data passed between the two remains private and secure while SSL encryption prevents hackers from stealing private information. The processing is carried out using IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated herein.
6. YOUR RIGHTS
Pursuant to the Data Protection Legislation, you have the right of access, rectification, restriction, data portability and erasure to your Personal Data as indicated below:
- Withdraw consent at any time: You have the right to withdraw your consent at any time, where you have previously given your consent to the processing of your Personal Data. Please note that such withdrawal of consent will not affect the lawfulness of the processing before we become aware that your consent was withdrawn.
- Access, verify and seek rectification: You have the right to access and correct inaccurate or incomplete Personal Data and/or update such Personal Data that we hold about you, but you do not have the right to access information relating to others who have not consented to the disclosure of their information.
- Data portability: You have the right to receive your Personal Data and have it transferred to another data controller. Therefore, upon request, you have the right to receive copies of your personal information that you have provided to us in a reasonably commonly used and machine-readable format subject to the request mechanism indicated in paragraph 10 below and request to transmit the said data to another data controller.
- Restrict processing of your Personal Data: You have the right to request the restriction of processing of your Personal Data, under certain circumstances.
- Have your Personal Data deleted or otherwise removed: As long as the Personal Data are no longer necessary in relation to the purposes for which they are collected or processed as further described in paragraph 4.1 and 4.2 above, you have the right to request erasure of personal information which identifies you. However, some identifying information would be required to be retained (pursuant to our retention period) and are not capable to be erased as this information will be needed to meet our obligations such as: pursuant to the Law, regulatory authorities and/or any legal proceedings.
- Object to processing of your Personal Data: Under certain circumstances, you have the right to object to the processing of your Personal Data, if the processing is carried out on a legal basis other than consent. However, your objection must provide a valid justifiable ground related to your particular situation specifically if the processing is related with the Company’s legitimate business interests.
- Right to Lodge a Complaint: If you would like to bring a claim or if you would like further information about your Personal Data you may contact us at: email@example.com.
Note that there is no Fee for this request. We ask that you please make clear what information and/or query you have about your Personal Data. For security purposes and for your protection, we may need you to verify your identity before implementing your request. You do not have the right to information relating to others who have not consented to the disclosure of their information and/or to information which is privileged and confidential.
Your request will be responded the soonest reasonably practicable, and in any case not longer than within 30 (thirty) calendar days. If your request is particularly complicated, we retain the right to extend our response to up to 3 (three) months depending on the complexity of the case.
7. DATA RETENTION
We will keep your Personal Data for a period necessary to fulfil our legitimate business interests and/or pursuant to the contractual obligation you may have with the Company (for example invoices and/or receipts for services rendered) and/or for any statutory or legal obligations and/or legal claims, pursuant to the applicable limitation period, where your Personal Data may be relevant to any possible liability we may have to you and to protect our legal rights. The Company may be allowed to retain Personal Data for a longer period subject to receiving your prior explicit consent to such processing and as long as you do not withdraw your consent (for example, for marketing communications).
8. TRANSFER OF PERSONAL DATA OUTSIDE THE EU/EEA
Where your personal information is transferred outside the EU/EEA to third party service providers (who provide services to us), we will do so while always ensuring that the appropriate and suitable safeguards have been obtained and/or implemented prior to us doing so, in order to ensure that your Personal Data continues to be adequately protected to the standards set out in the Data Protection Legislation. In addition, we require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with the Data Protection Legislation.
10. CONTACT US
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