PRIVACY AND PROTECTION OF PERSONAL DATA POLICY
I. General Provisions for the Protection of Personal Data
1.Who is responsible for your data – Where do you go to exercise your rights?
Responsible for Processing your Data is the law firm with the name “KOUMENTAKIS KE SYNERGATES” , based in Thessaloniki ( Morgendau 1) and legally represented, with telephone center 2310 278084 and contact e-mail [email protected] (hereinafter “the Company”), to which you can address all requests for exercise of below (under 3.1-3.7.) of your rights.
2. General principles observed by the Company regarding transparent information and data protection
2.1. Any information we give you with this document and any information you may request from us in the future is provided free of charge provided that the request is not repeated, excessive or manifestly unjustified (see more in 2.3.)
2.2. For each of the above rights that you exercise, the Company will respond to you within one (1) month of receiving the request or in case of objective difficulty, complexity of the request or the number of requests, the Company will respond to the maximum period in total three (3) months regarding either the termination of your request or the justified refusal to perform what you requested for legal reasons expressly specified in the General Regulation 679/2016.
2.3. In the event that the Company deems that any of your above rights are manifestly unfounded or the request is excessive or (much more) repetitive, it is entitled on the one hand to charge you with a reasonable fee for providing further information (which is in principle free) and on the other hand to refuse to follow through on the request.
2.4. In the event that the Company has reasonable doubts about your identity when you submit a request to exercise any of your above rights, it may request the provision of additional information necessary to confirm your identity before processing the request.
2.5. In the event that the Company delays beyond the justified period to respond to your request as well as in any case where you consider that your rights are violated or the Company is not consistent with its obligations to keep your data, you have the right to file a complaint with the supervisory authority, which for Greece is: Personal Data Authority, Athens Kifisias 1-3, P.O. 115 23, Athens, [email protected] , +30-210 6475600.
2.6. You reserve the right to revoke your (if any) provided consent at any time by submitting a relevant document of your request to the e-mail address [email protected] (see above under 1).
3. What are your Rights in relation to the Personal Data you have provided to us?
- Right to Information
You reserve the right to request information about the personal data we received from you and keep for one or more purposes as described below under A to D. This text as a whole is a manual of basic information and understanding of the philosophy of the regulatory framework that governs the protection of your personal data. Updates, deepening and clarifications in this text can be given to you after submitting a relevant request to exercise the right to information (see how under 1).
- Right of Access
You retain the right to request from our Company access to your data which we retain and confirmation in relation to whether it is being processed, and more specifically information regarding the purposes of processing, the categories of personal data, the recipients or categories of recipients, the period of retention and processing, the existence of the right to complain to the Personal Data Protection Authority, any available information about the origin of the data when it has not been made available by you, as well as a copy of the personal data that held and processed (see how under 1).
- Right of Correction
You reserve the right to request from our Company the correction of your data in the event that any element for which we have the right to process has been changed or has been entered incorrectly (see how under 1).
- Right to Erasure
You reserve the right to request from our Company complete or partial deletion of your data which we have the right to keep and process, either because they are no longer necessary to fulfill the purposes for which they were collected, or because you revoke your consent, or because the data was collected for a purpose that you consider unlawful. Our Company, in a reasonable time (no longer than one month and under conditions if there is a difficulty no longer than three months in total) will respond to you confirming the total or partial deletion of your data respectively or regarding the impossibility of deleting specific data if any law or the fulfillment of a duty in the public interest, or the right to freedom of expression and information or the exercise or support of a legal claim requires their retention. In this case, you have the possibility of filing a complaint with the supervisory authority on the one hand, and on the other hand of bringing legal action (see how under 1).
- Right of Limitation
You reserve the right to request from our Company a limitation of the processing of your data, quantitatively, temporally or with regard to the purpose of processing them and more specifically (a) either because you dispute the accuracy of your data and for as long as it takes the Company to confirm their accuracy, (b) either because you consider the processing illegal but instead of deletion you choose restriction (c) or because their use by the Company is no longer necessary but you do not wish to delete them as their retention will serve you for a legal claim, (d) either in the event that you object to the processing of the data and until it is verified whether your rights as a Subject prevail over the Company’s legitimate processing grounds (see how under 1) .
- Right to Portability
You retain the right to receive the personal data you have provided to us in a structured commonly used and machine-readable format as well as the right to further transmit it without objection, as long as your data is processed on the basis of consent. In the context of exercising this right, you also have the possibility to request direct transmission from the Company to the third party without your own mediation.
This right is exercised subject to the limitations of the right to erasure (see above under 3.4.) and its exercise cannot adversely affect the rights and freedoms of others (see how under 1).
- Right to Object
You retain the right to object to the use of your personal data for the purpose of direct marketing (see how under 1). Especially with regard to our Company’s newsletters , you have the right to request your deletion from the relevant list of recipients, by sending a relevant request to the email address [email protected] .
4. Can your data be forwarded somewhere else?
Your data is not intended to be the subject of transmission to any organization outside the Company with the exception of (a) our Company’s electronic systems and network support service providers – and for the sole purpose of their performance of the contract to support our Company , (b) the competent tax authorities in the context of our mandatory compliance with tax legislation and to the extent (and subject to the condition) that this is required, and (c) specifically in the context of the case handling mandate and in measure that this is necessary (see below under II A)
- to the competent judicial and/or public and/or administrative authorities and services (indicative: land registry, mortgage office, tax office, etc.), and
- to any partners and cooperating services (indicative: postal services, subcontractors – cooperating lawyers, accountants, etc.) following a relevant (between them and the Company) contract exclusively for the purpose of fulfilling their relevant contract with our Company and/or to the completion of your order (e.g. courier ), to the extent that this is necessary, and with strict contractual conditions of confidentiality by all involved.
5. Warranties
We assure you that the Company will exhaust every technical and organizational Data protection measure and will only make the optimal, minimal and absolutely necessary use and processing of the Data as defined by the law and strictly and exclusively for the purpose for which you have made it available to us.
II. Special provisions for the individual categories of Personal Data Subjects that coincide cumulatively with the above general provisions of the Policy
(A) RECIPIENTS OF COMMUNICATION
A.1. Data: The e-mail address of customers, potential customers, their legal representatives and executives, and in general the Company’s partners, who make up the list of newsletter recipients .
A.2. Purpose : The processing and retention of your above data provided in the context of any transaction and provision or potential provision of legal services by us, is (and) to satisfy the purpose of informing you about recent legislative developments, as well as for information about the Company’s services and actions.
A.2. Legal basis for processing : The legal basis for the processing of your data is the promotion of the legitimate interest of both the Company to maintain contact with its network and yours to receive immediate information on current legal issues, services and actions of the Company, according to article 6 par. 1f of Regulation 679/2016 and in accordance with the provisions of no . 11 par. 3 n. 3471/2006, always maintaining the possibility for you to submit a request for immediate deletion.
A.3. Data Retention Time : In order to fulfill the above processing purpose, i.e. to inform you about current legislative changes, our services and actions we consider a reasonable and necessary time to retain your relevant data, as long as we are able to offer this information service , provided that you have not in the meantime objected to receiving the update.
(B) CUSTOMERS and EXISTING CUSTOMERS
B.1. Purpose – Legal Basis:
(a) during the pre-contractual stage and especially in the case of filling out an electronic contact form on our website or sending an email or phone call directly (at a minimum and completely indicative: name, email address and/or telephone and/or address and/or status or / and other information that you may want to make available to us), the purpose is to investigate the possibility of your transaction (or the legal entity that you represent or on whose account you come into contact with our Company) with the Company and on a legal basis the service of the legitimate interest of the Company to pursue its statutory purposes by responding to the requested communication to investigate the possibility of entrusting the handling of a case to our Company.
(b) In the event that you choose to provide an order to handle your case (i.e. if a transaction takes place) to the Company, your Data that you have provided to us pre-contractually (as well as that which you will provide to us as part of the order) will be processed for the purpose of implementation of the relationship (contract) mandate between us but also of our compliance with tax legislation and the Lawyers Code. In this case, the legal basis for the processing is the execution of the contract for the handling of your case as well as our compliance with the legislation ( art . 6 para. 1b and 1c of the Regulation on the Protection of Personal Data, in combination with the provisions on the mandate of the Lawyers’ Code ).
B.2. Data Retention Time:
(a) We will keep the above data under B.1.(a) for three (3) years and then we will delete them subject to the previous article regarding the email address.
(b) With regard to the above under B.1.(b) data will be kept for as long as necessary by tax legislation. However, the documents and other documents of any nature that are intellectual work products of the Company will be preserved indefinitely , despite the revocation of the order by you.
(C) VISITORS TO THE COMPANY’S FACILITIES
C.1. Purpose – Legal Basis:
In the context of defending the rights of the people who are in the Company’s premises (indicative: customers, other employees, external partners etc. ) but also of safeguarding the property and the interests of the Company, closed circuit television (CCTV) operates which records (only image and not sound) on a continuous basis the movement that takes place in the corridor of the entrance of the Company’s headquarters. The observance of the above data (the image of the visitors) takes place in order to safeguard the legal interests of the Company, which are identified with ensuring the safety of people and material objects (indicative building facilities, equipment, customer case files, etc. .) located at the Company’s premises.
C.2. Legitimate Processing Base:
The legitimate basis for the processing of your data is the Company’s legitimate interest in ensuring the protection, indicatively and among others, of the persons who are in the company’s premises, as well as the building facilities, the case files (: customer data) and in general of the Company’s equipment, according to article 6 par. 1 element f of the Regulation on the protection of personal data.
C.3 Data Retention Time:
For the fulfillment of the purpose of processing which concerns the safety and protection of both the persons who are in the company’s facilities (e.g. employees, visitors, customers) as well as the data files and the company’s equipment in general (indicative of building, electronic, etc. ) we consider a period of fifteen (15) days to be reasonable and necessary for the retention of your relevant data. After the lapse of fifteen (15) days from the time you entered the Company’s facilities, the relevant file with the image files will be deleted.
(D) CANDIDATE EMPLOYEES:
D.1. Purpose: The evaluation of your possibility of employment by the Company.
D.2. Legal basis for processing: For the data you have provided us in the context of the evaluation of your possibility of employment by the Company, the legal basis is your consent according to Art . 6 par.1 a of the Regulation.
D.3. Data Retention Time: In order to fulfill the purpose of processing related to the investigation of the occupation of a certain job position in our company, we consider a reasonable and necessary time to retain your relevant data in the period of twelve (12) months. After twelve (12) months have passed from the time your resume was received (and if you have not become our partner) the relevant file with all your information will be deleted.