VERBENA TRADE & TOURISTIC ENTERPISES SINGLE MEMBER PUBLIC COMPANY, a single member public company based at 25, November 17 str., Aharnes, Attica, Greece, organized and existing under the laws of the Hellenic Republic, herein after mentioned as the Company, having regard to:
Ι. the provisions of Law 2472/1997 for the Protection of Persons from Personal Data Processing, as this law stands after amendments,
ΙΙ. the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (G.D.P.R.), with direct and binding effect from May 25, 2018 onwards,
ΙΙΙ. its declared will to protect the personal data of all the natural person interacting with the Company, as well as its obligation to comply with the provisions of standing legislation on personal data protection,
informs you that the purpose of this Policy is to display in a concise manner the basic principles and concepts of the legislation in force from May 25, 2018 AND to notify for the framework within the Company processes personal data.
1. The General Data Protection Regulation
1.1 The G.D.P.R. provisions apply to the processing of personal data in the context of the activities of an establishment of a controller or a processor in the Union, regardless of whether the processing takes place in the Union or not. The G.D.P.R. provisions apply also to the processing of personal data of data subjects who are in the Union by a controller or processor not established in the Union, where the processing activities are related to: (a) the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or (b) the monitoring of their behavior as far as their behavior takes place within the Union.
1.2 “Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.3 “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.4 “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
1.5 “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
2. Processing Purposes
Processing activity of your personal data, known to the Company after your actions, is carried out by the Company, according to G.D.P.R. provisions, for the following purposes:
a) for the accomplishment/execution of your trade affairs with the Company, including, but not limited to, service delivery, communication and information exchange before, during and after trade transactions, issue of any kind of tax documents and returns or invoices,
b) for your identification in case you submit a complaint or a request to the Company, as well as for the Company’s facilitation to handle and to answer your complaint or request,
c) for your information and supply with promotional and advertising material, printed or electronic, concerning Company’s commercial activities.
3. Lawfulness and bases of processing
3.1 Processing activity of your personal data, known to the Company after your actions, is carried out by the Company, according to G.D.P.R. provisions, following your consent and/or for the performance of a trade agreement regulating your trade relationship with the Company, in order for the Company to be able to identify you as its counterparty, to execute your order, to issue all invoices or tax documents and to communicate with you before, during and after the term of your trade relationship with the Company,
3.2 In relation with the above, the Company further notifies you that in the latter case, providing the Company with your personal data you enables your trade relationship with the Company to take place. Your denial to provide your personal data to the Company and to consent to their processing by the Company will result in the Company’s inability to identify you as a customer and to proceed to a trade relationship with you.
4. Rights of data subject
4.1 Notwithstanding any special G.D.P.R provisions, processing activity of your personal data, known to the Company after your actions, carried out by the Company, according to G.D.P.R. provisions, DOES NOT CANCEL your right to submit to the Company a request concerning information, access, rectification or erasure of the personal data you have provided to the Company or your right to submit to the Company a request to restrict or even to oppose processing of your personal data by the Company. Your request should be clear and straightforward in order for the Company to be able to ensure the certainty of your identity as well as acknowledge the meaning of its content. Additionally, your request should be submitted to the Company in writing and in such a manner to ensure the certainty of the submission date.
4.2 If the above mentioned conditions about the submission of your request are met, the Company shall provide you with all necessary information, without any delay and at the latest within one (1) month of the receipt of your request. This period may be extended by two (2) further months where necessary, taking into account the complexity and number of the requests. The Company shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, the information shall be provided to you by electronic means where possible, unless you requested otherwise.
4.3 If the Company does not take action on your request, the Company shall inform you without delay and at the latest within one (1) month of receipt of the request, of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy. Information provided to you by the Company shall be provided free of charge. In case, though, that your requests are manifestly unfounded or excessive, in particular because of their repetitive character, the Company may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on your requests.
The Company shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
5. Personal Data Retention
5.1 Notwithstanding any special G.D.P.R provisions, standing national laws, including the provisions of tax laws and regulations, your personal data provided to the Company shall be stored and retained by the Company for the term of your trade relationship with the Company and up until both parties’ obligations to one another are fulfilled.
5.2 After the termination of this period, the Company shall continue storage and retention of your personal data for more than a month’s period from the expiration of the time limit you shall have to exercise any right concerning Company’s services’ or products’ defects. Additionally, the Company shall continue storage and retention of your personal data for as long as court’s proceedings may last between you and the Company and up until an irrevocable court decision is issued over these proceedings.
5.3 Notwithstanding any special G.D.P.R provisions, standing national laws, including the provisions of tax laws and regulations in which case the retention period is set to ten (10) years, the termination of the above mentioned retention periods shall be followed by the destruction or erasure of your personal data. You shall also have the option of delivery of your personal data by the Company to you only in a manner that you will specify after a written communication with the Company.
6. Transfer of Personal Data
The Company is obliged to inform you on its intention to transfer your personal data to a third country or an international organization, as well as for the existence or the absence of an adequacy decision of the European Commission or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), to inform you about the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.
7.1 You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
7.2 You can withdraw your consent by submitting a clear and straightforward request in order for the Company to be able to ensure the certainty of your identity as well as acknowledge the meaning of its content. Additionally, your request should be submitted to the Company in writing and in such a manner to ensure the certainty of the submission date. You should be aware though, that withdrawal may result in the consequences mentioned in term 3.
8. Article 22 G.D.P.D. provision
8.1 Article 22, par. 1 of the G.D.P.R. states that “…The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her…”. Article 22, par. 2 of the G.D.P.R. states that “…Paragraph 1 shall not apply if the decision: (a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; (b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or (c) is based on the data subject's explicit consent…”. Considering the above, when you provide your personal data to the Company based either on your consent and/or for the performance of a trade agreement regulating your trade relationship with the Company, the Company reserves itself the right to decide for the execution of this trade agreement by analyzing and evaluating certain aspects such as the volume of previous transactions and your behavior and reliability as a buyer in these transactions.
8.2 When you provide your personal data to the Company in the context of a request or a complaint submission, the Company is committed to abide by the provision of Article 22, par. 1 of the G.D.P.R..
9. The Company as a Controller
9.1 In compliance with the provisions of the G.D.P.R., the Company shall be regarded as a Controller. Therefore any request you may have concerning your personal data should be addressed to the Company.
9.3 As already mentioned in term 4 of this Agreement, you have always the right to be informed by the Company for the actions that the Company has taken in order to Comply with standing legislation on data protection.
If any part of this Policy is for any reason found to be in contrast with the provisions of standing national or european legislation, it is only this part that should be considered as invalid and unenforceable.
11. Dispute Resolution
If any disagreement concerning the interpretation or the application of this Policy cannot be resolved with an amicable settlement or following the competent authority’s intervention or suggestion, this Policy shall for all purposes be governed by and interpreted in accordance with the laws of the Hellenic Republic and the Regulations of the European Union. In the latter case the dispute shall be settled by the competent Courts of the city of Athens.
Issues that are not addressed by this Policy are to be governed by and interpreted in accordance with the laws of the Hellenic Republic and the Regulations of the European Union.
Any failure by either party to strictly enforce any provision of this Policy will not be a waiver of that provision or any further default.
The Company reserves itself the right to modify this Policy whenever this is judged by the Company as necessary. Any amendment or modification of this Policy shall be posted on the Company’s website and shall be communicated with any appropriate means. You are advised to be regularly visit the Company’s website in order to be kept informed.
Your communication with the Company regarding your personal data that you have provided to the Company should be made at the Company’s responsible person for personal data.
What we collect
We may collect the following information:
- contact information including email address
- demographic information such as postcode, preferences and interests
- other information relevant to customer surveys and/or offers
For the exhaustive list of cookies we collect see the List of cookies we collect section.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
- if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by letting us know using our Contact Us information
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please email us this request using our Contact Us information.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.