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PRIVACY & PERSONAL DATA PROTECTION POLICY
This Privacy & Personal Data Protection Policy (hereinafter the "Policy") and the information contained therein concerns your personal information collected, processed and used by the Company and the measures taken to protect it, in the context of each of your possible interaction with the Company, including your visit to this website (hereinafter "Website").
The company responsible for processing is:
"COPHARM K. KOLETTIS & SIA OE" ("Company" or simply "We")
Headquarters: 143 N. Papagiannopoulou, Postal Code 19400 Thesi Kitsi, Koropi Attica
Tel.: 210 3468304 / E-mail: info@copharm.gr
We review this Policy regularly to ensure that it is always up-to-date and accurate and to conform to the requirements of applicable legislation. For this reason, please read carefully and check the Policy regularly so that your information is up to date.
1. WHEN AND HOW WE COLLECT YOUR PERSONAL DATA
The Company collects personal information:
• Directly from you, when:
- you send your CV to our Company or otherwise contact us to apply for a job,
- you are hired and work in our Company,
- you become our customer or supplier, either physically or through our Website;
- you represent, work or otherwise cooperate for our customers or suppliers;
- you visit our Website,
- register as a user on our Website by creating an account,
- subscribe to the list of recipients of our newsletters,
- you contact us in the context of an exhibition or other commercial event.
• From third parties, such as when one of our employees introduces you as a prospective employee, customer or supplier or otherwise as our partner, or e.g. when a customer or supplier asks us to make an offer to you or recommends you to supply us with a product or service or to work with you in another way.
• From publicly accessible sources, such as e.g. from business registers, reports, the internet, directories, etc.
2. PERSONAL DATA OF MINORS
We do not provide services directly to minors, nor do we collect their personal data.
3. WHAT TYPES OF DATA DO WE PROCESS
Depending on the subject and the purpose of the processing, the personal data we receive and process are in particular:
• For our employees and those who apply for work in our Company:
- identification information (surname, identity number, A.F.M., A.M.K.A.),
- contact details (full postal address, email address, telephone numbers),
- date and place of birth,
- bank account details,
- details of marital status, as well
- information related to degrees, professional qualifications, experience, recommendations, professional certifications, photos.
• For persons who are our suppliers, technicians or other consultants, lawyers, accountants and/or other service providers:
- full name,
- contact information (mailing address, email address, telephone numbers),
- VAT NUMBER. and other billing and payment information,
- capacity and/or job position.
• For persons who are our clients:
- full name,
- contact information (mailing address, email address, telephone numbers),
- VAT NUMBER. and other invoicing, payment and shipping/delivery information,
- capacity and/or job position.
• For visitors to our Website:
- information related to their IP addresses,
- date and time of connection to the Website,
- server response codes,
- call parameters of the https protocol (https response),
- URL address from which the Website is accessed,
- browser type,
- type of operating system you are using.
• For those who open an account through / registered users of the Website:
- full name,
- contact details (full postal address, email address, telephone numbers),
- profession,
- VAT NUMBER. and other billing and payment information.
• For persons who subscribe to the list of recipients of our newsletters, e-mail address.
4. WHY WE PROCESS YOUR PERSONAL DATA (PURPOSE & LEGAL BASIS)
Depending on the subject and case by case, the purpose of processing your data is:
• For our employees:
the fulfillment of our obligations as an employer in the context of the relevant employment contracts [based on art. 6 para. 1b΄ GDPR, because the processing is necessary for the execution of a contract between us] or
the Company's compliance with its legal obligations, e.g. tax record keeping, employee insurance, accident reporting, etc. [based on art. 6 para. 1c GDPR, because the processing is necessary to comply with our legal obligation]
• For those applying for a job at our Company:
the evaluation of your qualifications and ability to work for the Company, in the context of its need to employ employees and develop its activities [based on art. 6 para. 1f GDPR, because the processing is necessary for the purposes of our legitimate interests] or
the Company's compliance with its legal obligations, e.g. recruitment announcement [based on art. 6 para. 1c GDPR, because the processing is necessary to comply with our legal obligation]
• For persons who are our suppliers, technicians or other consultants, lawyers, accountants and/or other service providers:
the fulfillment of our obligations as a customer and/or recipient of your services in the context of the relevant contractual relationships and transactions [based on art. 6 para. 1b΄ GDPR, because the processing is necessary for the execution of a contract between us] or
the Company's compliance with its legal obligations, e.g. maintaining tax records, accepting invoices, receiving products, etc. [based on art. 6 para. 1c GDPR, because the processing is necessary to comply with our legal obligation]
• For persons who are our clients:
the fulfillment of our obligations as a supplier and/or service provider in the context of the relevant contractual relationships and transactions [based on art. 6 para. 1b΄ GDPR, because the processing is necessary for the execution of a contract between us] or
the Company's compliance with its legal obligations, e.g. maintaining tax records, issuing invoices, shipping and delivering products, etc. [based on art. 6 para. 1c GDPR, because the processing is necessary to comply with our legal obligation] or
the management of any complaints [based on art. 6 para. 1f GDPR, because the processing is necessary for the purposes of our legitimate interests]
• For visitors to our Website:
the connection to the Website, the execution of its basic functions and its correct and efficient operation (installation of necessary cookies / collection of information related to IP addresses) [based on art. 6 para. 1f GDPR, because the processing is necessary for the purposes of our legitimate interests] or
sending targeted advertisements, performing analytics to measure traffic and improve the Website, enabling content sharing, etc. (installation of optional cookies) [based on art. 6 para. 1a' GDPR, because you have consented to the processing]
• For those who open an account through / registered users of the Website:
the creation of a user account in our Company's online services, your identification as a natural person and the provision of the possibility of electronic submission and tracking of orders and making purchases [based on art. 6 par. 1b΄ GDPR, because the processing is necessary for the execution of a contract between us and art. 6 para. 1f GDPR, because the processing is necessary for the purposes of our legitimate interests]
• For persons who subscribe to the list of recipients of our newsletters:
sending our updates, promotional messages, offers, catalogues, etc. [based on art. 6 para. 1a' GDPR, because you have consented to the processing]
When processing is dictated to pursue our Company's legitimate interests, we do not process your data in the event that your interests override ours and we only use methods and technologies that are necessary and proportionate, which we apply in the least intrusive way and with appropriate means to balance your fundamental rights and freedoms as data subjects.
When the processing is based on your consent, you can at any time revoke it, in which case the Company will immediately stop processing your data, but without affecting the legality of the processing that was based on your consent until the moment of its revocation.
5. SPECIAL CATEGORIES OF DATA
We do not process special categories of personal data, unless this is necessary for or concerns the health of our employees, as is the case when someone is absent due to illness or accident, in which case they provide us with relevant medical notes, opinions, certificates, etc. This information, as a special category of personal data, is used in order for our Company to comply with its legal obligations in the field of labor law and social security law [based on art. 9 para. 2b' GDPR] and possibly forwarded to competent authorities (e.g. to report an accident, sick leave, etc.).
If we need to process any other data that constitutes a special category of data, including references to health data, racial origin, sex life, trade union activity, etc., this will be collected and processed lawfully by the Company and in the event that this is not required by law as above or is not required to protect their subject in an emergency situation [based on art. 9 para. 2c GDPR], we will obtain express consent before any processing [based on art. 9 para. 2a GDPR].
6. HOW LONG DO WE KEEP YOUR PERSONAL DATA
Your personal data is not kept by the Company for longer than is necessary for the purposes for which it is processed.
For as long as we keep your personal data, we apply appropriate technical and organizational measures in order to protect your rights as data subjects and to ensure their security and confidentiality.
When we process personal data based on your consent, the processing continues for as long as it remains valid and until revoked.
We generally retain your data for a maximum of one (1) year, unless retention is required for a longer period, until the statutory limitation period, by tax or other applicable legal provision or in support of legal claims by (or against ) Company.
7. HOW WE USE YOUR PERSONAL DATA – WHAT MEASURES WE TAKE TO SECURE AND PROTECT IT
• We do not collect more information than we need to fulfill the above purposes, only the data that is necessary for the respective processing purpose ("principle of minimization").
• We maintain an accurate and up-to-date database in a manner that reasonably ensures data security and protection against unauthorized or unlawful processing, accidental loss, destruction or damage and securely delete it when it is no longer necessary for the purposes of its processing.
• We restrict access to authorized persons only.
• We use appropriate technical and organizational measures already by design and by definition ("by design & by default") and specific encryption applications and other technological solutions and IT systems, to protect the integrity, security and availability of the personal data we process.
• In order to ensure the long-term protection of your data, technical security measures are monitored, regularly reviewed and updated and, if necessary, adapted to modern technological standards.
8. AUTOMATED DECISION MAKING AND PROFILING
The Company does not take into account your personal data for the purpose of profiling nor for automated decision-making.
9. WHO WE DISCLOSE YOUR DATA TO
As a rule, we do not share or transmit your personal data to third parties and only disclose them to authorized personnel of the Company.
When using the Website and as part of your registration as a user of the Company's electronic services, your data is stored on servers in Greece and is not transmitted abroad.
If the transmission of personal data to a third country is required by law, the Company will only carry it out where there is an adequate level of protection of your rights and freedoms as data subjects or where there are guarantees, including the use of standard contractual clauses, that ensure the required protection of this data.
We may lawfully share your data with:
• competent authorities, if and to the extent that this is mandatory according to law (e.g. to tax authorities),
• service providers/external consultants (eg accountants, lawyers), to pursue our legitimate interests or to comply with our contractual obligations to you;
• transport companies, to fulfill our contractual obligations regarding the shipment and delivery of the products to you;
• banks / financial institutions, to manage your payments,
• staff of the company that provides technical support services for the Company's computer/computer system, if and to the extent that this is required for the provision of these services,
• staff of the company that has undertaken the management of the Website, who may need to have access to the lists of recipients of the Company's newsletters and to the extent that this is required for the provision of technical support and management services of the Website.
Where the Company relies on a third party processor to process personal data on its behalf, we select a partner that provides an adequate level and security measures and takes the necessary steps to ensure its compliance with such measures, committing to this with corresponding data processing agreements. The executors may not further process your personal data, unless we have expressly instructed them to do so, nor pass your personal data on to third parties.
10. FUTURE USE AND UPDATE
If in the future we need to process your personal data for a purpose other than that for which it was originally collected, we will inform you of this purpose and of any other relevant information, if this purpose is not compatible with the original one.
11. WHAT ARE YOUR RIGHTS
Under data protection law, when we process your personal data you have the right to:
• withdraw your consent and ask us to stop the processing, if the processing is based on your relevant consent (right to withdraw consent);
• ask us for information on the processing of your personal data or copies thereof (right of access),
• ask us to correct information that you consider to be inaccurate and/or complete information that you consider to be incomplete (right to rectification);
• ask us to delete your personal data in certain cases (e.g. if this data is no longer necessary for the processing purpose for which it was collected or otherwise processed / when there is a withdrawal of consent and no there is another legal basis for processing / if you object to the processing and there are no compelling and legitimate reasons for the processing / when there is illegal processing), then we will delete them, unless there is a legal obligation for us to process or the data must be kept with for the purpose of establishing, exercising or supporting the Company's legal claims (right of erasure),
• ask us to restrict the processing of your data in certain circumstances (eg when you dispute the accuracy of your data / pending a decision on your objections as to whether our legitimate reasons for processing override your reasons etc.) [right to restrict processing],
• object to the processing of your personal data, in cases where we process your data for direct marketing purposes, in which case we will stop processing them, and/or for the pursuit of the Company's legal interests, in which case we will stop processing, unless there are compelling and legitimate reasons that require the processing and override your rights and interests or if it is necessary to establish, exercise or support legal claims of the Company, which depends on the reason for which the processing is carried out (right to object to the processing ),
• request that we transfer the data you have given us to someone else or give it to you (right to data portability), if the data has been collected directly from you and we are processing it based on your consent or for the purpose of contracting; or of contract execution and processing is automated.
For any issue related to the processing of your personal data by the Company, as controller, and for assistance regarding the exercise of your above rights, you can contact us:
• by mail: 143 N. Papagiannopoulou, 19400 Thesi Kitsi, Koropi Attica
• by phone: 210 3468304
• via e-mail: info@copharm.gr
You can exercise your rights free of charge and we will respond within one month of receiving your request.
12. COMPLAINT OF INFRINGEMENT
In the event that you believe that the protection of your personal data has been violated, you can file a complaint with the Personal Data Protection Authority (APDPH/ 1-3 Kifisias Avenue, PO Box 115 23, Athens/ tel.: +30 210 6475600 / fax: + 30 210 6475628 / e-mail: contact@dpa.gr).
For the Authority's competence and how to submit a complaint, you can also visit its website (www.dpa.gr - My rights - Submit a complaint), where detailed information is available.