PROCOS S.A.
Α. Introduction
Procos S.A., with registered address at 56th klm. Of Old National Road Athens-Chalkida and G.E.MI. Registration number 013390917000 (hereby referred to as “Company”, “we”, “us”, “our”) is committed to protecting and respecting the privacy of its clients, prospective clients, suppliers, associates and visitors to its website (www.procosparty.com) and any other individual who contacts or associates with it (collectively each referred to as “user”, “you”, “your”).
This Policy together with our Cookie Statement and any other documents referred to herein, aims to provide you with all information regarding any processing of your personal data by our Company, as well as your rights as a data subject, in compliance with GDPR and Greek Law 4624/2019.
Please read the following carefully to understand our views and practices on when processing your personal data.
This version of our Privacy Policy was published in July 2018 and updated in September 2022.
Β. Personal data we collect from you and why
Our Company, acting as controller under the meaning of article 4 (7) of GDPR, collects and further processes personal data that you voluntarily provide us with, as well as data obtained from third parties (such as credit reference agencies and public information registries), that is necessary for our transactions, the communication between us and the persuit of the Company’s business activities and legitimate interests. In particular, we may collect personal data from you, for the purposes mentioned herebelow, when you visit our website www.procosparty.com and fill in any form, subscribe to our newsletter and/or brochures and put in an "enquiry" about one of our products, using our enquiry form, when you send us your resume to apply for a job posting, participate in a survey or contest that our Company may organize or submit requests, complaints, comments, reviews or interact with us on any matter via e-mail, phone or via the Social Media accounts of the Company (such as Facebook, Instagram etc.) or otherwise.
You are under no obligation to provide us with any information, but without it, we may not be able to offer our content, products or information you may request to you, or we may not be able to satisfy your specific request or query.
More specifically, we may collect, directly from you or from third parties, the following categories of data that concern you:
· Data related to the fulfillment of our tax and administrative obligations, such as identification documents, ΤIN number, payment method and other information.
C. Legal basis for processing
The legal basis for processing your personal data may be, per case, the following:
a) The fulfillment of our contractual and pre-contractual obligations (article 6(1), first section, case (b) of GDPR): It is necessary to provide us with the personal data required in order to prepare and carry-out the contractual relationship between us. Without this data, we are not able to process your request or to execute the contract between us;
b) The processing is necessary for the conclusion of an employment contract or, after the conclusion, for its execution (article 27 par. 1 of Law 4624/2019);
c) Compliance with the Company’s legal obligations (article 6(1), first section, case (c) of GDPR): If the required data is not provided to us, we may not be able to abide by our obligations under law;
d) The fulfillment of the legitimate interests of the Company or third parties (article 6 (1), first section, case (f) of GDPR); such legitimate interests include processing that allows us to improve our products, detect and prevent fraud, enhance the security of our network and information systems, run promotional campaigns and advertisements and check their effectiveness, provide postal communications that we believe are in your best interest;
e) Your consent (article 6(1), first section, case (a) of GDPR): If you have provided your consent for specific purposes, these purposes arise from the corresponding content of that consent. In cases where you have to provide data for this purpose, we will explicitly mention it to you. If this data is not provided to us, we will not be able to comply with your will, as set forth in your consent. You can withdraw your consent at any time, which, however, will not affect the lawfulness of the processing based on your consent before its withdrawal;
f) Your consent as an employee of the Company (article 27 par. 2 of Law 4624/2019), for specific purposes of processing arising from the content of the consent, which you can withdraw at any time, but without prejudice to the lawfulness of the processing based on your consent before its withdrawal;
g) In the cases of article 25 par. 1 of Law 4624/2019 ; namely to prevent threats to national security or public safety, to prosecute criminal offences, or to establish, exercise or support legal claims.
D. Data concerning minors
We do not knowingly collect personal data from minors under the age of 15. We do not sell products intended for purchase by minors and all minors' products that we sell are intended for purchase by adults only. If you are under the age of 15 and a minor in general, you are not authorized to use this site. In the remote event that any processing of personal data of minors under 15 years of age is required, such processing will be carried out only pursuant to the prior explicit consent of their legal representatives.
Ε. Purposes of processing
We process personal data that concern you for the following purposes:
1. Conclusion and execution of the Company’s contracts and in particular:
a) to communicate on any matter arising from our contract/transaction, especially for the preparation / processing / submission of tenders, the processing of contracts concluded, the execution / delivery of an order, the confirmation of your details and your identification, in any case required, the answer to specific requests / questions / complaints that you direct to us, as well as your general service, promotion of products and services to you or third parties, for sending you our brochure or for subscribing to our newsletter;
b) for the collection of the consideration for our products or services and the issuance of the legally required documents, for the avoidance of property infringements (especially for the cases of fraud, theft, embezzlement), as well as for the assessment of your creditworthiness by receiving the corresponding information from credit bureaus;
c) for the defense of the legal rights and the exercise of the legal claims of the Company before judicial or other authorities;
d) for the fulfillment of the Company’s compliance obligations with domestic and foreign supervisory authorities;
e) to ensure the correctness and accuracy of the data, so that any transaction can be executed properly;
f) to communicate with you in case of an existing risk related to any products of our Company.
2. Promotion-Advertising-Creation of customer profile (marketing)
In particular, if you have provided your consent, the Company may process your data for the following purposes:
a) promotion of products and services to you or third parties;
b) conducting qualitative / quantitative research, and / or analysis;
c) understanding of visitors to our website in terms of their access to it and the content of the website that falls within their field of interest;
d) optimizing our online presence.
3. Other purposes
We process your personal data in order to comply with disclosure duties to the authorities and to comply with processing requirements as defined by commercial and tax legislation.
F. Data recipients
1. Exceptionally we may transmit your data to third parties, only for specific legal purpose
2. Recipients of your personal data, to whom it is disclosed are indicatively:
a) associates, such as companies that provide services in the fields of telecommunications, technical / IT support, advertising, printing, delivery/transportation companies etc., which act as processors under the meaning of article 4 (8) of GDPR and process your data on our behalf and subject to our instructions and mandates;
b) to a potential buyer (including its agents, representatives and advisers) in connection with a proposed purchase, merger or acquisition of any part of our business, provided that we have informed the buyer that it must use your personal information only for the purposes that are contained in this Privacy Policy;
c) to any competent law enforcement agency, regulatory, governmental body, court or other third party that we believe disclosure is necessary (i) pursuant to applicable law or regulation (ii) to exercise, establish, establish or defend our our legal rights or (iii) protect your vital interests or those of others;
d) service providers to whom the data is transmitted to process a request or to execute a contract with you or to safeguard legitimate interests, e.g. credit institutions, legal practitioners etc., or for promotional and advertising purposes, i.e. technology companies (i.e. Google) and social media companies (i.e. Facebook, Instagram);
e) public authorities or prosecutor and judicial authorities or tax and customs authorities to whom we are obliged to disclose personal data that concern you.
Besides the aforementioned persons, your personal data will not be further disclosed to third parties.
3. In case your data is disclosed to our third party associates, the Company will ensure that any processors acting on its behalf meet the conditions and provide sufficient assurances (guarantees) for the implementation of appropriate technical and organizational measures to ensure the protection of your personal data.
4. In addition we may transfer your personal data to suppliers or service providers established outside the European Economic Area (EEA). In such case transfer to a third country shall take place only if the conditions laid down in Chapter V GDPR are complied with by the controller and processor. Specifically, the transfer will take place on the basis of an adequacy decision by the EU Commission. In the absence of such decision any transfer will be based on one of the appropriate safeguards of art. 46 GDPR
G. Data retention period
We retain your personal data only for the duration necessary to achieve the purposes, as entailed in this document:
• Your newsletter subscription preference and email address -if your consent has been granted- until you withdraw your consent and in any event for no more than 2 years. At the end of this period we will ask for your consent again.
• Your cookies consent preferences are stored until you withdraw your consent but no more than 12 months. After this period, you will be prompted to renew your consent through our cookies consent banner.
• Your contact information you share with us through our contact forms in the “CONTACT” and “REQUEST A BROCHURE” sections is stored for 2 years , unless you ask us to delete it earlier.
Generally, we delete your personal data immediately, when the legal basis for its processing does no longer exist, if it is no longer necessary for the purpose of drafting and executing our contract and if no other special legal basis for processing exists, in case of objection on your part, unless further processing is permitted according to the relevant legal provisions, if we are obliged to do so for other legitimate reasons and in any case after the lawfully required retention period. It is especially pointed out that any CV that you may send us in order to apply for a job posting in the Company and is subject to par. 6 of article 27 of Law 4624/2019 is retained by the Company for a period of six (6) months from sending it to the Company, after which it is deleted.
In case retention of personal data is necessary for the exercise or defense of the Company’s legitimate rights before judicial or other authorities provided for under the applicable law, the above period is extended until the end of the period during which such data is no longer necessary for the above purposes.
Η. Communication with the Company and exercise of your rights
According to the applicable data protection legislation you have the following rights:
1. At any time, in accordance with Article 7 of GDPR, to withdraw your consent to the processing of your personal data, in cases where the processing takes place with your consent or, in case of processing of your personal data under employment relations, your consent according to article 27 par. 2 case (b) 4624/2019. of Law 4624/2019. In this case, any processing will cease, without this affecting the lawfulness of the processing based on your consent before withdrawal;
2. Without prejudice to the provisions of article 33 of Law 4624/2019, to request access to your personal data, according to article 15 of GDPR. Specifically, you can receive information regarding which personal data that concern you is or has been processed, its categories, the purposes for which we process it, its origin, the categories of recipients to which it is transmitted and the retention period. Upon request, the Company will provide you with a copy of your personal data being processed;
3. Without prejudice to the provisions of article 35 of Law 4624/2019, to object to the processing of data that concern you, according to article 21 of GDPR, at any time;
4. Without prejudice to the provisions of article 34 of Law 4624/2019, to request the deletion of your data, if it is no longer necessary for the purposes for which it is collected or otherwise processed, if you withdraw your consent on which the processing is based or if the personal data have been processed illegally (Article 17 of GDPR);
5. To request the correction of your personal data that we retain. This allows you to correct any incomplete or inaccurate information we have collected about you (Article 16 of GDPR);
6. To request the restriction on the processing of your personal data, only for specific purposes, including the case of contested accuracy of the data or illegal processing (Article 18 of GDPR);
7. You have the right to the portability of your personal data to another controller, provided that the processing is based on your consent and is carried out by automated means (Article 20 of GDPR);
8. To submit a report / complaint to the Hellenic Data Protection Authority, 1-3, Kifissias Avenue, PC 115 23, Athens, tel : +30 210 6475600, fax: +30 210 6475628, web portal of the Authority: dpa.gr, e-mail address: complaints@dpa.gr.
For the exercise of the above rights, as well as for the communication between us or for any questions regarding the processing of your personal data, you can contact us by using the postal address: PROCOS S.A., 56th klm. of Old National Road of Athens-Chalkida, Inofita Viotia, 32011, Greece, or the e-mail address: privacy@procos.gr, or by phone : +30 2262031434, or by fax: +30 2262030869, +30 2262030870.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
I. Company obligations
We use appropriate technical and organizational methods to protect the personal information we collect and process about you. The methods we use are designed to provide a level of security appropriate to the risk of processing your personal information.
K. Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
