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PRIVACY POLICY

Last Amendment 25/05/2018




1.         Introduction


The Website’s Privacy Policy governs the processing of Personal Data (“PD”) collected or provided by users through the Website.  The PD collected or provided by the users of the Website are processed in accordance with the applicable legislation on PD and the Website’s Privacy Policy.  The Company is entitled to revise and / or unilaterally update the Privacy Policy at any time and always in conformity with applicable legislation.


The Company does not guarantee that third-party websites links of which are included in the Website comply with the requirements of applicable legislation.  Use of these websites is made at the sole responsibility of the users, excluding any liability of the Company.


2.         Data Controller and Data Processor 


2.1
       The Company “SALFO AND ASSOCIATES S.A.” with General Commercial Registry number 117037201000 and Tax Identification number 095702185 is the data controller of Website users’ PD.  The Company determines the purposes and means of the processing of Website users’ PD.  The Company’s contact details are the following:


Address: 11 Vouliagmenis Avenue, GR 116 36, Athens, Greece
Telephone: +30 210 92 100 80 / Fax: +30 210 92 104 87
Email: info@salfo.gr


2.2
       The Company may assign to a natural or legal person the processing of Website users’ PD on behalf of the Company within the limits of the Privacy Policy.  In such cases, the Company uses processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of the General Data Protection Regulation and / or other applicable legislation and the relevant contracts with data processors shall meet the requirements of the General Data Protection Regulation and / or other applicable legislation.


3.         Data Protection Officer


The Company has appointed a Data Protection Officer whom Website users may contact regarding the processing of their PD.  Website Users may contact the Data Protection Officer through the following contact details:



Address: 11 Vouliagmenis Avenue, GR 116 36, Athens, Greece
Telephone: +30 210 92 100 80 / Fax: +30 210 92 104 87
Email: dpo@salfo.gr


4.         Purpose of Processing


4.1
       Website users’ PD are processed for explicit and legitimate purposes and are not further processed in a manner that is incompatible with those purposes.  In particular, Website users’ PD are processed for the purpose of responding to a requests of communication sent by email and / or the exercise of the rights of the Website users’ PD and / or the management and transmission of newsletters or / and the recruitment of employees.

4.2
       Within the above purposes, PD are provided by the users through a corresponding online form that requires only adequate and relevant PD, which are limited to what is necessary in relation to the purposes for which they are processed.


5.         Lawfulness of Processing


5.1      
In principle, the lawfulness of processing Website users’ PD by the Company or data processors on behalf of the Company is the consent of the Website users. When Website users provide PD, their consent is requested for the processing of their PD by the Company or a data processor on behalf of the Company, in an intelligible form and for one or more specific purposes and only for the period necessary for the purposes for which the personal data are processed.

5.2      
The data subject shall have the right to withdraw his or her consent at any time by following the link on the bottom of each newsletter and, in any other case, by email dpo@salfo.gr.

5.3
       The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 

5.4      
Users’ consent shall be retained by the Company so that it is able to demonstrate that the subject of the PD has consented to the processing of his or her personal data.  Users’ consent is retained by the Company for the period required for the purposes of the processing and no more than six (6) months from the date of fulfilment or expiration of the purpose of processing or the withdrawal of the consent of the subject of the PD. 

5.5      
In any case, even without the consent of the users, the Company or third parties on behalf of the Company may process users’ PD in all cases provided for in Articles 6 and 9 of the General Data Protection Regulation and / or other applicable legislation.


6.         Recipients of PD


6.1
       Recipients of PD collected from and / or provided by the Website’s users are the employees and agents of the Company.  Moreover, users’ PD may be disseminated or otherwise made available to branches and / or subsidiaries of the Company in the European Union and third countries and / or third parties which process personal data on behalf of the Company and / or professionals, independent consultants which provide to the Company services for the operation of the Website (e.g. IT services and Cloud Computing) and / or Public Authorities and / or organisations to the extent necessary for compliance with a legal obligation of the Company.
 
6.2     In the case of recipients outside the European Union, the dissemination or otherwise making available of PD shall be carried out in accordance with the provisions of the General Data Protection Regulation and / or other applicable legislation.


7.         Technical and Organisational Measures


Users' PD are processed using both electronic and printed form.  The Company makes every effort to ensure that the Website users’ PD are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.  The Website uses SSL (Secure Sockets Layer), a 128-bit encryption, for secure electronic communications.  This encrypts all users' PD entries so they cannot be read or modified when transferred in the Internet.


8.         PD  Storage


The Company keeps Website users’ PD only for the period necessary for the fulfilment of the purposes for which the PD were collected.  In particular, it maintains PD, in the case of a user’s request for communication, for a period reasonably necessary to respond to the request for communication but, in any case, no more than one (1) year from the submission of the request; in the case of the newsletter no more than six (6) months from the withdrawal of the user's relevant consent for receiving it; and in the case of a CV no more than two (2) years from the submission of the CV, unless the subject of the PD renews its consent  for another two (2) years and so forth.


9          Users’ Rights (Data Subjects’ Rights)


9.1
       Website users, as data subjects of the PD processed by the Company, as a Data Controller and / or a third party on behalf of the Company, as a Data Processor, have the following rights:


9.2
       The abovementioned right may be exercised by email to dpo@salfo.gr.

9.3
       The Website users, as data subjects, may additionaly file a complaint before the Hellenic Data Protection Authority (http://www.dpa.gr/).


10.       Applicable Law and Jurisdiction


Any dispute with respect to the implementation, interpretation, invalidity of the Terms of Use, the existence or non-existence of rights and obligations of users or the Company, under contract or tort, is governed by Greek law and is subject to the exclusive jurisdiction of the competent courts of Athens.