Personal Data Protection Policy
Last updated: 05/11/2021
Introduction
Through this “Policy on the Processing of Personal Data – Information Notice”, SUGARTIA SUGAR TRADE LTD. (hereinafter referred to as the “Company”) informs users/visitors of its website, or in general natural persons/data subjects, that in the context of its business activities it may collect and process personal data concerning them, provided that users/visitors provide such data to the Company.
In Appendix A of this Policy, the Company informs visitors/users of its premises about the processing of data carried out in relation to the video surveillance system installed in its outdoor areas.
The protection of personal data is governed by the principles of Regulation 679/2016 (GDPR) on the Protection of Personal Data and National Law 4624/2019.
Personal data we collect
The Company will collect and process only the personal data that is appropriate, relevant and necessary for each of the above processing purposes. Depending on the case, such data may include, in particular, identification or legalization details, such as full name, date and place of birth, identity card or passport details, etc.; contact details, such as address, landline or mobile phone number, email address; education/professional experience details; and any other information you may voluntarily provide to us. The Company will not process such data for any purpose other than the one for which it was collected.
Users/visitors are requested to disclose to the Company only the information/data requested through the contact form. If such information/data is not provided to the Company, it may not be possible to carry out and/or complete the action for which such data/information is requested.
The Company’s website is intended for an adult audience.
Purpose of Processing
The Company uses the data it collects exclusively for the following purposes:
- for communication purposes;
- in the context of submitting CVs for the filling of a specific position and their evaluation;
- for purposes of the Company’s compliance with its legal obligations, or in the context of other lawful purposes listed in Article 6(1) of the GDPR, such as where processing is necessary for the performance of a specific contract to which you are a party and/or in order to take steps at your request prior to entering into such contract, etc.
Period of processing of Personal Data
The storage and processing of the data of customers and users of our services is carried out exclusively and only as permitted by law or according to the explicit consent of users, only for as long as required in order to fulfil the purposes of processing, as defined above, or until the user objects to the use of Personal Data by the Company or withdraws their consent. However, where required by law, the Company will retain Personal Data for a longer period, or whenever Personal Data is required in order for the Company to assert or defend itself against legal claims.
Place of data processing
The Company’s registered office is located in Greece; therefore, all processing carried out at our premises takes place within Greek territory.
Disclosure/Transfer of data to other persons
Access to personal data collected and processed in accordance with this Policy will, in principle, be granted only to competent/authorized members of staff and/or members of corporate bodies of the Company, and only to the extent required within the framework of the aforementioned processing purposes.
Furthermore, the Company may, depending on the case, transfer such data to third parties, where and to the extent required for the fulfilment of the relevant processing purpose mentioned above, such as to its shareholder, consultants and/or partners in general, as well as to any kind of authorities, bodies, services, agencies and/or organizations, etc.
In the event that the Company intends to cooperate with other persons, where such cooperation involves the processing of personal data by those persons as processors on its behalf, those persons must comply with the national and EU legal framework on the protection of personal data and must sign an agreement with the Company governing the terms and conditions of the data processing carried out in that context, with the content required by the applicable provisions.
How to access and control your Personal Data
Users of the Company’s services may at any time request information from the Company regarding their Personal Data and may also request its correction or deletion. The Company may delete the data only if there is no legal obligation or other legitimate right to retain it. Naturally, if a user’s data is deleted, the Company will not be able to continue providing its services to that user where such services require the use of that data.
Users may also request that the Company restrict any processing of their Personal Data in the following cases:
- The Personal Data held by the Company is incorrect.
- The user does not agree with one of the above processing activities.
For any request or clarification required, users may contact the Company through the email addresses listed in the contact information, specifying the information or processing activities related to their request, as well as the form in which they wish to receive this information. The request will be carefully reviewed and we will discuss with the user the best way to fulfil it.
Cookies and Similar Technologies
The Company uses cookies, small text files placed on your device, as well as similar technologies and services that use the IP address for the provision of its web locations, mobile applications and electronic services. Detailed information about the cookies used on our website can be found in the Cookies Policy posted on this website.
Contact Information
The Data Controller is SUGARTIA SUGAR TRADE LTD., located at Parodos Sofokli Venizelou, Nea Menemeni, Thessaloniki, Postal Code 54628.
Contact telephone: 2310 552 255, email: info@sugartia.gr
The Company has appointed a Data Protection Officer (DPO), whom you may contact at the email address dpo@sugartia.gr.
Changes to this Policy
The Company may amend this Personal Data Protection Statement in order to reflect current personal data protection practices. When changes are made to this statement, the “Last updated” field at the top of this page will be updated. We encourage you to review this Personal Data Processing Policy periodically in order to stay informed about how the Company protects your data.
Questions about this Policy and its application
The Company is committed to protecting your personal data online. If you have any questions or comments regarding our management of your personal data, please contact us at the address and details mentioned above in the contact information.
APPENDIX A
Information on the processing of personal data through a video surveillance system (CCTV)
Data Controller: SUGARTIA SUGAR TRADE LTD.
Purpose of processing and legal basis
We use a surveillance system for the purpose of protecting persons and goods. Processing is necessary for the purposes of legitimate interests pursued by us as the data controller, Article 6(1)(f) GDPR.
Analysis of legitimate interests
Our legitimate interest consists of the need to protect our premises and the goods located therein from unlawful acts, such as theft, indicatively. The same applies to the safety of the life, physical integrity, health and property of our personnel and third parties lawfully present in the monitored area. We collect only image data and limit the recording to areas that we have assessed as having an increased likelihood of unlawful acts, such as theft, for example at our cash desks and entrance gates, without focusing on areas where the privacy of the persons whose image is captured may be excessively restricted, including their right to the protection of personal data.
Recipients
The recorded material is accessible only by our competent/authorized personnel responsible for the security of the premises. This material is not transferred to third parties, except in the following cases: a) to the competent judicial, prosecutorial and police authorities when it includes evidence necessary for the investigation of a criminal offence concerning persons or goods of the data controller; b) to the competent judicial, prosecutorial and police authorities when they lawfully request data in the performance of their duties; and c) to the victim or perpetrator of a criminal offence, where the data may constitute evidence of the offence.
Retention period
We retain the data for ten (10) days, after which it is automatically deleted. If, during this period, we identify an incident, we isolate part of the video and retain it for up to one (1) additional month for the purpose of investigating the incident and initiating legal procedures to defend our legitimate interests. If the incident concerns a third party, we will retain the video for up to three (3) additional months.
Rights of data subjects
Data subjects have the following rights:
- Right of access: you have the right to know whether we process your image and, if so, to receive a copy of it.
- Right to restriction: you have the right to request that we restrict processing, for example by not deleting data that you consider necessary for the establishment, exercise or support of legal claims.
- Right to object: you have the right to object to the processing.
- Right to erasure: you have the right to request that we delete your data.
You may exercise your rights by sending an email to info@sugartia.gr, by sending a letter to our postal address or by submitting your request in person at our premises. In order for us to examine a request related to your image, you must specify approximately when you were within the range of the cameras and provide us with an image of yourself, so that we can locate your own data and obscure the data of third persons depicted. Alternatively, we give you the option to visit our premises so that we can show you the images in which you appear. We also point out that exercising the right to object or erasure does not imply the immediate deletion of data or modification of processing. In any case, we will respond to you in detail as soon as possible, within the deadlines set by the GDPR.
Right to lodge a complaint
If you consider that the processing of data concerning you infringes Regulation (EU) 2016/679, you have the right to lodge a complaint with a supervisory authority.
The competent supervisory authority for Greece is the Hellenic Data Protection Authority, 1-3 Kifisias Avenue, 115 23 Athens, https://www.dpa.gr/, tel. 2106475600.