Privacy Policy

1. In general

In compliance with the provisions of the European Regulation on the Protection of Personal Data and the relevant Greek legislation (as amended and in force), the CIRCULARGREECE manages the personal data which are submitted by the USER with the utmost care, ensuring in any case their protection and privacy.

The USER may browse into the website without being asked of any personal information from the CIRCULARGREECE, unless expressly otherwise informed by the CIRCULARGREECE. The CIRCULARGREECE collects personal data that are disclosed only when the USER is registered at its services, as well as when they proceed to an order as an unregistered USER. In any case, these information are considered as necessary to perform the online purchase and the relevant USER’s update on the proceedings.

2. In which cases are the data collected

The CIRCULARGREECE collects one type of information about the users: data that the user gives when sending an email via website. The CIRCULARGREECE makes use of those data provided by the USER while completing their contact form, in order to contact him/her.

You have the option to choose whether or not to receive such notifications/newsletters from the CIRCULARGREECE by sending your request via e-mail to [email protected].

3. Data’s Use

The CIRCULARGREECE will use the USER’s personal data solely for the purposes which are hereafter described. No extra or other type of personal data, apart from those that are considered as necessary, are collected or processed, to fulfill its intended purpose. The CIRCULARGREECE will only use those personal data that are defined in the present Privacy Policy, unless the USER has specifically given its consent to another use of their personal data. In the exceptional case that the CIRCULARGREECE intends to use the USER’s personal data, which are processed based on their prior consent, for purposes other than those disclosed in the said consent, the CIRCULARGREECE undertakes to inform the USER in advance and, in cases where the processing is based on the USER’s consent, their personal data will be used for a different purpose only upon their relevant permission.

4. Data’s use for advertising purposes

The CIRCULARGREECE will not use the USER’s data for advertising purposes unless the USER has given their explicit and free consent. With regard to existing customers, CIRCULARGREECE may use the email address received from the USER with an existing customer relationship to provide them with marketing materials related to similar products or services that they have previously requested, used or you may be interested.

The USER can be deleted at any time or alternatively, they may choose through their account whether or not to receive promotional / promotional material via email or sms. It may also oppose this use at the time of collection and every time they send a message. In order to stop receiving emails for marketing purposes, the USER is proposed to follow the instructions in the e-mail received.

5, Legal obligations

THE CIRCULARGREECE may need to use and maintain personal data for legal and compliance purposes such as the prevention, detection, or investigation of a crime, prevention of loss, fraud or any other misuse of its services and IT systems. The USER’s personal data may also be used by the CIRCULARGREECE for internal and external audit requirements, information security purposes, or to protect or enforce its rights, privacy, security, property or other persons.

6. Processing of children’s personal data

The CIRCULARGREECE will not collect or process personal data of children under the age of 16 unless a parental consent has been given in accordance with applicable local law. If the CIRCULARGREECE realizes that a child’s personal data was collected in error, they will be deleted without undue delay.

7. Processing sensitive data

In some cases, CIRCULARGREECE may process special categories of personal data relating to the USER (“sensitive data”). Sensitive data defines personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, participation in trade unions, genetic data, biometric data to identify a natural person, health or sexual life, or sexual orientation. For example, the CIRCULARGREECE may process sensitive data that the USER has made public. The CIRCULARGREECE may also process sensitive data, where appropriate, to support, exercise or defend legal claims. The CIRCULARGREECE may also process the USER’s sensitive data if they has freely given their explicit and separate consent in a specific context for a particular purpose.

8. Correction, Modification or Deletion of Information/Data

The website allows and encourages its USERS to correct, change, supplement or delete data and information submitted. If the USER chooses to delete an item of information, the website will act to delete this information from the CIRCULARGREECE’s files immediately. For the USER’s protection and security, the website will attempt to make sure that the person making the changes is the USER. To access, change or delete your personal data to report problems arising from the website’s functioning or make any question please contact via website circulargreece.gr or by e-mail at [email protected]. Changing or correcting your personal information can also be done through the sign-up page. Please note that the CIRCULARGREECE will do everything possible to protect the USERS’ password privacy of users, but to protect the site depends on them.

9. USER’S rights

As a data subject, the USER has specific legal rights regarding the personal data collected by him/her. THE CIRCULARGREECE will respect its rights and deal adequately with their concerns. The following list contains information about the USER’s legal rights of arising from applicable data protection laws:

• Right to withdraw the consent: Where processing of personal data is based on the USER’s consent, they may withdraw its consent at any time.
• Right of rectification: The USER may request the CIRCULARGREECE to correct the inaccurate personal data concerning him or her. THE CIRCULARGREECE makes reasonable efforts to maintain the personal data held or controlled by her and are used on a continuous basis, accurate, complete, current and related, based on the most up-to-date information available. The USER also has the ability to check and correct their personal data by entering his /her personal account.
• Right of limitation/restriction: The USER hall have the right to obtain from the controller restriction of processing where one of the following applies:
  • (i) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  • (ii) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • (iii) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  • (iv) If the USER has objected to the processing for the period the CIRCULARGREECE verifies whether its legitimate interests override their own.
• Right of access: The USER may request information about the personal data the CIRCULARGREECE holds, including information about the categories of personal data in its possession, process or control, for the purpose they are used, from who they were collected (if not directly by the USER) and to whom they have been disclosed etc. The USER may receive from the CIRCULARGREECE without charge a copy of their personal data. THE CIRCULARGREECE reserves the right to charge a reasonable fee for any further copies that may be requested.
• Right of data portability: Based on a USER’s request, the CIRCULARGREECE will transfer their data to another controller if technically feasible, provided that the processing is based on the consent of the USER or is necessary for the performance of a contract. The USER, instead of receiving a copy of his or her personal data, he/she may request the CIRCULARGREECE to transfer the data to another controller, which will be directed to it directly by the USER.
• Right to erasure: The USER shall have the right to obtain from the CIRCULARGREECE the erasure of personal data concerning him or her without undue delay in the following cases:
  • (i) personal data are no longer necessary in relation to the purposes for which they were collected or processed,
  • (ii) the USER has the right to object to further processing of his or her personal data and exercises it,
  • (iii) the processing is based on the consent of the USER, withdraws its consent and there is no other legal basis for processing,
  • (iv) the personal data has been illegally processed unless processing is necessary,
  • (v) Compliance with a legal obligation that requires processing by the CIRCULARGREECE,
  • (vi) in particular for legal obligations to perform a task; and
  • (vii) for the support, exercise or defense of legal claims.
• Right to object: The USER may at any time object to the processing of his/hers personal data because of their particular situation, provided that the processing is not based on their own consent but in the CIRCULARGREECE’s legitimate interest or in the legitimate interest of third parties. In this case, the CIRCULARGREECE will no longer process the personal data of the USER unless overriding legitimate reasons can demonstrated and a superior interest in processing or supporting, exercising or defending legal claims. If the USER opposes the processing, kindly specify whether the deletion of their personal data or limit the processing by the CIRCULARGREECE is desired.
• Right to lodge a Complaint with a supervisory authority: In the event of a suspected violation of applicable privacy laws, the USER may lodge a complaint with the Data Protection Supervisory Authority in particular in the place of his or her habitual residence, place of work or place of the alleged infringement.

10. Special highlights

• Timeframe: The CIRCULARGREECE will attempt to satisfy any relevant USER’s request within 30 days. However, the time limit may be extended for specific reasons relating to the specific legal entitlement or complexity of the request.
• Restriction of access: In some cases the CIRCULARGREECE may not be able to provide access to all or some of the USER’s personal data due to legal provisions. If the CIRCULARGREECE refuses the USER’s request for access, he/she will be informed on the reasons of this refusal.
• Non-recognition: In some cases, CIRCULARGREECE may not be able to search for the USER’s personal data due to the identifiers they provide in their application. In such cases, where the CIRCULARGREECE cannot identify the USER as the data subject, he is unable to comply with his request to perform his / her legal rights as described in this article unless provided by the USER for additional information which allow it to be identified.
• Exercise of the USER’s legal rights: In order for the USER to exercise their legal rights, please contact us in writing by e-mail. You can also contact the CIRCULARGREECE Data Protection Officer (DPO) directly at [email protected].

11. Personal data retention

Generally, the CIRCULARGREECE will delete the personal data collected from the USER if it is no longer necessary to achieve the purposes for which they were originally collected. However, we may be asked to store personal data for a certain time period because of legal provisions.

The USER may address questions on data protection and any relevant requests for the exercise of their legitimate rights to the CIRCULARGREECE’s Data Protection Officer (DPO) at [email protected].