INFORMATION ON THE PROCESSING OF PERSONAL DATA OF CLIENTS AND THIRD PARTIES IN THE CONTEXT OF PROMOTIONAL ACTIVITIES
By means of this Notice, the company CERVED REAL ESTATE SERVICES SINGLE-MEMBER S.A., with GEMI No. 002296701000, Tax Identification Number 094158466, having its registered office at 7 Eslin Street and 20 Amaliados Street, Ampelokipoi, Attica, Postal Code 11523 (hereinafter the “Company,” “we,” “us”), informs you about how it protects your personal data in the context of promotional activities (hereinafter the “Newsletter Notice”), when, in its capacity as data controller (within the meaning of the GDPR), it collects, stores, and further processes your personal data in order to inform you about real estate market opportunities and share news that may be of interest to you.
The terms “you” or “your” in this Notice refer to the individuals whose personal data we process, namely any natural person who has not objected to receiving informational content from the Company or who chooses to receive such content.
In this Notice, “Personal Data” means any information that allows your identification, directly or indirectly, in particular by reference to an identifier such as your name, an online identifier (e.g., IP address), etc.
The Company complies with the applicable legislation on the protection of personal data, including Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”), Law 4624/2019, Law 3471/2006, as well as the guidelines and directions of the Hellenic Data Protection Authority (“HDPA”) and the European Data Protection Board.
We may update this Notice from time to time (e.g., to reflect changes in the applicable legal framework or our practices), and we will revise the date at the beginning hereof to indicate when such update has been made. You should check for updates regularly.
- Which of your personal data do we process and from which sources have we collected it
We collect and further process certain of your Personal Data in order to stay in contact with you and send you informational material (newsletter).
We process only the data strictly necessary for this purpose: your full name, telephone number, email address, and the company you work for. In addition, when you express interest in receiving informational material, we also process your affirmative declaration to that effect.
Your Personal Data has been collected in one of the following ways:
- You are an existing client or have been a client in the past, and we have collected your personal data directly from you; or
- You are a prospective client and have expressed to one of our partners your interest in buying, selling, or renting property, and we have collected your personal data directly from you; or
- You have expressed interest, through the Company’s Website, in receiving relevant informational material (newsletter).
- Legal basis and purpose of processing
We process your Personal Data where there is a legal basis for such processing, only if and to the extent that at least one of the following cases applies:
- If you have had a prior transaction with the Company, i.e., if you are an existing or former client of the Company, we send you relevant material to promote similar services to those you have already received from the Company (Legitimate Interest); or
- If you have expressed interest, either through one of our partners or through the Company’s Website, in receiving relevant informational material (newsletter) (Consent).
- Recipients of Personal Data
We engage external service providers to deliver certain services who, in the context of their cooperation with the Company, have access to or further process your Personal Data. These services include, among others, IT and systems management services, such as the development and maintenance of the Company’s website; marketing and communication services, such as newsletter management and promotional activities; as well as data hosting services.
To the extent necessary, we may disclose Personal Data to law enforcement authorities, competent independent regulatory or supervisory authorities, competent courts and other judicial bodies, as well as to our external professional advisors, including lawyers, auditors, accountants, and insurers who provide related services to us. In the event of a merger or acquisition, your Personal Data may be disclosed to the third parties involved in such merger or acquisition.
In the context of our cooperation with the above recipients, any transfer of your Personal Data outside the European Economic Area (“EEA”) for the purposes described above will be based on an adequacy decision issued by the European Commission or will be subject to appropriate and suitable safeguards and conditions to ensure an adequate level of data protection, such as data transfer agreements based on Standard Contractual Clauses approved by the European Commission. For more information on how the Company protects Personal Data transferred outside the EEA, or to obtain a copy of the safeguards applied for such transfers, please contact us at: cps.dpo.gr@iongroup.com.
- Retention period of your Personal Data
Depending on the legal basis for processing, we retain your Personal Data for marketing purposes for the following periods:
- If you are an existing client or have been a client of the Company in the past, we will retain your Personal Data for a maximum period of five (5) years from our last communication with you, unless you request the deletion of your data earlier.
- If you have expressed your interest, through the Company’s Website, in receiving relevant informational material, we will retain your Personal Data until you withdraw your consent.
Taking into account the latest technological developments, the cost of implementation, and the nature, scope, context, and purposes of processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks of processing.
- Your rights
Subject to the conditions set out under applicable legislation, you have the following rights regarding the protection of your Personal Data:
Right of access: You may contact us to be informed and receive explanations as to whether we process Personal Data concerning you, the categories of such data, as well as the manner in which we process it. You may also request a copy of your Personal Data that we process.
Right to rectification: If you believe that your Personal Data is inaccurate or incomplete, you have the right to request its correction or completion.
Right to erasure: Under certain conditions, such as when the data is no longer necessary, you may request that we delete your data.
Right to restriction of processing: If you believe that your Personal Data is inaccurate, that the processing is unlawful, that we no longer need your Personal Data, or if you object to automated processing (where applicable), you have the right to request the restriction of processing.
Right to object: You may object to the processing of your Personal Data on grounds relating to your particular situation, unless, among other things, there are compelling and legitimate grounds for the processing which override your interests, rights, and freedoms. You also have the right to object where a decision concerning you is based solely on automated processing, including profiling, and that decision produces legal effects or significantly affects you (subject to applicable legal exceptions).
Right to data portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another organization (data controller) that you designate.
Withdrawal of consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on your consent prior to its withdrawal.
Right to file a complaint before HDPA: You have the right to file a complaint before the Hellenic Data Protection Authority (HDPA) regarding matters related to the processing of your Personal Data by the Company. More information about the responsibilities of the HDPA and how to submit a complaint can be found on its website at www.dpa.gr.
If you have any concerns or questions regarding this Notice, or if you wish to exercise any of the rights described in the section “Your Rights,” please contact us at: cps.dpo.gr@iongroup.com.