Information Form on the Processing of Personal Data (G.D.P.R.)

In general:

The company named “SOUTHSTAR AE” based in Athens (Kallirois Ave. 23), with T.I.N. 800592200 as Personal Data Processor (hereinafter referred to as “SOUTHSTAR”), in the context of its harmonization with the provisions of the General Data Protection Regulation (EU) 2016/679 (hereinafter “GDPR”) and Directive 2016/680/EU and the relevant provisions of Greek legislation, with this form informs you about the processing of the personal data of its customers, partners, suppliers, employees and your rights as subjects of the relevant processing.

Controller of processing:

“SOUTHSTAR” has the status of Data Controller. A Data Controller is defined based on Regulation (EU) 2016/679 as the natural or legal person, public authority, agency or other entity that, alone or jointly with others, determines the purposes and manner of processing personal data.

Lawfulness of processing (i.e. why we collect your data and for what purposes it is processed):

“SOUTHSTAR”, may process personal data of our customers, partners, suppliers, employees if any of the following conditions are met:

1. a) the processing is necessary for the service, support and monitoring of our business relations with our customers, partners, suppliers, etc. in goods and services, as well as for the proper and lawful execution of our permanent contracts. In this case, the processing needed to take the necessary measures, at the request of the customer, partner, etc. before the conclusion of the contract (pre-contractual stage), is also included.
2. b) the processing is necessary to comply with a legal obligation of “SOUTHSTAR” or to pursue the legal interests arising from our business relations or from our rights and obligations arising from the applicable legislation,
3. c) the processing is necessary for the fulfillment of an obligation to the public and generally public Authorities, Organizations and Services, in accordance with the current legislative and regulatory framework,

(It is noted that in the cases under a), b) and c), for the processing of the data, the consent of the customers, partners, etc./data subjects is not required.)

1. d) you have specifically and expressly consented in writing to the processing of your personal data for one or more specific purposes such as for statistical, organizational and operational purposes, provided that the processing is not based on any of the above under a to c mentioned legal bases. In this case, you have the right to withdraw your consent at any time, and the relevant withdrawal does not affect the legality of the processing based on the consent before its withdrawal. The revocation is made by a document submitted, in writing or electronically, to “SOUTHSTAR” (addressed to : Tseva Angeliki) and is valid from the date of its submission and henceforth.

Data processing:

The processing of the personal data of customers, partners, suppliers, employees of “SOUTHSTAR” consists of the collection, registration, organization, structure, storage, alteration or adaptation, retrieval, information search, use, transmission or any other form of disposal, association or the combination, limitation, deletion of the personal data of our customers, partners, suppliers, etc. that have come to our knowledge, both in the context of our business relationships, and in the context of information that “SOUTHSTAR” can receive from third parties, natural or legal persons or bodies of the wider public sector in the exercise of their legal rights or that of “SOUTHSTAR”, carried out with or without the use of automated means.

In the case that the processing of your personal data is based on your consent (and such consent is required e.g. for “SOUTHSTAR” to send you forms and electronic messages for advertising – promotional and other purposes), you have the right to withdraw your consent at any time, and the relevant withdrawal does not affect the legality of the processing based on the consent before its withdrawal. The revocation is made by a document submitted, in writing to “SOUTHSTAR” or electronically to the email address atseva@southstar.gr, and is valid from the date of its submission and henceforth.

Type of data processed by “SOUTHSTAR”, which means which personal data we collect and from where:

The personal data that we process may have come to our knowledge, both in the context of our business relationships, and in the context of information that we receive from third parties, with natural or legal way, persons or structures or authorities of the wider public sector, in the act of the legal rights of themselves or “SOUTHSTAR’s”. These are the following data:

1. Name and patronymic of customer, partner, etc.
2. Identity or passport details of the customer, partner, etc.
3. Tax Registry Number, Tax Authority & Country of Tax Residence
4. Profession
5. Home or Work Address
6. Contact Details: Mobile Phone number, Home Phone number, Work Phone number, Email, Mailing Address.
7. Electronic communication recording data after your prior notification (via a message on our website, communication application and social media), and in compliance with the conditions set by the GDPR.
8. Data from the use of electronic and/or digital products and services of “SOUTHSTAR” (such as cookie identifiers, IP addresses, location data or other online identifiers, applications, social media) according to their more specific conditions.
9. Information on the execution of payment transactions regarding the provision of services, which payments can be made either in cash, or by using a debit or credit card, or by bank transfer. In these cases, the transmission of the data to the bank is considered to be done at the request of the respective subject to the transmitting provider, who is responsible for their completeness and accuracy.
10. Face image data from the video recording systems of the “SOUTHSTAR” headquarters facilities.
11. It is noted that the personal data provided by our counterparties (e.g. our customers) must be complete and accurate and updated with their care, immediately in any case of change or whenever seemed necessary or appropriate by “SOUTHSTAR” for the maintenance of business relations between us or for our compliance with our obligations deriving from the applicable legislative and regulatory framework.

Special category data:

“SOUTHSTAR” does not process personal data of our customers that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, nor genetic or biometric data for the purpose of identifying the customer, partner, etc. or data concerning the health or sex life of the client, partner, etc. or their sexual orientation.

Minors Data:

The processing of personal data concerning minors is carried out under the strict condition of the prior consent of the parents or those exercising their parental care, in accordance with the specific provisions of the applicable legislation.

Purposes of processing the personal data of our customers and counterparties in general are:

1. a) the proper execution of contracts regarding the import, marketing and promotion of all kinds of products, the development, execution and exploitation of programs and projects aimed at environmental protection and sustainable development, the distribution of all kinds of forms and advertising activities, the provision transportation services, the advertising and promotion of products, the provision of waste management services, the collection and transportation of bulky objects, etc., and the servicing of our organizational and operational needs and our obligations to the State, Organizations, Banks and providers of goods, media and services,
2. b) the service, support and monitoring of the business relations of “SOUTHSTAR” with our customers, partners with whom the provision of services is agreed for the execution-implementation of all types of the above contracts and the services/project provided from them or based on them, the distribution of advertising forms, brochures, coupons, product samples and in general the introduction, marketing, promotion of products,
3. c) the registration, recording and archiving of all kinds of orders, requests of our customers, partners to “SOUTHSTAR” given in writing, electronically or by telephone, or registered in the respective software or information systems of the company in the context of the execution of each kind from the above contracts and the services provided from them or based on them,
4. d) in the context of the provision of distribution services of all kinds of advertising material or product promotion, the fulfillment of the obligations arising from the applicable legislative and regulatory framework of “SOUTHSTAR” as well as our compliance with the decisions of the competent supervisory, administrative, public and judicial/prosecuting Authorities,
5. e) the satisfaction of all kinds of requests addressed to “SOUTHSTAR” from our customers and partners or the analysis of complaints from our customers and
6. f) the receipt from our customers, partners of printed and electronic messages from “SOUTHSTAR” to inform you about preferential programs, usage reward programs, advertising / promotional purposes, as well as the receipt from our customers of questionnaires for the investigation / evaluation the quality-level of all kinds of services provided, such as e.g. distribution of advertising material, marketing and promotion of products in order to improve them.

Storage and retention time:

The personal data of our customers, partners are processed, maintained and kept by us in a secure environment, exclusively and only for the purposes for which they are intended and only for as long as is necessary to achieve said purposes, subject to of the more specific ones provided by the current legislation. In any case, the personal data of our customers, partners are kept for a period of five years (5) years from the termination of the contractual relationship between “SOUTHSTAR” and the customer, our partners, i.e. until the completion of the of article 250 A.K. set limitation period for related claims. In the event of legal disputes, the above time limit does not apply, in which case the prescribed data retention time is extended until the issuance of an irrevocable court decision.

Recipients/categories of data recipients:

Recipients of the personal data of our customers and partners may be:

1. the employees or partners of “SOUTHSTAR” to whom we have assigned tasks for the execution of the marketing contracts, product promotion, development, execution and utilization of programs and projects aimed at protecting the environment, distribution of any kind of form and advertising actions , providing transportation services, advertising and product promotion, distribution of promotional material, waste management, collection and transportation of bulky items, etc., as well as those who have been entrusted with the service of requests/complaints from our customers, partners, the monitoring, information and collection of debts from and on the execution of the above contracts and the services provided from them,
2. third parties, natural or legal, to whom “SOUTHSTAR” has delegated, partially or fully, the execution of functions of the processing of personal data, in order to facilitate and better serve the execution of all types according to the above contracts and the provision of advertising material distribution or product promotion services to its customers, as well as its compliance with the applicable legislative and regulatory framework, defined by our relevant counterparties (businesses, e.g. distribution or support of software, applications etc. about our operation) and are covered by confidentiality statements,

• third parties with whom “SOUTHSTAR” cooperates in the exercise of its activities, in order to fulfill its obligations in the context of the execution of the trainings according to the above contracts, the provision of promotion and advertising services of products, distribution of advertising material, waste management, collection and transport of bulky objects, etc., as indicative may be the specially designated partners of the providers of IT products and/or services and/or support of all kinds of information and electronic systems, networks, applications, including online systems and platforms, companies storage, archiving, record and data management, telephone service companies bound by confidentiality statements,

1. any person to whom the transfer is required to be carried out, pursuant to the applicable legislative and regulatory framework or pursuant to a court order and
2. the competent authorities for the control and operation of “SOUTHSTAR”, as well as in general any public, administrative, supervisory, judicial, prosecutorial or other Authority, in the exercise of its legal duties.

“SOUTHSTAR” informs the public, customers, partners, employees etc. that it has ensured, on the one hand, the commitment of all the above recipients to confidentiality during the processing of your data, and on the other hand, that those performing on its behalf the processing of personal data of our customers, etc. meet the conditions arising from the applicable legislation and provide assurances for the implementation of the appropriate technical and organizational measures, so that during the processing of the personal data of our customers, etc. by them, the rights of the subjects are protected.

Rights of our customers, partners and employees as data subjects:

Our customers, partners and employees as the subject of personal data have the following rights:

1. a) right to update and access the personal data concerning you and to receive information about those, as well as about their origin, the purposes of their processing, the recipients or their categories of recipients and their storage period,
2. b) right to submit a request to correct inaccurate data and fill in incomplete data held,
3. c) right to oblivion, i.e. deletion of data, subject, however, to the obligations and of the legal rights of “SOUTHSTAR” to maintain them for a minimum specific period of time, pursuant to the applicable legislative and regulatory framework,
4. d) right to limit the processing of the data, if either their accuracy is disputed, or their processing is illegal, or the purpose of the processing is no longer relevant and provided that there is no legitimate reason for their retention,
5. e) the right to portability of the data to another controller, provided that the processing is based on your consent and is carried out by automated means (the satisfaction of this right is subject to the legal rights and obligations of “SOUTHSTAR” to retain the data and fulfill its duty in the public interest) and
6. f) right to object to the processing of the data concerning you for reasons related to the particular situation of yours, in the cases where the data is processed for the fulfillment of a task performed in the public interest or for the purposes of the legitimate interests pursued by “SOUTHSTAR” or a third party.

Security:

“SOUTHSTAR” has taken strict security measures (organizational and technical) to ensure the confidentiality and protection of the personal data of its customers, etc. from any illegal or unlawful processing, accidental or unlawful destruction, loss, alteration, prohibited dissemination or access , according to the specific provisions of the current legislation.

Data Protection Policy:

“SOUTHSTAR” has adopted and implements a Personal Data Protection Policy, which is available, as applicable, on its website www.southstar.gr The above policy is subject to unilateral modification by “SOUTHSTAR”, at its absolute discretion at its discretion, and its updated version is immediately posted on the above website.

Contact for Data Protection issues:

You can contact for Data Protection matters with Tseva Angeliki, who has been designated by “SOUTHSTAR” as responsible for such matters and his contact details are: 23 Kallirois Avenue-Athens, contact phone number 210 6424100 & 6940453722, email: atseva@southstar.gr

Your requests regarding your personal data and the act of your rights are submitted to the above Tseva Angeliki at the email address atseva@southstar.gr or written at its offices in Athens (Kallirois Ave. 23) under his/her consideration.

“SOUTHSTAR” will make every effort to respond to your request within thirty (30) days of its submission. The above deadline may be extended for sixty (60) days if this is deemed necessary at the discretion of “SOUTHSTAR” due to the complexity of the request and the number of requests. In this case you will be informed within thirty (30) days.

The provision of the above service is free of charge. In the event that customer requests etc. are manifestly unfounded or excessive or repetitive, then he may ask the customer to pay a reasonable fee, after informing him accordingly, or refuse to satisfy his request or requests.