Personal Data Protection Policy

Personal Data Protection Policy

INTRODUCTION

As of 25 May 2018, the General Data Protection Regulation – Regulation EU 2016/679 (hereinafter “GDPR”) applies in the European Union. For the text of the Regulation, you can go to the URL: https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=CELEX:32016R0679.

This Privacy Policy (hereinafter referred to as the “Data Policy” or “Privacy Policy”) applies to our company’s website under the domain name: www.datalink.com.gr .

DATALINK attaches particular importance to the protection of the personal data of citizens, but also of any person visiting this website. For this reason, it has prepared this Data Protection Policy in order to inform the above persons about the way in which their personal data is collected, used and disclosed.

1. DEFINITIONS OF PERSONAL DATA

(Note: The definitions follow article 4 of the GDPR)

“Personal Data“: any information by which a natural person (“Data Subject”) is identifiable or can be identified.

‘controller‘ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor“: the natural or legal person, public authority, agency or other body that processes personal data on behalf of a controller.

“Personal Data Subject“: the natural persons for whom the controller collects and processes personal data (in this Data Policy, Data Subjects are the users of the above website, whether or not they are identified for the use of the service.

‘recipient‘ means the natural or legal person, public authority, agency or other body to whom the personal data are disclosed, whether or not a third party.

1. COLLECTION OF PERSONAL DATA

When the visitor/user visits the DATALINK website and as long as

1. 1. interacts with it, or
   2. make use of document issuing services

it is possible to collect certain information, such as:

Α. For the provision of the electronic services

For the use of the “service” and the effective and lawful provision of this service, DATALINK , processes – as the controller – the following personal data:

1. 1. Navigational data within the “website” through the installation of “cookie” type data extraction programs
   2. Timestamp of the use of the “service”.
   3. Connection device details (operating system, browser software).
   4. The set of data contained in the document (application or declaration or authorisation) submitted by the “user”.

Β. Special Categories of Personal Data

DATALINK does not collect or process special categories of data, as defined in the provisions of the applicable legislation (in particular racial or ethnic origin, religion, health data, etc.) for the purposes of identification and provision of the service. It may, however, process special categories of data, provided that these data are entered by the user himself in the “free text” fields of the documents when using the e-services, such as in the online application, online authorisation and online declaration.

1. PURPOSE OF THE PROCESSING OF PERSONAL DATA

DATALINK processes your personal data for the exercise of its statutory responsibilities, its compliance with its legal obligations under national and EU law, the performance of tasks carried out in the public interest and in the exercise of public authority entrusted to it.

Legal basis of the processing

The processing of the personal data of the “users” is necessary for the operation of the “service” and is based on the provisions of Law 4635/2019 (Government Gazette A’ 167) and the Legislative Content Act of 20-03-2020.

Purposes of the processing

The personal data collected by the website are used to fulfil the following purposes:

a) the fulfilment of the purpose of the website’s operation, i.e. the provision of its services to users,

b) the provision of information regarding the services of the website and the way they operate; and

c) the extraction of statistics regarding the use of this website.

In particular, the Personal Data collected by the website and stored in the relevant database or cloud data are intended to be used for the purposes mentioned above, namely:

1. 1. Seamless operation of the “website” and the “service”.
   2. Technical support to the “declaration managers” of the “service”.
   3. User-friendly and easy to “user” operation of the “website”.
   4. Improving the online experience during the operation of the “service”.
   5. Generate statistical reports and graphs to monitor the service.
   6. The information in the statistical reports and graphs does not contain any personal data of “users” as it is derived from anonymised information.

DATALINK collects and processes personal data of “users” in the context of providing the “service” exclusively and only for the aforementioned purposes and only to the extent strictly necessary for the effective service of these purposes. This data is in each case relevant, appropriate and no more than is required in view of the aforementioned purposes, and is accurate and, if necessary, updated.

Furthermore, these data are kept only for the period necessary to fulfil the purposes of their collection and processing and are deleted after this period, in accordance with the general terms of use.

1. CONFIDENTIALITY

DATALINK does not make available or otherwise transmit or disclose personal data of visitors/users of the website to third parties without the consent of the visitor/user, except to the aforementioned recipients for the operation of the Portal and with the exception of the application of relevant legal requirements and to the competent authorities only.

The personal data kept may be communicated to the competent judicial, police and other administrative authorities, upon their legitimate request and in accordance with the applicable legal provisions. In addition, in the event of a legal order by a public prosecutor or other authority, or the conduct of a regular investigation or preliminary examination, DATALINK is obliged to give access to the relevant data and make it available to the requesting authority.

DATALINK does not transfer personal data of users to a third country or international organization.

1. TRANSFER AND STORAGE OF PERSONAL DATA

Any transfer or transmission of the personal data of the Data Subjects is carried out through electronic systems and the data is transferred in encrypted form.

The data is stored on servers or with the cloud service provider located within the European Union.

Access to user data may be granted to authorised employees of DATALINK Digital Governance and in particular the General Secretariat for Public Administration Information Systems within the framework of their duties and responsibilities.

DATALINK in the context of the purposes described above may, at the user’s option, transmit some personal data to third parties to which the user himself chooses to send the electronic application or the electronic declaration or the electronic authorization in the context of the use of the electronic services provided.

1. SATISFACTION OF RIGHTS – GUARANTEES – PERIOD OF RETENTION

Overall DATALINK ensures that:

1. 1. Procedures are in place to allow the rights of Data Subjects to be exercised easily, so that all required actions can be initiated immediately.
   2. It shall respond to a request submitted by the Data Subject without undue delay and in any case not later than thirty (30) calendar days. In the event that it cannot satisfy a right exercised by the Data Subject, DATALINK shall ensure that a specific, adequate and complete justification is provided.
   3. Except in the case of manifestly unfounded or excessive requests, all actions concerning the satisfaction of the rights of the Data Subjects will be carried out free of charge for the Data Subjects.
   4. The personal data collected are recorded in computerised systems, which provide adequate security and are used by specially trained and authorised employees, in order to achieve the maximum possible protection of the data recorded in the modern digital environment.
   5. DATALINK retains and processes your Personal Data for the purposes mentioned above only for as long as necessary for the purpose for which they have been collected under the terms of use of the service or under applicable law.
2. POLICY ON ‘COOKIE’ PRESS ARCHIVES
   1. General

The Portal’s website uses “cookies” files (program – “treat”) in compliance with the applicable legislation. “Cookies” are small pieces of information (files), in the form of plain text, which are stored on the user’s computer (or other devices with internet access, such as a smartphone or tablet) when visiting any page on the internet. Cookies do not cause any harm to the user’s computer or to the files stored on it. Without them, the user’s personal preferences would be impossible to store.

“Cookies” help to collect information necessary to measure the effectiveness of a website, to improve and upgrade its content, to adapt it to the demand and needs of users and to measure the effectiveness of the presentation and visibility of the website on third party websites. The “Cookies” files used on the website do not collect information that personally identifies users and do not take note of any document or file from the users’ computer.

The information collected by “Cookies” may include the type of browser used by the user, the type of computer, the operating system, the internet service providers and other such information. In addition, the website’s information system automatically collects information about the sites visited by the user and links to third-party websites that may be on the Portal’s website.

1. 1. Which “Cookies” are used by the Portal

The Portal website, as well as all websites, in order to operate smoothly and serve the user to the maximum, use “cookies”. The four categories used are detailed below:

Α) Necessary

Necessary Cookies help to make the website usable, allowing basic functions such as navigation and access to secure areas of the website. The website cannot function properly without these cookies.

B) Preference

Preference Cookies allow the website to remember information that changes the way the website behaves or looks, such as the preferred language or the region in which the user is located.

C) Statistics

Statistics Cookies help website owners understand how visitors interact with pages by collecting and reporting information anonymously.

LIST – INVENTORY – CATEGORISATION OF GATEWAY COOKIES

1. 1. How to manage and delete “Cookies”

The menus of most browsers provide options on how to manage cookies. Depending on the options given to users by the browser, the user can allow the installation of “Cookies”, disable/delete existing “Cookies” or be notified each time a “Cookie” is received. Instructions for managing and deleting Cookies are usually found within the “Help”, “Tools” or “Edit” menu of the respective browser. Also, the user can find more detailed guidance in the www.youronlinechoices.com/gr, which explains in detail how to control and delete cookies in most browsers.

The user must take into account that, in case of rejection or deactivation of the cookies of the website, the functionality of the websites may be partially lost. Also, disabling a “Cookie” or a category of “Cookies” does not delete the corresponding file from the browser. Such an action would have to be performed by the user himself, by modifying the internal functions of the browser he uses.

1. Contact

You can contact the Data Protection Officer of DATALINK by sending an e-mail to: info@datalink.com.gr

In the event of exercise of one of the aforementioned rights, DATALINK will take all possible measures to satisfy it within thirty (30) calendar days of receipt of the relevant request, informing in writing of its satisfaction, or the reasons that prevent the exercise. If, due to the complexity or the number of requests, this is not technically feasible, the time limit shall be extended for a further two months upon notification.

If you are not satisfied with the response or if you consider that the processing of your Personal Data violates the applicable regulatory framework for the protection of personal data, you have the right to lodge a complaint with the Personal Data Protection Authority (postal address: Ave. Kifissia 1-3, P.O. Box 115 23, Athens, tel. 210 6475600, e-mail address (e-mail) contact@dpa.gr).