In this Privacy and Cookies Policy you will find all relevant information about the use of the personal data of our users and customers, regardless of the channel or the medium (online or in person) that you use to cooperate with us.

For information on how we use cookies and similar files, we recommend that you refer to the Cookies Policy.

When we talk about our Company, we generally refer to any of the channels or media, digital or personal, that you may have used to interact with us. The main ones are:

• Our Website.

 

A. Information of the Data Controller

The Company under the name “F.L.S. ANAPTYXIAKI AXIOPOIISI AKINITON VOREIOU ELLADOS ANONYMI ETAIREIA” with General Electronic Commercial Registry (G.E.MI.) No. 149671101000, with VAT No. 801124924 subject to the Piraeus Tax Office for Commercial Companies, which is based in Alimos of Attica on  77 Poseidonos Ave., (hereinafter referred to as “Company”), hereby inform you, in the capacity of data controller, in accordance with Regulation (EU) 2016/679 (hereinafter “GDPR”) and the relevant provisions of the Greek legislation on the protection of personal data, as applicable, for the type of personal data collected, the source of their collection, the reason for their collection and processing, any recipients thereof, the time of their keeping, any transmission outside the EU; as well as for your rights in relation to your data as potential customers of the Company and/or as its customers and how you can exercise them.

B. Type of data and sources of origin

1. Marketing

Depending on the activity we only process the personal data that is absolutely necessary. For example when you set up your mobile device, when you set it up in relation to your device’s privacy settings, when you consent through cookies settings or when you accept the legal terms and conditions for participating in a promotional activity or for posting your photos on Company or on the channels of our social networks.

• Displaying ads on the Internet that you might see when you visit websites and apps, for example, on social media. The ads you see may be random, but in other cases they may be ads related to your preferences or browsing history.
• If you use social media, we may provide the companies we work with with certain information, so that they can show you ads of our Company and, in general, offer you and users like you ads that take into account your profile in such social networking sites. For information about the use of your data and how social media advertising works, we recommend that you consult the privacy policies of the social networking sites on which you have a profile.
• We also use your data to perform measurements and segment analysis on the ads we display to users on some of our partner platforms. To do this, we work with third parties who provide us with the necessary technology (for example, cookies) to use these services. Keep in mind that, although we do not provide personal identification data to these partners, we do provide them with some form of identification at a time (for example, the device-related advertising ID, a cookie-related ID, etc.) For more information about this, please refer to the Cookies Policy. Likewise, you can reset the ad identifier or disable the personalized ads on your device by setting your preferences in the settings section of your device.
• To carry out promotional activities (for example, to organize competitions). By participating in any promotional activity, you authorize us to process the personal data that you have shared with us according to the promotional activity and to be able to communicate it through various media such as social networks or the Company itself. In each promotional activity in which you participate, you will be provided with the terms and conditions where we will provide you with more detailed information about the processing of your data.
• To release photos or images that you have shared publicly on the Company or through our social media channels, provided that you have given us your express consent to do so.

The above personal data are provided to the Company by you.

 

2. Pre-contractual or contractual relationship with the Company

Through our Website, we collect the necessary Personal Data, at the stage of both the pre-contractual and the contractual relationship with you, which according to the Law, are considered necessary when completing the “become a trader” expression of interest form, in order to communicate with you and inform you about your expression of interest and your ability to rent a shop in Agora Modiano. These include, for example, the Name and Surname, the E-mail address, the Contact telephone number (landline and mobile), the name of your Company, the website link of your Company, the social networks links as well as professional/business activity through presentation of your company. 

3. Analysis of usability and quality to improve our services

If you access the Website we will inform you that we will manage your browsing data for analytical and statistical purposes, that is, in order to understand how users interact with our Website with the activities we implement to other websites and applications, so that we can improve our services.

In addition, we sometimes conduct quality surveys and actions to identify the level of satisfaction of our users and to identify those areas in which we can improve.

4. Browsing our website

Connection, geo-location and internet browsing data (for example, location data, device ID or advertising ID, subject to conditions). We collect this data passively, as we use browser cookies on our website. For more details on information collected through cookies and similar technologies, please refer to the relevant section “Cookies Policy”.

5. Provision of third party data

In case you provide personal data of a third party (such as Name, Surname, Address, Telephone number) on our Website the Company will protect the Third-Party Personal Data in accordance with this Personal Data Protection Policy. If you provide us with personal data of third parties, you confirm that you have informed that third party of the purpose and manner in which we must process their personal data.

6. Contact

If you contact us using the contact form on the “Contact” page, we collect the Name and Surname, the Email address, the Contact telephone number (landline and mobile)

SOCIAL NETWORKS: 

We may process your Personal Data obtained through social networking platforms (including Facebook, Instagram,) or online reviews about our Company. If you choose to contact us using social media in order to respond to your requests or to receive information about our services, none of the data you provide will be stored on our Website or transferred/processed by anyone from third-party data processors. Instead, the data will be sorted into a message so that we can reply to you. As described in Article G, do not use social networks and their platforms to exercise your rights. For the exercise of your above rights or for matters relating to the processing of your personal data, please submit your request using the specially designed forms of our company at the reception area of the Hotel or you can apply in writing to the Data Protection Officer’s Office (DPO) of the Company by physical or electronic correspondence using the following information: 77 Poseidonos Ave., Alimos of Attica 17455, E-mail: dpo@agoramodiano.com. Some of our social media pages allow users to submit their own content. Remember that any content submitted on one of our social media pages can be viewed by the public and you should be careful about providing certain personal information (e.g. financial information or address information) through these platforms. We are not responsible for any actions taken if you post personal information on one of our social networking platforms (e.g. Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the platforms of the relevant social networks you use.

 

C. Purpose and legal basis for the processing

Processing activities	PURPOSE	LEGAL BASIS
Contact	Contact us to answer your requests or questions	Overriding legitimate interest (6.1f)
	Contact DPO to exercise your rights, about which we inform you below	Compliance with legal obligation (6.1c)
4. Marketing	Sending: customized information over multiple networks, or settings of your device, when you configure it in relation to your device’s privacy settings; consent through cookies settings, acceptance of legal terms and conditions for participation in a promotional activity or for the publication of your photos on the Company or on the channels of our social networks.	Consent (6.1a)
5.         Pre-contractual or contractual relationship with the Company	We contact you and inform you about your expression of interest and your ability to rent a shop in Agora Modiano	Execution of the contract (6.1b)
6. Analysis of utility and quality	Ensuring the smooth operation of our Company and improving the services provided through it.	Overriding legitimate interest (6.1f)
7. Responding to orders from courts or public authorities, prosecutors and police authorities, as well as audit authorities	We may process your personal data in order to respond to such requests.	Compliance with legal obligation (6.1c)

 

D. Transmission of data – Recipients

In order for the Company to respond to the above mentioned functions and its related obligations, it shares the personal data of its customers to categories of persons or bodies (recipients). The recipients have access only to those of your Personal Data that are absolutely necessary for the fulfillment of the tasks or the provision of the services they have undertaken towards the Company. These categories are as follows:

1. Processors: the Company cooperates with the following processors on its behalf to assist them in fulfilling its legal or contractual obligations, which are:

• accounting services providers;
• IT support service providers;
• hosting, cloud providers;
• promotion service providers;
• physical security service providers

subject to maintaining the confidentiality of your data.

2. Financial institutions, to the extent necessary for the execution of the transaction;
3. Tax authorities, in accordance with applicable tax legislation;
4. Lawyers, if this is necessary for the exercise of the Company’s rights and the defense of its legitimate interests;
5. Bailiffs, notaries, judicial, prosecutorial and police authorities, as well as auditing authorities, where this is required by legislative provisions or court decisions or following relevant legitimate requests from them in the exercise of their duties.

Ε. Data retention time

Your data shall be kept during the period that every contract is in force and, after termination of the latter in any way, for as long as it is laid down in the current legal framework.

If, until the expiry of the above time intervals, legal proceedings are in progress, in which the Company is involved and which directly or indirectly concern you, the time of keeping your data is extended until the adoption of an irrevocable court decision.

After the passage of the above time intervals, the personal data concerning you will be deleted/destroyed on the basis of the Company’s destruction policy.

 

F. Transmission of data outside the EU

The Company does not transmit your personal data concerning third countries outside the EU.

 

G. What rights you have in relation to your data and how you can exercise them

As data subjects you have a number of rights, in accordance with the provisions of Articles 15-22 of the GDPR, regarding your personal data, which are processed by the Company.

We are committed to respecting the confidentiality of your personal data and to ensure that you can exercise your rights free of charge by requesting a written request to the Data Protection Officer’s Office (DPO) of the Company by physical or electronic correspondence using the following information: 77 Poseidonos Ave., Alimos of Attica 17455, E-mail: dpo@agoramodiano.com. In the event that we deem it necessary to confirm your identity, we may request a copy of a document proving your identity.

The following table lists your rights. In this table you will find detailed information (concept, method) for the exercise of each right.

If you wish to exercise your right, do not use social networks and their platforms. For the exercise of your below rights or for matters relating to the processing of your personal data, you can apply in writing to the Data Protection Officer’s Office (DPO) of the Company by physical or electronic correspondence using the following information: Postal address, email dpo : dpo@agoramodiano.com.

Please note that if there are reasonable doubts about the identity of the data subject, we may request additional information to confirm the identity.

Right to information:	The COMPANY must inform you on the processing to which your data is subject, such as which data is processed, for what purpose, for how long it retains it, using clear and simple wording.
Right of access:	You have the right to receive from the COMPANY a confirmation as to whether or not your personal data is processed and, if this is happening, you have the right to access this data.
Right to rectification:	You have the right to demand from the COMPANY to rectify any inaccurate personal data of yours and to complete any incomplete data.
Right to erasure:	You have the right to request from the COMPANY to delete your personal data, which can be satisfied provided some specific conditions are met.
Right to restriction of processing:	You have the right to ensure that the COMPANY will restrict processing provided some specific conditions are met.
Right to object:	You have the right to object, at any time, to the processing of your personal data. The COMPANY, in this case, must stop processing, except if it proves urgent and legal reasons which outweigh your interests, rights and freedoms as data subject or for the establishment, exercise or defense of legal claims.
Right to human intervention in the framework of a decision through an automated procedure:	You have the right to request from the COMPANY that you do not undergo, if that is the case, a procedure of decision making solely according to an automated processing, including profiling, which produces legal effects that concern you or affect you significantly in a similar way.
Right to portability:	You have the right to request from the COMPANY that you obtain your personal data, which you have provided in a structured, commonly used and machine-readable format, or that the COMPANY transfers it to another provider.

 

It is noted that the Company has in any case the right to partially or completely refuse the satisfaction of your request for limitation in the processing or deletion of your data, if the processing or keeping of personal data concerning you is necessary for the establishment, exercise or support of its legal rights or fulfillment of its legal obligations. 

The Company must reply to your request within one month of receipt. This deadline may be extended by another two months, if required by the Company, taking into account the complexity of the request and the number of requests, and in this case the Company will inform you within one month of receipt of this extension and the reasons for the delay.

If the Company does not act upon your request during the exercise of the above rights or after its reply you consider that your above mentioned rights are violated, you have the possibility of lodging a complaint to the Personal Data Protection Authority, 1-3 Kifissias Ave., 115 23, Athens, https://www.dpa.gr/, tel. 2106475600.

For any matter concerning the protection of your personal data, you can contact the Data Protection Officer of the Company in writing at the Data Protection Officer’s Office (DPO) of the Company by physical or electronic correspondence using the following information: 77 Poseidonos Ave., Alimos of Attica 17455 E-mail: dpo@agoramodiano.com.

H. CHANGES TO PRIVACY AND COOKIES POLICY

We may modify the information contained in this Privacy and Cookies Policy when deemed necessary or when this is required by changes in the institutional framework. In any case, we recommend that you check this Privacy and Cookies Policy from time to time in case we make changes or introduce any interactive improvement, taking advantage of the possibility that you will always find it as a permanent point of information on the Website so that you can check the changes, evaluate them and, where applicable, object to or unsubscribe from a service or feature.

This Personal Data Protection Policy has been drafted pursuant to the provisions of the General Regulation on the Protection of Personal Data under No. 2016/679/EU. In any case, the Company reserves the right to change the personal data protection policy, in accordance with the applicable legal framework. Therefore, these terms of personal data protection can be reviewed and updated at any time and without notice. Users of our website and our customers are kindly requested to check these terms on a regular basis for any changes, as the continued use of the website implies that they accept all possible modifications thereof.