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Privacy Notice

PRIVACY NOTICE
Information on the Processing of Personal Data

The Public Properties Company SA (ETAD SA) is a société anonyme whose purpose is the exploitation, by any appropriate means, of the immovable assets owned by it and the management of the assets assigned to it by the State, by legal persons governed by public law, by legal persons governed by private law belonging to the wider public sector and by other societies anonymes whose share capital belongs directly or indirectly to the Greek State (hereinafter referred to as “ETAD SA” or “Company”).
ETAD SA was formed by the absorption of Sociétés Anonymes, “Tourist Properties SA”, “Olympiaka Akinita SA”, “Public Real Estate Company SA” and “Paraktio Attiko Metopo SA”.
In this context, ETAD SA is active in:
• Administration / Management of Public Property (Tourist, Olympic, Urban, Rural and Other Real Estate Properties)
• Management of Lease Contracts or/and properties’ concession
• Operation of tourist business units as branches (ski, marinas, coasts, thermal springs)
• Exploitation of Property, with private investment, through lease tenders
• Development of Real estate Property through co-funded programs
• Short-term lease of facilities and outdoor areas throughout Greece for the holding of various kinds of events (exhibitions, concerts, conferences, receptions, etc.)
• Participations (equity participation in corporate schemes for the development and exploitation of tourist property)
For “ETAD SA” the main priority is the management and exploitation of its portfolio's real estate properties, through modern financial tools, in accordance with the objectives and priorities of the country's development, contributing to the development of the economy, tourism and local communities. The intention of the Company is to attract private investment and to promote public-private partnerships, with a view to protecting the environment and working with local communities.  The total percentage (100%) of the Company’s share capital is hold by HELLENIC COMPANY OF HOLDINGS AND PROPERTY (EESYP SA), after the adoption of Law 4389/2016.
The “ETAD SA” operates in the public interest, in accordance with the rules of the private economy.

Notification of personal data’ protection
We would like to assure you that for ETAD SA, the protection of its clients’ and other persons’ personal data, such as its associates’ and its personnel’s data, is of paramount importance. Therefore, we are taking all necessary measures to protect the personal data we process and to ensure that the processing is always in compliance with the obligations as set by the legal framework, both by the Company itself and by those third parties that process personal data on behalf of the Company.

Controller – Data Protection Officer (DPO)
The Public Properties Company SA (ETAD SA), seated in City of Athens, Attica, VAT number 094537454, at 7 Voulis street, email: info@etasa.gr, fax: 210-3339507 tel: (+30) 210 3339641/9483,website: http://www.etasa.gr,  as duly represented, informs that, for the purposes of its business activities, processes the personal data of its clients & associates in accordance with applicable national law and European Regulation 2016/679 on  with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, hereinafter referred to as the “Regulation”), as such is in force.
For any matter related to the processing of personal data, please contact directly Data Protection Officer, Mrs Marilena Bellou, email: mbellou@etasa.gr

What personal data do we process?
The personal data you provide with us (such as, your full name, your residence address, your telephone number, your email address, as well as information concerning your CV for filling vacancies) prescribed documents such as tax and insurance clearance, non-bankruptcy certificates, and so on, for your participation in tenders, are being processed only when we have a legitimate ground to do so.

Which are the legitimate grounds for processing your personal data;
Legitimate grounds for processing your personal data constitute:
(a) the actions we take to provide you with the services you expect and wish to receive from us. In particular, as part of our activity, we promote, through our website, real estate properties that are available for sale or hire and we also conduct online auctions, through an online platform, as well as tendering exercises (in particular tenders for supplies and contracting of services and tenders for conducting studies and technical designs). We also collect and process the information you provide to us in order to participate in tenders announced by our Company or in order to subscribe to the lists of suppliers or service providers via e-Katalogos.
(b) the consent you provide us under the specific conditions as set in the legal framework, in case you wish to receive from our Company updates regarding the properties that we are going to make available to the public for use as well as other news related to our activity. We assure you that on this legal basis we process your personal data solely for the purpose for which you give us your consent.
(c) the collection of criminal records in the context of submission a participation in a tender is carried out on a case-by-case basis and in special circumstances (eg if the applicant is a member of a company's board and acts as a representative), and we provide in each case sufficient guarantees for the protection of your data, your rights and freedoms as defined by the current legislative framework.
(d) the processing of personal data in compliance with an obligation imposed by law, such as compliance with legislation on public / private tendering, environmental legislation for the use of properties with special characteristics as well as compliance with tax legislation,
(e) the safeguarding and protection both of your, as well as our, legal interests. Thus, we use security cameras in the Company's reception areas and its business units, as we can, for the above reasons, operate a closed circuit television system, in order to be able to protect the safety and security of individuals, materials and facilities.

How and why do we use your personal data?
  • To offer our clients quality services, to properly organize tenders and to provide you with the best possible services
From our contractual relationship and the pre-contractual actions, we collect and process the information needed for the smooth development of our co-operation, for example: the personal data you submit to the online platform of our website in order to contact you and meet your requests. You send us through our website and in particular through the contact form, filling in the required mandatory fields (name, surname, e-mail) and optional ones (telephone, company), your interest in participating in tenders and related questions, which we have to answer in detail. We also use your personal information to sign up in the list of suppliers and service providers, while we process your personal information in order to provide you with important information about our site and any changes to this Privacy Notice.
  • For the presentation and promotion of real estate properties through marketing services
If you have given your consent to this, we inform you about the properties we are going to make available to the public for use as well as other news about our activity. A significant prerequisite for sending you an e-mail for marketing purposes is your prior consent.
  • To comply with legal obligation
We are obliged to comply with the legal provisions in order to comply with the legislation that refers to public / private tenders, environmental legislation for the exploitation of properties with special characteristics, as well as compliance with tax legislation. Therefore, the compliance with all above legal provisions define the legal and well-functioning operation of our Company.
  • To safeguard our legitimate interests and protect individuals and goods
We process our customers' personal data to optimize our services, improve our site's performance and promote real estate properties, which are available for sale or hire. We inform you that the use of the closed circuit television system and security cameras ensures the protection of individuals (i.e. visitors and our personnel) and the security of our Company's facilities.

Do we share your personal data?
The Public Properties Company SA (ETAD SA) informs you that it shares your personal data with the following categories of recipients:
  • Public authorities, Law enforcement institutions
When it is necessary, e.g. in cases that we are required to disclose personal data to public bodies (e.g. Ministries) in the course of a public tender procedure, in the case of a tax audit or even if we need to provide information to a police and / or judicial authority, if any dispute arises as well as to a competent Public Economic Service, by sending a Cash and Confirmation List (for arrears due pursuant to Article 68 (2) of Law 4484 / 2017) and in any case in order to safeguard our business interests and the reputation of our Company.
  • Cooperating companies (suppliers, agencies, advertising bodies etc.)
Our Company shares your data with third parties, which have been assigned with the processing of your data on our behalf (equipment suppliers, accountants, lawyers). In those cases, our Company remains responsible for your data processing, defines the specifics of the processing and receives from the partners to whom it entrusts the execution of processing activities all the necessary collateral (Data Privacy Assignment). Our Company concludes data processing agreements with the third parties, in order to ensure the compliance of the process with the current legal framework, and the unhindered exercise of the rights of every natural person.
Furthermore, the Public Properties Company SA (ETAD SA) may transfer data to third-party cooperating companies (marketing companies) in order to inform the public about our services, promote our services and present our offers, provided that consent has been given by any natural person as mentioned above.
  • To the shareholder company "Hellenic Corporation of Assets and Participation S.A”.
ETAD SA may transfer personal data that it processes, such as employees, customers, etc., to the parent company and its sole shareholder, Hellenic Corporation of Assets and  Participation (EESYP) in the context of development, approval or control of its strategic planning, its economic activities and its financial elements and, in general, for the exercise by EESYP of all its rights as the sole shareholder within the purposes of its establishment and operation, as defined by the Law 4389/2016 in combination with Law 2190/1920.

Transfer of personal data outside the European Economic Area
Your personal data are not transfered to third countries [i.e. in countries outside the European Economic Area].
To exercise any of the above rights, you may contact the Data Protection Officer (DPO) Mrs. Marilena Bellou, postal address: 7, Voulis str., 105 62 Athens, email: mbellou@etasa.gr

Data Storage Period
The data storage period is decided on the basis of the following specific criteria, as the case may be:
When processing is imposed as an obligation under provisions of the applicable legal framework, your personal data shall be stored for as long as required by the relevant provisions.
When processing is conducted on a contractual basis or/and in order to take steps at your request prior to entering into a contract, your personal data are stored for as long as necessary for the performance of the contract and for the foundation, exercise, support or defence of legal claims under the contract and until their legal limitation. The above personal data may be retained for as long as it is determined by other tax or more specific legal provisions.
For the purposes of promoting our products and services and to the extent that the supply of your personal data is based on your consent, your personal data will be retained until your consent is withdrawn. This could be done by you at any time. The withdrawal of your consent does not affect the legality of processing, which is based on consent given in the period before the withdrawal.
To withdraw your consent, please contact the Data Protection Officer (DPO) Mr. Marilena Bellou, postal address: 7, Voulis str., 105 62 Athens, email: mbellou@etasa.gr
  • What are your rights in respect to your personal data
Every natural person whose data are being processed by The Public Properties Company SA (ETAD SA) enjoys the following rights:

Right of Access:
You have the right to be aware and verify the legitimacy of the processing. So, you have the right to access the data and get additional information about their processing.

Right to Rectification:
You have the right to study, correct, update or modify your personal data.

Right to Erasure:
You have the right to request the deletion of your personal data when we process it based on your consent or in order to protect our legitimate interests. In all other cases (such as, by way of indication, where there is a contract, obligation to process personal data required by law, public interest), such right shall be subject to specific restrictions or shall not exist, as the case may be.

Right to Restriction of Processing:
You have the right to request the limitation of the processing of your personal data in the following cases: (a) when the accuracy of the personal data is questioned and until such data is verified, (b) when you object to the deletion of personal data and request the limitation of their use rather than their deletion, (c) when such personal data are not needed for processing purposes, they are, however, indispensable for the foundation, exercise, support of legal claims, and (d) when you oppose to the processing and until it is verified that there are legitimate grounds that concern us and supersede the reasons for which you are opposed to the processing.

Right to object:
You are entitled to oppose the processing of your personal data, at all times, in case where, as described above, this is necessary for the purposes of legitimate interests pursued by us as controllers, as well as in the processing for direct marketing purposes and consumer profile training.

Right to data portability:
You have the right to receive your personal data free of charge in a format that allows you to access, use, and edit them with commonly used editing methods. Moreover, you have the right to ask us, if technically feasible, to pass the data directly to another controller. Such right to do so exists for the data you have provided to us and their process is carried out by automated means based on your consent or performance of a relevant contract.

Right to withdraw your consent:
Last, The Public Properties Company SA (ETAD SA) informs you that, where processing is based on your consent, you have the right to revoke it without affecting the legality of consent-based processing in the period prior to said revocation.
To exercise any of the above rights, you can contact the the Data Protection Officer (DPO) Mr. Marilena Bellou, postal address: 7, Voulis str., 105 62 Athens, email: mbellou@etasa.gr
Right to lodge a complaint to the Personal Data Protection Authority
You have the right to file a complaint with the Personal Data Protection Authority (www.dpa.gr): Switchboard: +30 210 6475600, Fax: +30 210 6475628, E-mail: contact@dpa.gr

Security of Personal Data
The Public Properties Company SA (“ETAD S.A”) shall implement appropriate technical and organizational measures aimed at the safe processing of personal data and the prevention of accidental loss or destruction and the unauthorized and/or unlawful access to, use, modification or disclosure thereof. In any case, the way in which internet operates and the fact that it is free to anyone cannot guarantee that unauthorized third parties will never be able to violate the applicable technical and organizational measures gaining access and, possibly, using personal data for unauthorized and/or unfair purposes.

Connections with other sites
Our site may contain links to foreign websites. The Public Properties Company SA (“ETAD SA”) is not responsible for the privacy practices or the content of other sites, which do not belong to The Public Properties Company SA (ETAD SA). Therefore, we suggest that you read carefully the privacy statements of these foreign sites.

Changes in the Privacy Notice
The information about our Company's privacy notice reflects the current state of data processing on our site. In case of changes in data processing, this information related to the data protection will be updated accordingly. We will always have the latest version of this information regarding the data protection on our site so that you are aware of the breadth of data processing on our site. We encourage you to be always aware of the way we process and protect your personal information. All changes in respect of this Privacy Notice will be known in time before these changes come into force.