Privacy Policy – ΣΚΛΑΒΕΝΙΤΗΣ Κύπρου

Introduction

SKLAVENITIS CYPRUS limited attaches high importance in the protection of your Personal Data their security and your privacy when collecting and processing information about you. This Privacy Notice will inform you as to how “SKLAVENITIS CYPRUS limited” (hereinafter referred to as the “Company”, “we”, “us” and “our”) collects and processes information about you and in particular, your personal data; their collection, processing, retention, storage, security measures, the kind of personal data and the reason of collection and relevant information. We hereby assure you that this Privacy and Personal Data Protection Policy (“Policy”) fully respects and complies with the EU Regulation 679/2016 (“Regulation”) and the relevant Law 125 / I / 2018 of the Republic of Cyprus.

Useful Definitions

Personal Data is any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, indicatively by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

Controller is 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 is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data

The Controller

Regarding your personal data in cases we, as a company, determine the purposes and means of the processing, the Controller is the legal person: SKLAVENITIS CYPRUS Limited, address 11 Spyrou Kyprianou, 4043 Yermasoyia, Limassol, Cyprus, tel: +357 8000 0033, email: info@sklavenitiscyprus.com.cy.

Principles we adhere to

At SKLAVENITIS CYPRUS Limited, we are committed to and adhering to the following principles of processing personal data in accordance with Article 5 of the Regulation. The personal data is:

processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of ‘lawfulness, fairness and transparency’);
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (principle of ‘purpose limitation’);
adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (principle of ‘data minimisation’);
accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, erased or rectified without delay (principle of ‘accuracy’);
kept in a form which permits identification of data subjects for no longer than it is necessary or as required by relevant Laws (principle of ‘storage limitation’);
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (principle of ‘integrity and confidentiality’).

Finally, we are able to demonstrate compliance with the aforementioned principles (principle of ‘accountability’).

Collection of Personal Data

We, as the Controller, collect Personal Data from you in the following cases:

When you contact us physically, or by phone, or indirectly (e.g., through our webpage and/or e-mail, or through our collaborators, or through our Social Media accounts, etc.), in order to be informed regarding our products and services or ask relevant information;
When we provide you or a person you may indicate instead of you, products or services, if you cooperate with us, or if you are involved in events related to the offer of our products and services;
If you fill in any of our documents or when you submit a complaint to us;
When your personal data is disclosed to us by third parties – partners under your consent or based on contracts or agreements;
When you are connected to our webpage or visit our premises where a legal CCTC system is legally operating for security reasons;
When you are an employment candidate;
When you are one of our employees.

In addition, it is noted that we process personal data, which third parties, usually legal entities, disclose to us if we act as Processors on their behalf. In such case, these third parties are responsible to properly inform you.

Minors’ Personal Data

We do not collect and/or process as The Controller minors’ personal data without verifiable parental consent in cases when we are able to control it. For example, it is not possible to control information that is communicated to us without physical presence (e.g., online).

Kind of Personal Data we may collect about you as the Controller

Data from the following categories of personal information about you, may be collected and processed per case, in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:

Contact details with you or a natural person you may indicate instead of you (name, surname, address, telephone or fax number, email) and communication language;
Occupational information (occupation, position);
Identification data such as ID or passport number or equivalent and/or date of birth;
Information of those involved in agreements, such as necessary data from the above-mentioned information, nationality, object of the agreement or goods and services, contact person information, type of property, details of pledges and assignments if the agreement concerns property, reasons for donation if it refers to donations, signatures terms and amounts;
Data from the above categories and student ID number, language of communication, name of University / School of study for issuing cards to students;
Information that you include in the case of incoming electronic or ordinary mail;
Payment and transaction details (IBAN, account number, tax number, desired payment method, credit card details necessary data depending on the payment method, terms of payment, depositor’s details);
Data of recommendations or suggestions for improvement, through the corresponding form that you can find at the customer service points in our hypermarkets, or on the website;
Details of accidents or incidents, such as details of those involved and witnesses, evidence and related information during the investigation;
Client history (satisfaction, transaction details, claims, problems, terms) and information related to assessing persons and situations;
Apps / websites / social media related data (cookies, full name or nickname, photograph, information you publicly disclose and comments on social media, or email attachments);
Your image when with your consent it appears on our social media accounts or our website or when you visit our premises where a video surveillance system with image recording is in operation for security purposes;
Employment data and/or data referred in your Curriculum Vitae and data related to studies, competencies or previous working experience if you disclose this information to us or information attached in emails you send us.

It is noted that we collect some more kind of personal data about our employees; they are informed through documents, manuals, policies and procedures and information internally provided.

Purposes of Processing & the Legal Bases of Data Processing

The processing of personal data is based on one of the “legal bases” as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data).

The legal bases on which the collection and processing of your personal data by us is based (in most of the cases) are, the consent, the compliance in performing our contractual obligations, the compliance with our legal and statutory obligations, and the safeguarding our legitimate interests, provided that safeguarding our legitimate interests overrides your rights, interests and fundamental freedoms. In the case of special categories of personal data, the legal basis is mainly the explicit consent.

The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:

Consent: when you communicate with us in any way directly or indirectly as interested in our products and services, when you are interested in working with us or cooperating with us, when you apply for a student’s or professional’s discount card, when you fill in our forms, when you make a complaint, when you visit our social media accounts, when you expressly and voluntarily consent to being photographed or upload your photograph, when you give us your business card.

Commitment to perform our contractual obligations: when you have agreed to receive our products or services, when you are our employee or collaborator, during the payment of our liabilities, or when we are contacting you in the framework of a contract.

Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or according the Government’s decisions, acts and Laws.

Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, for the assessment of persons and situations or in order to safeguard the security of our premises through the CCTV system.

Our employees are informed about the processing purposes and the legal bases, internally, through specific documents.

Retention of Data Period

We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose.

Data collected on the basis of contractual and legal obligations shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework.

Data that may be needed for our legitimate interests as the Controller shall be kept until the reason for keeping them ceases, or until the limitation of applicable rights as the case may be.

Especially for the data that we process based on your consent, they are kept from the receipt of your consent and until it is revoked, or until the reason for keeping it ceases. The withdrawal of consent does not affect the legality of the processing, which was carried out before the withdrawal of consent.

Your CV received as a job candidate and any related information, is retained until your consent is withdrawn or for 12 months. If we cooperate with you, your CV is transferred to the employee file, and it is noted that in such case, consent is no longer the legal basis for processing, but processing is based within the framework of a contract.

The personal data recorded in the CCTV system we legally operate is kept for 15 days.

Information that is no longer necessary is safely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for the specific purpose.

How we ensure the security of Personal Data

We have received reasonable organisational and technical measures to protect the personal data we collect, and in particular any specific categories of personal data. We follow international standards and practices to ensure the security of our networks. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:

Access to personal data is restricted to a limited number of authorised employees under a need-to-know basis, and the necessary data transfer is done by secure procedures.
Pseydonymisation of personal data is used where possible.
Our employees are bound by confidentiality clauses in relevant agreements, and we provide them limited classified access to the necessary data only.
We select trusted collaborators who are bound in writing, in accordance with Article 28 of the Regulation, with the same obligations regarding the protection of personal data. We reserve the right to audit them in accordance with Article 28 (3) (h).
In our ICT systems used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access or other illegal processing.
In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.

Some of the security measures are not announced for obvious reasons.

To whom the Data may be disclosed

There may be instances, where we will share your personal data with third parties, including, service providers and business partners or other legal entities, where required by Law, where necessary to manage our relationships, or where we have a legitimate interest to do so.

We receive measures to ensure that the recipients of personal data are kept to a minimum and be bound by similar procedures to protect your personal data. The personal data that we collect and process as the Controller are primarily processed by the company’s staff, and are disclosed to third parties, provided that the legality of such disclosure is fully justified and that these third parties apply corresponding legal and legitimate processing practices.

Specific data from those that we lawfully process as the Controller, may be accessed (or disclosed) on a case-by-case basis by:

Any relating supervisory or prosecuting authority within its role;
Any public or judicial authority where required by law or judicial decision.
Our auditor, for audit related financial data, under confidentiality.
Company’s advocate, for whatever data is required in legal cases, under confidentiality.
The Insurance cooperating company and only for the relevant part of the information.
Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
The training or systems consultants, the trainer and HRDA (training Authority) for training or systems control issues and only for the necessary pieces of information and data.

We do not allow third party service providers to use your personal data for their own purposes. We only allow your personal data to be processed for specified purposes and in accordance with our own instructions. The above third parties, other than the Authorities, have contractually committed to the Company, that they will use the personal data only for a specific reason per third party, will not transmit this personal information to other third parties, as well as that they will not share it with third parties unless required by Law or Court order.

Territorial Scope – Transfer to Third Countries

The personal data we collect is processed within the European Economic Area (EEA). No personal data is transferred to Third Countries or International Organizations.

Your rights as a Data Subject and how you can exercise them

You have the rights

To be informed;
To consent where this is the legal basis for processing;
The right of access to your personal data;
The rights of rectification and erasure (in cases it is permitted);
The right to restriction of processing;
The right to data portability, and the right to object.

The use of personal data by an automated system in order to make a decision without human intervention, constitutes automated decision making. We do not use automated decision-making tools, nor we carry out profiling.

Your right to consent is provided by design and by default in every case where it is required. The company has designed and implemented consent forms when required. If processing is based on your consent, you may withdraw it at any time by contacting us.

The right to be informed is exercised through this privacy and personal data protection notification. In some cases, it is also mentioned in documents – forms we are using. You may ask our Privacy Policy in paper form by contacting us. Your right to be informed regarding the video surveillance system (CCTV), that is legally operating with image recording for the security of people and the property, is satisfied by having appropriate information signs before you enter the recording range. Additional update information (2nd level or 2nd layer information) is available at the customer service points of our Hypermarkets.

You also have the following rights, if you exercise them in writing directly or through legal representation and after it has been confirmed that you are the data subject.

Right of access: you have the right to obtain from us confirmation as to whether or not your personal data is being processed as well as other relevant information, and, where that is the case, access to your personal data.

Right of rectification: you have the right of rectification of your inaccurate personal data as well as to have incomplete personal data completed by providing a supplementary statement.

Note: Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process.

Right to erasure (‘right to be forgotten’); we have to answer such right when:

your personal data is no longer necessary in relation to the purposes for which we collected it;
you withdraw your consent on which the processing is based and where there is no other legal basis for the processing;
your personal data has been unlawfully processed;
your personal data has to be erased for compliance with a legal obligation we are subject to;
your personal data has been collected in relation to the offer of information society services and at that time you were minor.

We reserve the right to refuse this right, for whatever period of time is required, if the processing is necessary for compliance with any legal obligation we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according to Article 17 § 3).

Right to restriction of processing; you have the right to restriction of processing when:

you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
we no longer need your personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;
you objected to processing pending the verification whether our legitimate grounds override those of yours.

Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format, and under an explicit request such data to be transferred to both you and another natural or legal person who will process it. This applies when the following two conditions are simultaneously met: a) the processing is based on your consent, or is necessary for the performance of a contract to which you are a party, and b) the processing is carried out by automated means.

Right to object: you have the right to object to the processing of your data at any time when the reason for the processing relates to direct marketing.

All of the above applies to the case where we act as the Controller. For the cases where we are the Processors, the person in charge of informing you, as well as handling your requests, is the respective Controller.

In the event that you make such request in a written or electronic form regarding any of the above rights, we will assess your request and respond within one month of its receipt, either for its satisfaction, or to provide you with objective reasons preventing it from being satisfied, or, given the complexity of the request and the number of requests at the given time, request an extension of response for a further two months period (according to Article 12.3 of the GDPR).

The exercise of your rights is free of charge, by sending a relevant request i.e., letter or email to our Data Protection Officer listed below. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to answer or charge you an administrative fee.
If you are dissatisfied with the use of your data by us, or our response after exercising your rights, you have the right to lodge a complaint with a supervisory authority.

Personal Data Breach

In the event of a breach of the confidentiality, the integrity or the availability of the personal data processed, we will take the following measures (in accordance with Article 33 and 34 of the Regulation in case we are the Controller) and we will:

Assess it in order to implement the appropriate procedures needed to limit the breach;
Examine the extent of the breach and the sensitivity of the data included and we will evaluate the risk and its impact on your rights and freedoms;
Endeavour to reduce as much as possible the damage that is or may be caused;
Notify within a time limit of 72 hours of becoming aware of the breach, the National Personal Data Protection Authority, if required;
Assess the impact on your privacy and take appropriate measures to prevent the repeating of the incident.

In the event we are the Processor, we will inform the Controller as soon as possible.

Links to other Websites

Our website may contain links to other websites that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third-party site. We recommend that you review the Privacy Policy for each site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Contact details with the National Data Protection Authority

Cyprus Personal Data Protection Authority, 1 Iasonos Street, 1082 Nicosia, telephone +357.22818456, e-mail: commissioner@dataprotection.gov.cy.
Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=celex%3A32016R0679.

Contact details with our Data Protection Officer

If at any time you want to contact us or make a request regarding your rights or any other matter relating to the protection of personal data you may contact our Data Protection Officer: telephone +357 8000 0033, email: cy.gdpr@sklavenitis.com.
Communication languages are Greek and English.

Update of this Policy

This Policy was updated on 03.11.2021 and will be reviewed when there is a significant change. This review will be available on our website, with a note of the effective date. You may find a hard copy of this Policy at our premises or may be dispatched at your request.