This notice sets out details of how personal information relating to you, as a tenant, adviser, or applicant, as an authorized representative/agent or beneficial owner of legal entities (“Personal Data”) will be handled by [Sodia Capital Management] (referred to as ‘we’, ‘us’, ’our’ or ‘the Company’) as controller of the Personal Data and / or on the Company’s behalf by its third party service providers in accordance with the General Data Protection Regulation (“GDPR”), the Greece Data Protection Law 125(I)2018 as amended or replaced from time to time, Law 4624/2019 (hereinafter the “Greece Data Protection Law”). The Company is committed to protecting your privacy and handling your data in an open and transparent manner.
This privacy statement;
- explains how we collect your personal data and how we use it in the provision of services or the conduct of our obligations to you
- tells you about your rights under the local data protection law and the EU General Data Protection Regulation (‘GDPR’)
- contains information about when we share your personal data with third parties (for example, our service providers or suppliers)
However, if you have any questions or concerns in relation to this Privacy Notice please contact Sodia Capital Management at (+30) 2111031360 or send e-mail to firstname.lastname@example.org
This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their use of your personal data.
1. WHAT INFORMATION WE MAY COLLECT AND HOW WE USE IT
For persons making enquiries or providing contact information on this website: this might include information relating to property management services, emails, call recordings and website usage data. This may also include technical data (cookies, internet protocol address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, online identified, location data and other similar identifying information required for the customer’s device(s) to communicate with websites and applications on the internet).
You may give us your Identity, Contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide:
- When you subscribe to our service or publications;
- When you request marketing to be sent to you;
- If you contact us through social media; or
- If you give us some feedback.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data for the legitimate purposes for which we have collected it. If we need to process your personal data for a different purpose that is not compatible with the original purpose that we collected your personal data, we will let you know.
We may process your personal data for a different purpose and without your consent where it is necessary for us to comply with our legal obligations.
Below we summarize the purposes for which we are processing your Personal Data and the legal bases on which we rely in each case.
A. For compliance with a legal obligation
We may have legal obligations that oblige us to collate, retain, process and potentially transfer personal data in relation to you, these include health and safety regulations, anti-money laundering and counter-terrorist financing directives and laws and tax laws. There may also be various supervisory authorities to whose laws and regulations we are subject e.g. the tax authorities, the Unit for Combatting Money-Laundering.
B. For the purposes of safeguarding legitimate interests
We may process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information.
Examples of such processing activities include:
- Means and processes we undertake to provide for the Company’s IT and system security, preventing potential crime, asset security, admittance controls and anti-trespassing measures,
- Sharing your personal data within the Company’s group and shareholder,
C. You have provided your consent
In order to manage and administer your request, either you may provide personal data to us, either on the website, by phone, email or post. This information is collated and processed based on the consent that you provide while submitting this information. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected. Also, we will no longer be in a position to retain your data in order to provide further services.
Please note that you have a right to object to the processing of your Personal Data where that processing is carried out for our legitimate interests or to withdraw your consent, should we rely upon your consent for processing the special categories of data specified above.
In all instances in which we request your personal information, we will, where applicable, identify if there is a statutory reason for requesting such information and we will explain the consequences for you if you do not provide it.
You have the right to withdraw your consent for us to use your personal data for marketing purposes at any time. If you do withdraw your consent, this will result in us ceasing to market goods and services to you.
Should we send any marketing messages to you, you can ask us to stop sending you these at any time by:
- Following the opt-out links on any marketing message sent to you;
- Contacting us at any time by emailing to email@example.com or by calling to (+30) 211 10 31 360.
3. DATA SECURITY
Once we have received your personal data, we will use reasonable and necessary procedures and security measures to try and prevent unauthorized access. We limit access your personal data to those individuals and other parties who need to know it and who are subject to a duty of confidentiality.
4. DATA BREACHES
If we become aware of a data breach, we may notify the Hellenic Data Protection Authority (HDPA). Protection provided that the breach is likely to result in a risk to you. If we believe that the data breach is more serious and could result in a high risk to you, we may notify you in accordance with our legal requirements.
5. DATA RETENTION
We will keep your personal data for as long as we have a business relationship with you as an individual or in respect of our dealings with a legal entity you are authorized to represent or are beneficial owner and thereafter as required or permitted by law.
Once our business relationship with you (or the legal or natural person which/who you are authorized to represent or are the beneficial owner of) has ended, we may keep your data in accordance with the Hellenic Data Protection Authority (HDPA) (https://www.dpa.gr).
6. YOUR LEGAL RIGHTS
- Receive details with regard to the personal data that we hold on you and request access to your personal data. To raise a request please contact us at firstname.lastname@example.org
- Request correction [rectification] of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us continuing to process it.
- Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
- Request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if;
- it is not accurate;
- it has been used unlawfully but you do not wish for us to delete it;
- it is not relevant anymore, but you want us to keep it for use in possible legal claims;
- you have already asked us to stop using your personal data but you are waiting us to confirm if we have legitimate grounds to use your data.
- Request to receive a copy of the personal data concerning you in a format that is structured and commonly used and transmit such data to other organizations. You also have the right to have your personal data transmitted directly by ourselves to other organizations you will name.
- Withdraw the consent that you gave us with regard to the processing of your personal data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you. To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact email@example.com
- Right to lodge a complaint
If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us, you have the right to complain by writing to us as the address on this website or email us at firstname.lastname@example.org
- You also have the right to complain to the Hellenic Data Protection Authority. Find out on their website how to submit a complaint (https://www.dpa.gr/complaint).
7. CHANGES TO THIS PRIVACY STATEMENT
We may modify or amend this privacy statement from time to time.
A current and up to date statement will be available on our website. We encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.