Privacy Policy
PRIVACY NOTICE
Information on personal data processing
The company under the name “AS COMMERCIAL AND INDUSTRIAL COMPANY OF COMPUTERS AND GAMES S.A” and the distinctive title “AS COMPANY S.A.” (hereinafter “AS COMPANY S.A.”) takes into serious consideration the lawful processing, security and protection of your personal data, regardless of the capacity under which you may be working with or contacting our company (including but not limited to customers, prospective customers, consumers, affiliates, suppliers, employees, prospective employees, former employees, employees of our suppliers, participants in competitions and surveys, sponsored, shareholders and board members, web site visitors or individuals and third parties who cooperate or communicate with our company).
Being a Data Controller AS COMPANY S.A. is committed to implementing all regulations concerning the protection of personal rights and freedoms with regard to the processing of personal data, in compliance with the General Data Protection Regulation 679/2016 (GDPR), the Greek legislative framework in force and the decisions of the Hellenic Data Protection Authority (HDPA).
With this Privacy Notice the company wishes to inform you as to how we use and process your personal data, as well as on your rights as data subjects, according to articles 12 – 14 GDPR.
1. Who is responsible for Data Processing?
|
The company named:
“AS COMMERCIAL AND INDUSTRIAL COMPANY OF COMPUTERS AND GAMES S.A” and the distinctive title “AS COMPANY S.A.”
Registered offices: Ionias street, Oreokastro, Thessaloniki, P.C. 570 13, Greece Tel.: +30 2310 572 000 Email: privacy@ascompany.gr |
2. What is personal data and which types of personal data AS COMPANY S.A. collects?
Personal data means any information found in either printed or electronic media that may lead itself or in combination with other information, to the identification/ verification of the identity of a natural person.
Personal Data Processing is the collection, registration, organization, storage, customization, modification, retrieval, search of information, use, transmission to third parties, dissemination, association, combination, restriction, deletion and destruction of Personal Data regarding natural persons.
In connection with its business activities and transactions AS COMPANY S.A. collects the following personal data:
• During your visit at our website www.ascompany.gr:
Generally, we do not collect your Data, except those collected from cookies that you have given your consent to be used, which are mentioned in detail in our Cookies Policy, which you can read here. If you wish to contact our company for any reason (e.g. technical support, information about the company and its products, etc.), please fill out the contact form on the website where we collect information, such as your email address, first name, last name, address and phone number. For your subscription to the newsletter, we collect and maintain your full name and email address. Your consent is required to collect the above data.
• For Clients - Members of the Club:
Your ID data, such as name and surname, address (residence and email), phone number (home and mobile), date of birth. Your consent is required to collect the above data.
• For the employees of our company:
Data, such as Social Security Number, ID number, family status data, number and age of children, citizenship, salary / allowance / gift records, CVs, experience, level of education, diplomas, licenses, information related to payroll and taxation of employees and other data required by labor or social legislation.
• For customers, suppliers, partners:
Commercial and financial information, such as payment/ debit information, shipping address of the products, contact details (exclusively for the execution of the order), business information, bank account number, work address, VAT number and Competent Tax Authority, information regarding previous transactions or commercial contracts / agreements, etc.
• For shareholders - investors:
Full name, identification documents, investor unit code number, unit securities account, tax data, scope of business-activity, contact details, bank account number, details of proxies/authorized persons, details of shares and rights held thereon, details of various requests submitted to AS COMPANY S.A., via e-mail and/or via the contact form, etc.
• For interested in sponsorship:
For natural persons / individuals: first name, last name, address and phone number, VAT number and Competent Tax Authority, Name of contact person, email, occupation/ profession. The aforementioned data is collected in order to evaluate applications and to communicate with the applicants so as to respond their requests for sponsorship. If our answer in your request is affirmative, the data is retained by our company for a period of five (5) years, so that we are able to evaluate the applications over time, otherwise the data is retained for one (1) year. Your consent is required to collect the above data.
The aforementioned personal data is either collected directly by you, or from your authorized representatives as part of our business relation. We may also collect and process personal data from publicly available sources, such as commercial registries, the press, the media or the internet, which we acquire legally and are allowed to process.
Processing of special categories of personal data: AS COMPANY S.A. does not collect or use personal data relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade-union memberships, genetic or biometric data for the purpose of uniquely identifying you as a data subject, as well as data concerning your health, your sex life or your sexual orientation.
The company may exceptionally collect and process the above data if:
• you have given explicit consent to the processing of those personal data for one or more specified purposes, for example contract with the insurance company,
• processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the company or you as a data subject (e.g. in the fields of employment, social security and social protection law),
• the personal data are manifestly made public by you,
• processing is necessary to protect your vital interests where you are physically or legally incapable of giving consent,
• processing is necessary for the assessment of the working capacity of an employee (e.g. ability to operate machinery) or for raising awareness and developing the appropriate working conditions for people with disabilities or special needs. If you do not provide us with information concerning any disabilities or special needs AS COMPANY S.A. will not be able to take the appropriate precautions,
• processing is necessary for the establishment, exercise or defense of legal claims, both yours and the company’s,
• processing is necessary for reasons of substantial public interest having taken into account the principle of proportionality,
• the processing (health data and biometric data) is necessary in cases of extremely urgent and emergency situations (e.g. health crisis) to ensure the public interest and public health.
3. How do we process your personal data?
AS COMPANY S.A. is entitled to collect and process your personal data in the following circumstances:
- within the framework of our contractual or commercial relation, where data processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract,
- for compliance with a legal obligation of our company, where the company is Data Controller, for instance compliance with labor law.
- after your explicit consent. This consent should be given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the processing of personal data relating to you. The consent may be either in the form of a written statement, including electronic means, or oral statements. We shall not consider silence or inactivity to be consent.
Your subscription to our newsletter or to our Club, the completion of contact forms, exclusively for the purpose of communication and processing your requests, etc. requires your consent so as to maintain and process your data.
4. Purposes for which we will process your personal data
In compliance with the aforementioned legal bases (our contractual relation, the provisions of law or your explicit consent) we process your personal data for the following purposes:
• For developing, performing and fulfilling a contractual agreement. As for instance, corresponding with you (by email or telephone) in order to notify you about products or services relevant to our contractual agreement, or processing your personal data for payment/billing management, as well as any form of processing that is necessary for implementing and performing a contract. AS COMPANY S.A. may use your email address to send you payment notices, information regarding changes in our services, or other notifications that may be relevant to the company’s field of activities. Users in general, cannot choose to opt out of these forms of communication as they are not related to marketing, but are essential to our transactional relations, nor they can refuse to provide this information required to complete our business relationship, e.g. Tax ID, bank account. In this case, our company will not be able to work with you.
• For the proper conduct of transactions (B2B), communication with you for the completion of your orders, your invoicing, the facilitation of deliveries, the generally proper execution of your orders and the service of your requests.
• For your support / service regarding the services / products of our company. AS COMPANY S.A. collects and processes your own information, which we collect either through the website or by phone, to answer your requests and questions, to resolve any issues, to update and respond to your suggestions and comments on improving our services or to to serve you quickly and optimally in your next transaction / contact with our company. Also, AS COMPANY S.A. may invite you to participate in questionnaires and surveys. These questionnaires and surveys will generally be designed in such a way that the answers will not require Personal Data. If you nevertheless enter Personal Data in a questionnaire or survey, AS COMPANY S.A. may use such Personal Data to improve its products and services.
• To enable the participation and exercise of shareholders' rights in the General Meetings, for the processing of requests submitted by shareholders, for the fulfilment of AS COMPANY's legal obligations regarding the prevention of financial crime, money laundering and fraud risk, for the notification of the Athens Stock Exchange of transactions of liable persons, for the publication of AS COMPANY's acts and data in the General Register of Companies, the Athens Stock Exchange or on our website, when required by law.
• For safeguarding the quality of our services or the company’s internal function, as for example for the prevention of fraud and other criminal offences, for the physical safety and protection of persons and property (e.g. video surveillance), for compliance with a company’s legal obligation deriving from the current legislative and regulatory framework, for the company’s information systems management and for optimizing safety procedures.
• For marketing purposes. This purpose includes the processing of your data for promotional and advertising activities as well as information sent to you about our products, educational programs, seminars or events, actions and activities of our company through various means (email or SMS). Regarding the types of communication that relate to marketing (i) opt-in is required and (ii) you have the opportunity to opt out if you do not wish to receive additional notifications regarding company information and promotions. Opt out is possible by contacting our company by phone or by email at the contact details found in this Privacy Policy or through the contact form on our website.
5. How long we retain your Personal Data?
AS COMPANY S.A. will retain your personal data:
(i) for the period required to meet the objectives set out above and more specifically:
Α. Where processing is necessary for the performance of a contract to which the data subject is a party, the Company retains your data throughout the contractual relationship as well as for an additional period of five (5) years commencing from the last calendar day of the year of termination of your relationship with our company. We retain your data in case of a future cooperation / contact as well as for proving against the authorities and public services. During this time, you have the right to object to the use of your Personal Data and to request the deletion of your data from our company. Exceptionally, the company retains your data beyond the aforementioned period, provided that it has a legitimate interest or legal obligation to do so or whenever your Personal Data is required in order for the company to assert or defend its rights against legal claims.
Β. Where processing is necessary to comply with a legal obligation of the data controller, for as long as our company has this legal obligation or for as long as it is provided by law.
(ii) if your data is processed after your consent, we retain your data until you withdraw your consent. You have the right to withdraw your consent at any time. However, the withdrawal of consent does not affect the legality of the consent-based treatment prior to its withdrawal.
6. Why should I provide you with my personal data?
As a general principle, providing us with your consent and any Personal Data under the present notice is completely voluntary. Therefore, there will not be any harmful effects if you choose not to provide us with such consent or Personal Data. There may be certain occasions, however, where AS COMPANY S.A. will not be able to take action, unless provided with specific Personal Data, as these data are essential, for instance, for the rendering of our services or for a fast and effective customer service, or for giving you access to our company’s newsletter. Unfortunately, in such circumstances, AS COMPANY S.A. will not be able to provide you with what you require without your Personal Data.
7. How does AS COMPANY S.A. process my Personal Data?
Our company as well as our employees, who are trained in personal data related matters, comply with the processing principles set out in the General Data Protection Regulation 679/2016 (lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality). In any case we take the necessary organizational and technical measures to ensure that your personal information is transferred, stored and processed in accordance with the appropriate standards and safety procedures and in compliance with the terms of the present Policy Notice and the current legislation on data protection. Our company has trained authorized personnel and has appointed a Data Protection Officer as it recognizes the importance of protecting your privacy and your personal information. For this purpose, we apply all the appropriate safety policies and use all the proper technical and operational tools, such as anonymisation, pseudonymisation, data encryption, firewalls, authorized employees, personnel training, and periodic inspections.
8. Which are your rights when you provide us with your data?
AS COMPANY S.A. is committed to respecting the confidentiality of your personal data and to ensuring that you are able to exercise your rights easily. The exercise of all the following legal rights is carried out by completing a "special data subject’s request form" provided by the company in the context of the relevant process of managing the subjects' requests. In order to exercise your rights, it is required to send only this form to the email address privacy@ascompany.gr and not other documents. Any other documents sent will not be considered and will be destroyed immediately. You can contact the company by phone or through the website or at the above email address, in order to be forwarded this special form.
In particular and regardless of the purpose, or the legal framework under which we process your data, you have the following rights:
1. The right to request access and to be informed of the personal data that we hold about you (right of access).
2. To request correction of your data in order for such data to be correct and accurate (right of rectification).
3. To ask for the deletion of your personal data, without prejudice to the company’s obligation and legal rights, as set out above (right to be forgotten).
4. To request for restriction of the processing of your data (right of restriction).
5. To request the receipt of the personal data you have provided the company with in a structured, commonly used, machine-readable format, in order to transfer it to a third party you have chosen without us objecting to such a transfer (right to portability).
6. To object to the processing of your personal data on the basis of your legitimate interests (right of objection).
For each of the above rights, the company will respond to you within one (1) month from receipt of the request or, in case of objective difficulty, complexity of the request or the number of requests, the company will respond within a maximum period of three (3) months in total, on your request, either by closing it or by a reasoned refusal to perform what you have requested for legitimate reasons, expressly identified in the General Data Protection Regulation (EU) 2016/679 - GDPR, ("Regulation"), in accordance with the relevant internal procedure provided for.
If your requests are manifestly unfounded or excessive, in particular because of their repetitive nature, the company may impose a reasonable fee, taking into account the administrative costs of providing the information or carrying out the requested action.
In the event that the company delays beyond the justified period of time to respond to your request and in any case where you believe that your rights are violated or the company is not consistent with its obligations to keep your data secure, you have the right to file a complaint with the competent supervisory authority, (Personal Data Protection Authority, "DPA", Athens Kifissia 1-3, P.K. 115 23, Athens, contact@dpa.gr, +30-210 6475600).
9. Data transfers to third parties
We may share your personal information with third parties under the terms of this privacy policy, and in particular:
(a) where required or approved by law or at the request of any public authority (e.g. governmental or other competent authorities),
(b) where necessary, in order to provide you with the services you have requested, in which case you will be informed (e.g. to a shipping company for the shipment of our products),
(c) to service providers and personal data processors, which we use to provide and improve our services and support our business (eg insurance companies, support companies and maintenance companies, website management companies, management of newsletters).
(d) to subsidiaries of AS COMPANY S.A. in Greece and abroad (Romania - Cyprus).
(e) to competent banking institutions, in case you choose to pay for your order by credit card. Your details (e.g. credit card number, card expiry date, as well as the three-digit security code, etc.) are entered directly into the secure transaction environment of the cooperating credit institution and are not entered into AS COMPANY's database, thus ensuring the maximum possible level of security.
(f) to the Athens Stock Exchange, the Central Securities Depository, the Capital Market Committee, the Deposits and Loans Department and the General Commercial Register.
10. Juvenile Data Collection
We do not knowingly collect any information from any person under the age of 15. Any personal data of minors are kept by the company only if they have been provided by the custodians and only for the purposes of fulfilling a relevant transaction in the interest of minors. It is noted that in no case does the company deal directly with minors, and only deals with those who exercise parental responsibility.
We may modify the information in this Privacy Notice, when deemed necessary and in particular when the Greek legislation on the application of GDPR entries in force, having regard to the relevant jurisprudence of the European and Greek courts on the protection of personal data and the recommendations of the Hellenic Data Protection Authority. In such a case, you will be notified accordingly, so that you have the ability to review, evaluate or even object to these changes and ask to be deleted from a service or operation.
We recommend that you regularly check for changes in the privacy notice that is always posted on our website. This website may contain links to other websites. AS COMPANY S.A. is not responsible for the privacy practices or content of other websites that we do not control. Therefore, we strongly advise you to read the privacy terms of the aforementioned websites.
11. Breach of Personal Data
The company will report any illegal and proven breach of its database to all directly concerned as well as to the competent supervisory authority (DPA), within seventy-two (72) hours of the breach, provided that it is obvious that the Employees, customers, partners, suppliers, consumers/visitors data stored in a recognizable form, have become a product of theft.
12. Changes to the Privacy Policy
This Privacy Policy may be amended when necessary and in particular in view of the entry into force of the Greek legislation on the application of the GDPR in the Greek legal order, as well as taking into account the relevant case law of the European and Greek courts on personal data protection issues and the recommendations of the Hellenic Data Protection Authority. In this case, we will notify you in various ways so that you can check the changes, evaluate them and even object or unsubscribe from a service or function.
In any case, we suggest that you check this Policy from time to time, which will always be posted on our website. This website may contain links to foreign websites. AS COMPANY S.A. is not responsible for the privacy practices or content of other websites that do not belong to it. Consequently, we recommend that you carefully read the privacy statements of these foreign websites.
Data Subject’s Request Form
For how to exercise rights, please click to download, complete the form and send it to privacy@ascompany.gr.
