PRIVACY POLICY

Information on the processing of personal data

The company "AS COMMERCIAL - INDUSTRIAL COMPANY OF COMPUTERS AND TOYS SA" and the distinctive title "AS COMPANY S.A." (hereinafter referred to as "AS COMPANY S.A.") attaches particular importance to the lawful processing, security and protection of your personal data, in any capacity you cooperate or communicate with us (such as, but not limited to, as customers, prospective customers, consumers, partners, suppliers, employees, prospective employees, former employees, employees of suppliers, participants in competitions and surveys, sponsors, shareholders and members of the Board of Directors, visitors to our website or generally individuals and third parties who cooperate or communicate with the company).

AS COMPANY S.A., as Personal Data Controller, undertakes to comply with the rules for the protection of the rights and freedoms of individuals with regard to the processing of personal data, in compliance with the General Data Protection Regulation 679/2016 (GDPR), the applicable Greek legislation and the decisions of the Personal Data Protection Authority.

With this Privacy Policy, the company provides you with all relevant information regarding the use and processing of your personal data, as well as your rights as data subjects, as required by Articles 12 to 14 GDPR.

 

1. Who is the Data Controller?

The company: "AS COMMERCIAL - INDUSTRIAL COMPUTER AND TOYS COMPANY SA" and the distinctive title "AS COMPANY S.A." Headquarters: Ionias Street, Oraiokastro Thessaloniki, P.C. 570 13, Greece Tel. Contact: 2310 572 000 E-mail: privacy@ascompany.gr

 

2. What is personal data and what personal data does AS COMPANY S.A. collect?

Personal data includes any information, in printed or electronic media, which may lead, alone or in combination with other information, to the identification / verification of the identity of a natural person.

Processing of Personal Data is the collection, registration, organization, adaptation, alteration, retrieval, search for information, use, transmission to third parties, dissemination, association, combination, restriction, deletion and destruction of Personal Data of natural persons.

AS COMPANY S.A., in the context of its activities and transactions, collects the following personal data:

• During your visit to our website www.ascompany.gr:

In case you simply visit our website, we process only those data collected by the cookies that you have allowed with your consent to be used, which are detailed in the Cookies Policy, which you can read here. In case you wish to contact our company for any reason (e.g. technical support, information about the company and its products, etc.) Fill in the corresponding contact form on https://about.ascompany.gr/epikoinonia/ website, through which we collect your email address, name, surname, address and contact number. To subscribe to the newsletter, we collect and maintain your name and email address. For the collection of the above data, your consent is required.

• During your visit to our website ir.ascompany.gr:

In principle, we do not collect your Data, only those collected by the cookies that you have allowed with your consent to be used, which are detailed in the Cookies Policy, which you can read here. In case you wish to contact our company for any reason (e.g. exercise of shareholder rights, corporate information, etc.), you fill in the corresponding contact form on https://ir.ascompany.gr/el/epikoinonia/ website, through which we collect your email address, name and surname. To keep up to date with company news, it is possible to subscribe to the newsletter, where we collect and maintain your email address. For the collection of the above data, your consent is required.

• For retail (B2B) customers:

AS COMPANY S.A. processes personal data relating to natural persons. In these cases, data relating exclusively to the processing and completion of your order are collected and processed. Regarding ordering products from the company's online store, the Customer is not required to have or create a personal account on www.ascompany.gr website. However, in case of account creation (option "Create account"), the company maintains and processes personal data, such as your identity details, name, address (home and email), telephone number (fixed and mobile), date of birth, postal address, order history. For the collection of the above data, your consent is required.

• For customers (potential or existing and through the company's B2B platform), suppliers, partners:

During your visit to https://b2b.ascompany.gr/gr/ website, we do not collect your Data, except those collected by the cookies that you have allowed with your consent to be used, which are detailed in the Cookies Policy, which you can read here.

AS COMPANY S.A. processes personal data relating to natural persons, sole enterprises, or even natural persons acting on behalf of a legal entity (e.g. legal representative of a company, contact person, etc.). In these cases, your identity data are collected and processed, such as name, address and email, telephone number (landline and mobile). Commercial and financial information, such as payment/billing details, shipping address of the products, contact details (exclusively for the execution of the order), business details, bank account number, work address, VAT number and Tax Office, data in relation to previous transactions or commercial contracts/agreements, etc.

• For the employees of our company:

Data such as social security number (AMKA), identity card number, marital status data, number and age of children, citizenship, records of salaries/allowances/gifts, CVs, work experience, level of education, diplomas, licenses, as well as information related to employee payroll and taxation and other data required by labor or social security legislation.

• For shareholders – investors:

Name, identification documents, investor's share code number (K.A.M.E.), securities account of the share, tax information, scope of business-activity, contact details, bank account number, details of proxies/authorized persons, details of shares and rights held thereon, details of dividends and capital returns, details of various requests submitted to AS COMPANY S.A., via electronic correspondence and/or via the contact form, etc.

• For those interested in receiving sponsorships:

In the case of natural persons / individuals: name, address, VAT number, Tax Office, name of contact person, contact telephone, email address, profession / activity of a person. This data is collected for the evaluation of applications and the possibility of contacting interested parties in order to respond to their request for sponsorships. If our answer is positive, the data of the interested parties are kept by our company for a period of five (5) years, so that we are able to evaluate the applications over time, otherwise the data are kept for one (1) year. For the submission and collection of the above data, your consent is required.

We receive the above information from you in person or through your authorized representatives, in the context of our relationship. We may also collect and process personal data from publicly available sources, commercial registers, the press, the media and the Internet, which we lawfully obtain and are permitted to process.

Processing of special categories of personal data: AS COMPANY S.A. does not collect or process, in principle, your personal data related to your racial or ethnic origin, your political opinions, your religious or philosophical beliefs or your trade union membership, your genetic or biometric data for the purpose of identifying you as a data subject, as well as health data or data concerning your sex life or sexual orientation.

Exceptionally, the company may collect and process the above data only if:

• you have expressly given your consent to this and for a specific purpose and specified time, e.g. a contract with an insurance company;

• processing is necessary for the exercise of certain rights or the performance of specific obligations, either on the part of our company or by you as a data subject (e.g. obligations and rights of labor law or social security);

• the data has been evidently made public by you;

• processing is necessary to protect your vital interests in case of physical or mental incapacity/inability to consent;

• processing is necessary for the purposes of assessing the worker's working capacity (e.g. ability to operate machinery) or raising awareness and creating appropriate working conditions for persons with disabilities or special needs. If you do not provide such information regarding disabilities or special needs, AS COMPANY S.A. will not be able to take the corresponding precautions.

• The processing is necessary for the establishment, exercise or support of legal claims of both you and our company.

• processing is necessary for reasons of substantial public interest, taking into account the principle of proportionality.

• The processing (health data and biometric data) is necessary in cases of extremely urgent and extraordinary circumstances (e.g. health crisis) to ensure the public interest and public health.
  
  

3. How are we entitled to process your data?

AS COMPANY S.A. is entitled to collect and process your personal data:

• either in the context of the contractual or commercial relationship between us, if the processing is necessary for the performance of the contract or before the conclusion of the contract, in order to take appropriate measures,

• either due to a legal obligation of our company as a controller, such as labor legislation compliance,

• or with your explicit consent. This consent should be given by your own clear affirmative action and be a free, specific and explicit indication of your agreement to the processing of your personal data. Consent may consist of a written statement, including by electronic means, or an oral statement. Silence or inaction is not perceived by us as consent.

Such a case, where your consent is required for the retention and processing of your data, is your subscription to our newsletter, your registration to the Club, the completion of contact forms, exclusively for communication purposes and the processing of your requests, the use of platforms operated by the company (eg B2B), participation in a competition, etc.

4. For what purposes do we process your data?

Based on the above legal bases (our contractual relationship or the provisions of the law or your explicit consent), we process your personal data for the following purposes:

• For the development, fulfillment and execution of the contract concluded between us. Indicatively, we mention the communication with you (telephone or electronic) for updates or notifications related to the products or services for which the contract has been concluded or the processing and use of your data for the management of payments / invoicing, the signing of contracts, as well as any processing necessary for the completion and execution of the contract. The company may use your email address to send you payment notifications, to send you information about changes to our services, as well as other notifications and disclosures related to the scope of the company's activities. In general, you cannot opt out of these communications, which are not related to marketing, but are required in the context of the relevant business relationship, nor can you refuse to provide information required to complete our business relationship, e.g. VAT number, bank account. In this case, our company will not be able to work with you.

• For the proper conduct of transactions through the B2C e-shop, the communication with you for the completion of your orders, your invoicing, the facilitation of deliveries, the general proper execution of your orders and the service of your requests.

• For the proper execution of transactions (e.g. through the B2B electronic platform), the communication with you for the completion of your orders, your invoicing, the facilitation of deliveries, the general 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. processes your information, which it collects either through the website or by telephone, to respond to your requests and questions, to resolve any problems, to update and respond to your suggestions and comments to improve our services or in order to serve you quickly and in the best way 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, however, you 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 General Meetings, to process requests submitted by shareholders, to fulfill the legal obligations of AS COMPANY S.A. regarding the prevention of financial crime, money laundering and risk of fraud, to notify the Athens Stock Exchange of obliged persons, for the publication of documents and data of AS COMPANY S.A. in the GEMI, in the Athens Stock Exchange or on our website, when required by law. For reasons of ensuring the quality of our services or the internal operation of the company, such as for the prevention of fraud and other criminal acts, for the physical security and protection of persons and property (eg video surveillance), For the fulfillment of legal obligations of the company arising from the current legislative and regulatory framework, for the management of the company's information systems and the optimization of security procedures.

• For marketing purposes. This purpose includes processing your data for promotional and advertising activities and for sending information about our products, training programs, seminars or events, actions and actions of our company via email. Regarding types of marketing communication (i) consent / acceptance (opt in) of such communication is required and (ii) you have the opportunity to withdraw consent / acceptance (opt out), if you no longer want to receive notifications regarding information and promotional actions of the company, by contacting our company by phone or electronically at the contact details you will find in this Privacy Policy, or through the contact form on our website.
  
  

5. How long do we keep your Personal Data?

AS COMPANY S.A. will store your Personal Data:

(i) for the time required to satisfy the purposes set out above, namely:

A. In case the processing is necessary for the execution of a transaction, the company retains your data throughout the period of the exchange relationship between us for as long as the legal obligation exists on the part of our company or, if specifically defined by law, for as long as the obligation to keep specific data is provided by law.

B. In case the processing is necessary for the performance of a contract to which the data subject is a party, the company retains your data throughout the period of our contractual relationship, as well as for a period of five (5) years from the last calendar day of the year of termination of your relationship with our company, for the possibility of our future cooperation / contact and for reasons of proof vis-à-vis the authorities and public services. During this time, you have the right to object to the use of your Personal Data and request the deletion of your data by our company. Exceptionally, the company retains your data beyond the aforementioned period, if it has a legitimate interest or legal obligation to do so or whenever your Personal Data is required so that the company can assert or defend its rights against legal claims.

C. In case the processing is necessary for compliance with a legal obligation of the controller for as long as the legal obligation exists on the part of our company or, if specifically defined in the legislation, for as long as the obligation to keep specific data is provided by law.

(ii) in case your data is processed with your consent, 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 lawfulness of processing based on consent before its withdrawal.

6. Why do I need to provide my Personal Data?

As a general principle, granting any consent and providing any Personal Data hereunder is entirely voluntary. There are generally no harmful consequences for you if you choose not to give your consent or provide your Personal Data. However, there are cases in which AS COMPANY S.A. will not be able to take action if it does not have specific Personal Data (e.g. if this Personal Data is required for the provision of our services or for your fast and effective service or for accessing and receiving the company's newsletter). In these cases, unfortunately AS COMPANY S.A. will not be able to provide you with what you wish without using your personal data.

7. How does AS COMPANY S.A. process my data?

Our company and its staff trained in personal data protection issues comply with the processing principles set out in the General Data Protection Regulation 679/2016 (legality, objectivity, transparency, purpose limitation, data minimization, accuracy, storage time limitation, integrity, confidentiality and accountability) and Law 4624/2019.

In any case, we take appropriate organizational and technical measures to ensure that your personal information is transferred, stored and processed in accordance with appropriate security standards and procedures and in accordance with the terms of this Policy and the applicable data protection laws. In the company we have trained and responsible staff and a Data Protection Officer, while we recognize the importance of protecting privacy and all your personal information. For this purpose, we have appropriate security policies and we use the appropriate technical and operational tools, such as anonymization, pseudonymization, data encryption, use of firewalls, authorized employees, staff training, periodic audits.

 

8. What are your rights when you provide us with your data?

AS COMPANY S.A. is committed to maintaining the confidentiality of your personal data and ensuring that you can easily exercise your rights. The exercise of all your legal rights below is carried out by completing a "special subject request form" provided by the company in the context of the relevant procedure for managing the subjects' requests. In order to exercise your rights, you only need to send this form to privacy@ascompany.gr email address and not any other documents. Any other documents sent will not be taken into account and will be destroyed immediately. You can contact the company by phone or through the website or at the above e-mail address in order to forward this special form.

In particular, regardless of the purpose or legal basis on which we process your data, you have the following rights:

1. Ask us for access and be informed about the data we hold about you (right of access).

2. Ask us to correct your data so that it is true and accurate (right to rectification).

3. Ask us to delete them, subject to the obligations and legal rights of the company, as detailed above (right to erasure).

4. Ask us to restrict the processing of your personal data (right to restriction).

5. Request to receive your personal data that you have provided to us in a structured, widely used and machine-readable format in order to transmit them directly to another legal entity without hindrance on our part (right to portability).

6. Object to the processing of your data, in particular if your data is collected for direct marketing purposes (right to object).

For each of the above rights, the company will respond to you within one (1) month from the receipt of the request or in case of objective difficulty, complexity of the request or the number of requests, the company will respond to a maximum of three (3) months, regarding your request, either by its completion or by the reasoned refusal to execute what you requested for legitimate reasons, explicitly specified in the General Data Protection Regulation (EU) 2016/679 - GDPR, ("Regulation"), in accordance with the relevant internal procedure.

If your requests are manifestly unfounded or excessive, especially due to their repetitive nature, the company may impose a reasonable fee, taking into account the administrative costs of providing the information or performing the requested action.

In case the company delays beyond the justified time to respond to your request as well as in any case where you consider that your rights are violated or the company is not consistent with the obligations of secure retention of your data, you are entitled to file a complaint with the competent supervisory authority (Personal Data Protection Authority, Athens, Kifisias 1-3, P.C. 115 23, Athens, contact@dpa.gr, +30-210 6475600).

 

9. Do we share your data with third parties?

We may share your personal information with third parties only under the terms of this privacy policy and in particular:

1. where required or approved by law or at the request of any public authority (e.g. government or other competent authorities);

2. where required, in order to provide you with services requested by you, in which case you will have been informed (e.g. to a transport company for the shipment of our products)

3. service providers and personal data processors, whom we use to provide and improve our services and support our business (e.g. insurance companies, software support and maintenance companies, website management, newsletter management).

4. subsidiaries of AS COMPANY S.A. in Greece and abroad (Romania - Cyprus).

5. to competent banking institutions, in case you choose to pay for your order by credit card. Your details (e.g. credit card number, card expiration date, as well as three-digit security code, etc.) are registered directly in the secure transaction environment of the cooperating credit institution and are not registered in the database of AS COMPANY S.A., thus ensuring the highest possible level of security.
   

6. the Athens Stock Exchange, the Central Securities Depository, the Hellenic Capital Market Commission, the Department of Deposits and Loans and the General Commercial Registry, the cooperating bank for the payment of dividend to shareholders.
   
   

10. Data Collection of Minors

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 holders of parental responsibility and only for the purposes of fulfilling a relevant transactional relationship in the interest of minors. It is noted that under no circumstances does the company deal directly with minors, and only deals with those exercising their parental responsibility.

11. Personal Data Breach

The company will report any illegal and proven breach of its database to all interested parties as well as to the competent supervisory authority, within seventy-two (72) hours of the breach, if it is obvious that the Data of employees, customers, partners, suppliers, consumers/visitors stored in recognizable form, have become the object of theft or other illegal action.

12. Changes to the Privacy Policy

This Privacy Policy may be amended when deemed necessary and in particular in view of the entry into force of Greek legislation implementing 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 review the changes, evaluate them and even object to or unsubscribe from a service or feature.

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. Therefore, we suggest that you carefully read the privacy statements of these foreign websites.

Subject-Natural Person Request Form

For directions on how to exercise your rights, please click to download, fill in the form and send it to privacy@ascompany.gr.