1. Personal data protection policy

LOTOS Properties recognizes the importance of personal data protection and sets as one of its main objectives the preservation of the confidentiality of your personal data. The Privacy Policy is fully compatible with the European Regulation for the protection of natural persons with regard to the processing of personal data and Greek Law and aims to inform you about the information and personal data collected.

Before providing your personal data, LOTOS Properties invites you to carefully review our Privacy Policy, as it contains important information about the protection of personal data and the protection measures we have adopted to ensure the privacy of your data and full compliance with applicable law. We inform you that your data will be processed in accordance with the principles of lawfulness, fairness, transparency, accuracy, purpose and time limitation of storage, minimization, integrity and data confidentiality. The processing of your data is carried out solely for the purposes which arise from the scope of LOTOS Properties’ activities and only for the provision of our services. Details of our offered services are presented on our corporate website lotosproperties.com

2. What personal data we collect and why

• Contact details of individuals

Customers: first name, surname, company, position, title, capacity, work address, telephone number, fax number, email address of legal representatives, contact representatives and personnel with whom we work.

The legal basis for the aforementioned data collection is the explicit consent of the data subject who provides the necessary information, the performance of the contract between us, the legitimate interest of LOTOS Properties as well as the legal obligation of LOTOS Properties (if applicable).

• Purpose and principles of the collection of personal data

LOTOS Properties collects and processes the personal data of its customers solely in the context of fulfilling its purposes and functions and more precisely for the purpose of communicating with them. The processing is limited to the personal data that is necessary and appropriate for the fulfilment of the purposes and functions of the controller. Processing is subject to the rules of the General Data Protection Regulation and relevant EU law, Greek law and relevant international treaties and conventions.

• Embedded content from other websites

Articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in exactly the same way as if the visitor had visited the other website.

These sites may collect data about you, use cookies, incorporate additional third-party tracking, and track your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that site.

3. For how long we keep your data

The period of retention of personal data depends on the lawful basis of processing, as detailed below:

• In the case where the legitimate basis of processing is the exercise of legitimate interest, the processing and retention of personal data will be carried out for as long as it is deemed necessary to achieve the intended purpose of LOTOS Properties, and for as long as still required until the limitation period of any relevant claims has expired (Article 6(f) of the GDPR).

• In the event that personal data is provided with the consent of the data subject in the context of their registration to the Website services, we will retain the data until the consent granted is withdrawn by the data subject. If, for whatever reason, this is discontinued, we will retain it for as long as necessary until the limitation period for any relevant claims has expired (Article 6(a) of the GDPR).

• Where the legitimate basis of the processing is the performance of the contract, we will retain the data for as long as you maintain a contractual relationship with us in both paper and electronic form or for as long as necessary until the limitation period for any relevant claims has expired (Article 6(b) of the GDPR).

4. The security of your data & our commitments

LOTOS Properties, in compliance with the relevant provisions of the new Regulation on the protection of individuals with regard to the processing of personal data, is committed to protecting your personal data as we consider the security of the personal data of our clients and/or prospective clients to be an important and integral part of the management of corporate information. For this reason, it takes all necessary measures to ensure that personal data is secured and protected against dissemination, loss, misuse, unauthorized access, modification or disclosure. In addition, we have adequate security systems and take all necessary and appropriate organizational and technical measures to prevent any breach of personal data security (leakage, disclosure, access by unauthorized persons) from our systems.

We undertake to keep your data up to date and accurate, to store and delete it securely, not to collect and keep data that is not necessary for us, to protect your data from any loss, misuse, unauthorized access or disclosure and, in general, to ensure that appropriate technical and organizational measures are in place to protect it.

4. Your rights to your data

In accordance with applicable law, you have the right to request at any time from LOTOS Properties to have inaccurate personal data corrected or incomplete personal data completed, to have your personal data erased if the processing is not necessary for the purposes for which it was collected, to restrict the processing if the accuracy of the data is contested, or to object to the processing, and to obtain human intervention in automated systems. In addition, you have the right of access in order to be informed, upon request, whether or not your personal data are being processed and, in addition, to receive a copy and further information on the processing being carried out, and the right to portability of your data, in other words, to receive your data in a structured and commonly used machine-readable format, as well as the right to transmit such data to another controller. You also have the right to restrict processing and under the Regulation you have the right to lodge a complaint with the Data Protection Authority.

To exercise the above rights and for any query, complaint, concerning your personal data, you can contact us by sending an e-mail to info@lotosproperties.com

If you exercise this right, we will take all possible measures to comply with your request within 30 calendar days of receiving it, after informing you either that it has been complied with or of the objective reasons that prevent it from being complied with.

5. Where to send your data

Visitor comments may be checked through an automated spam system.

LOTOS Properties reserves the right to disclose the data subject’s personal data to third parties to the extent reasonably necessary for the purposes set out in this notice and in particular:

• The data subject’s data will be transferred to the company NAPAN, which is responsible for the smooth and uninterrupted operation of the services and functions of the Website.

• The data subject’s data may be transmitted and made accessible by legal entities with which we enter into contractual agreements from time to time for the purpose of fulfilling our company’s legitimate interest in providing our services under the terms of the contract.

In the course of all data transfers, we always take all appropriate measures to ensure that the data transferred is necessary for the intended purpose of the processing and that the conditions for lawful and valid processing are always met. LOTOS Properties’ partners to whom personal data may be transferred have signed the necessary data processing agreements or have provided specific safeguards regarding personal data transfers by applying standard contractual clauses in their agreements while being subject to confidentiality.

In the event that visitors/users of our website are directed to websites which are under the supervision and responsibility of third parties (natural or legal persons), LOTOS Properties shall not be liable for the terms of protection and management of personal data which the third parties follow.

LOTOS Properties is not permitted to sell or otherwise transfer or disclose personal data of visitors/users of its website to third parties, other than the aforementioned, without the consent of the visitor/user, unless LOTOS Properties is obliged to do so by the competent authorities in accordance with the rules of mandatory law.

6. Amendments to the policy on the protection of personal data

LOTOS Properties reserves the right to amend or update the content of this Privacy Policy to include any changes to the legal and regulatory framework regarding the protection of personal data. We will inform you of any, within the scope of applicable law, amendments to this Policy by posting them on its website. Such amendments will be binding from the date of their publication. For this reason, we invite you to visit this section of its website on a regular basis in order to be informed of any updated versions of the Privacy Policy.