Thank you for visiting the website www.pepperhellas.gr (hereinafter the "website") owned and run by the company «Pepper Hellas Asset Management S.A.» email: Info@pepperhellas.gr) (hereinafter: "the Company").  

Before using our website, please read this Privacy Policy carefully (hereinafter referred to as "the policy"). This privacy policy applies to all clients and users of the website as to the collection and use of personal data by the company. 

1. How we collect personal data

2. What personal data we collect

When you visit the website www.pepperhellas.gr we collect the following personal data, which (data) will vary depending on the use performed by each visitor (contact form, Newsletter and other): 

• Name
• Surname
• Email address
• Telephone(mobile, landline
• Any information you include in the text of the contact form
• Information you include in your CV
• Browsing data such as address IP, screen resolution, browser used, operating system and settings, access times and URL and data collected through (cookies).

3. Cookies

Our website uses cookies or similar technologies to ensure the best possible user experience and to analyse trends, manage the website, monitor users' browsing on the site and gather demographic information about our user base as a whole. For more information about the use of cookies, please also review our Cookie policy

4. Processing purpose

The purpose of the data collection/processing is to provide information to all users, existing and prospective clients about the company and the services offered, to effectively communicate with the users and clients, to support, promote and perform the contractual relationship with our customers and to protect the security of transactions. Specifically, we use your data: 

• To enable you to access and use our website and the services we provide through our website
• To respond to customer service requests
• To send you notices and commercial communications,
• To perform marketing and promotional campaigns
• To be able to detect and prevent cases of fraud, abuse, security incidents and other harmful activities and to perform security and risk assessments
• To enforce the terms of use of the website and other policies
• To ensure the company’s compliance with legal obligations
• To improve our services and improve the user experience, for the purposes of controlling, troubleshooting and improving the functionality and quality of our online services and generally to optimize and tailor our web platform to your needs, making our website easier and more efficient to use.

5. Legal basis for processing

The legal basis for the processing of personal data collected in accordance with the above is: 

The company also reserves the right to regularly communicate with our clients by telephone, mail, email, SMS or any other means of communication, using the contact information which has been obtained lawfully, within the context of the company’s contractual relationship with the user (article 11§ 3 of N. 3471/2006) provided that the user has not opposed this communication. This communication  may include an update on services provided,  research to improve the services provided to the Customers and other promotional activities and to serve similar purposes.  

6. Social media share button

PEPPER HELLAS has official social media accounts, specifically On Facebook, Linkedin and Twitter. On its website, the company incorporates an additional social media share button for Facebook, LinkedIn and Twitter, inviting website visitors and users to follow the company in the respective social media (follow/like) as well as upload posts and comments. During your use of the social media we may collect certain personal data (such as your profile data in the corresponding medium).

Based on European Court of Justice case-law, the Company is considered a Joint Controller for processing your data together with each social medium. Within this context, the company has posted the Privacy Policy on an easily accessible spot on each corporate social media account, it strictly complies with the obligations relating to the protection of personal data by taking the appropriate technical and organisational measures (such as limiting the number of people with access to corporate social media accounts) in order to ensure the safe processing of data (see below par.9).

The purpose of the data processing is to make visible and promote the company's image and services, to provide updates or to communicate with you, responding to the messages/comments you send us.

The legal basis for processing is your consent, which you provide when you actively click on the social media share button, the “like” or “follow” button on the Company's social media. You can withdraw your consent at any time in the same manner in which you provided it, i.e. by clicking “unlike” or “unfollow”.

The Company is not responsible for how each social medium processes your data and it is your responsibility to be informed about it by reviewing the Facebook, Linkedin and Twitter Privacy Policy.

Finally, while PEPPER HELLAS wishes and encourages users to comment on posts and/or pages it maintains on social media, it informs users that any post or comment uploaded should respect the basic rules of politeness, decency and respect to different views, ensuring a safe online environment and will remove any content deemed to violate the terms of use of the website, such as insulting, pornographic, or threatening content or content violating intellectual property rights, and may block users who violate these terms. In any case, if you consider that content posted on PEPPER HELLAS' official social media accounts violates the terms of use, please contact us immediately.

7. Personal data recipients

For the Data which are necessary for the fulfilment of the each of the above processing purposes and within the scope of the responsibilities and duties of each recipient, the recipients of the user's data may be: 

It should be noted that when storing, accessing and/or processing the user's personal data, the employees and agents of the company fully comply with the relevant provisions of the European General Data Protection Regulation 2016/679 on the protection of Data as well as with current Greek legislation and jurisprudence on the protection of personal data. The company requires of its employees, its website hosting and service providers, as well as its third party partners to take all necessary technical and organisational measures (including appropriate policies and procedures) to prevent unauthorised disclosure of users’ personal data to which they gain access, and implement procedures for the management and processing of personal data in a manner that is lawful and protect such data according to GDPR imposed obligations. 

8. Retention period

We retain your personal data for the duration of our contractual relationship. The personal data we process is not retained for a longer period than is necessary for the performance of the contract and any services directly related to it:  

We will also retain personal data:  

• To the extent required by law (for example, in order to comply with tax legislation)
• In order to comply with court proceedings (any ongoing or future court proceedings)
• To establish, exercise or defend our legal rights, personal security of the users and the public.

However, some necessary personal data regarding your contractual relationship with the company as well as information concerning your notification on the processing of your data and your consent, where applicable, may be retained so as to establish the lawfulness of processing of user data by the company and the legal claims of the parties.  

9. Technical and organisational measures

The company, its employees, processors, assistants, agents shall implement appropriate technical and organisational measures to ensure, as much as possible, the most appropriate protection of personal data against accidental or unlawful destruction, loss, alteration, unlawful disclosure or access to them and any unlawful processing, as well as to ensure the possibility of restoring availability and access to them. These measures also serve so as to demonstrate that processing is performed in accordance with GDPR, obviously taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, while  applying appropriate procedures for the regular testing, evaluation and evaluation of the effectiveness of the techniques and organisational measures.  

10. Your rights

Under the GDPR (articles 12-22) you have the following rights:  

• Request a copy of your personal data
• Withdraw your consent when this is the legal basis of the processing of your personal data
• Request that your personal data be corrected if it is inaccurate
• Request erasure of the personal data you have provided, under the conditions set out by law
• Request restriction of processing, under the conditions set out by law
• Request the portability of your personal data, if you have provided us with the data and the processing is based on consent or performance of a contract and processing is based on automated means
• Oppose some form of processing of your personal data by the company

To exercise any of the above rights, you may contact us via e-mail:  dpo@pepperhellas.gr or by mail at P.O. Box 61358. We will take all possible measures to satisfy your request within a reasonable period, no later than one (1) month after the submission of the request and proper proof of your identity. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Please note that the absolutely necessary user data may be retained, in order to safeguard the legal interests of the Company. 

Please note that depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in the Firm’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law. 

Finally, each user has the right to submit a request to the company inquiring on how the company processes and protects your personal data, and if you consider that your rights are infringed, you have the right to file a complaint with the Data Protection Authority (http://www.dpa.gr/, Kifisias 1-3, P.C. 115 23, Athens, 210 6475600).   

11. Minors

Please be aware that the content and services of this site are not intended for persons under 18 years of age. No personal data must be submitted to the company through the website by visitors under 18 years of age. If we become aware that a user under the age of 18 has registered and provided personal data without the explicit consent of the parent or legal guardian, we will immediately delete, after receiving such information or request, the relevant data in accordance with the applicable company policy. 

12. Privacy policies changes

The company may change this policy. Please check the effective date at the top  of the policy to see when it was last revised. Every revision will be implemented as soon as we publish the revised policy.  

If we make substantive changes to this policy that broaden our rights to use the personal data that we have already collected from you, we will inform you and provide you with a choice for the future use of these data.