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 ir.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, business information, bank account number, work address, VAT number and Competent Tax Authority, information regarding previous transactions or commercial contracts / agreements, etc.

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.

2. 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 requires your consent so as to maintain and process your data.

3. 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.
 Για την υποστήριξη/ εξυπηρέτησή σας όσον αφορά τις υπηρεσίες/ προϊόντα της εταιρίας μας. Η AS COMPANY S.A. συλλέγει και επεξεργάζεται δικές σας πληροφορίες, τις οποίες συλλέγει είτε μέσω της ιστοσελίδας είτε τηλεφωνικώς, για την απάντηση σε αιτήματα και ερωτήματά σας, για την επίλυση τυχόν προβλημάτων, για την ενημέρωση και απάντηση σε προτάσεις σας και σχόλια σας περί βελτίωσης των υπηρεσιών μας ή προκειμένου να σας εξυπηρετήσουμε ταχέως και με το βέλτιστο τρόπο στην επόμενη συναλλαγή/ επαφή σας με την εταιρία μας. Επίσης, η AS COMPANY S.A. μπορεί να σας προσκαλέσει να συμμετάσχετε σε ερωτηματολόγια και έρευνες. Αυτά τα ερωτηματολόγια και οι έρευνες θα σχεδιαστούν γενικά με τρόπο που οι απαντήσεις δεν θα απαιτούν Προσωπικά Δεδομένα. Αν παρόλα αυτά εισάγετε Προσωπικά Δεδομένα σε ένα ερωτηματολόγιο ή σε μία έρευνα, η AS COMPANY S.A. μπορεί να χρησιμοποιήσει τα εν λόγω Προσωπικά Δεδομένα για να βελτιώσει τα προϊόντα και τις υπηρεσίες της.
 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.

4. 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.

5. 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.

6. 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.

7. 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. You may contact us, without charge, via email at privacy@ascompany.gr stating the reasons to your request and the right you wish to exercise.
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).
Right to make a complaint. If you feel that your personal data has not been processed by AS COMPANY S.A. in accordance with the present notice or in a manner that does not meet the applicable EU data protection regulation, you have a specific right to lodge a complaint at any time with the relevant supervisory authority of the EU country you reside in, or the Hellenic Data Protection Authority.
In addition, refusal of the company or undue delay in delivering your demands in exercising your rights, gives you the right to file a complaint to the Data Protection Authority:
Kifisia 1-3, P.C. 115 23, Athens, Tel: +30-210 6475600, Fax: +30-210 6475628, Email: contact@dpa.gr.

7. 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 processors who use the personal data to provide and improve our services and support our business (e.g. insurance companies, software companies),
(d) to subsidiaries of AS Company SA in Greece and abroad (Romania – Cyprus).

9. Changes to this privacy notice
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.