doValue Greece Real Estate Services Single Member Société Anonyme
Data Controller: doValue Greece Real Estate Services Single Member Société Anonyme, registered at the Hellenic General Commercial Registry (GEMI) with no. 156425101000, Tel. 2116245000 (hereinafter referred as “doValue RE Services”)
Registered Office: 27 Kyprou and Archimidous street, 18346, Moschato, Greece
Data Protection Officer e-mail address: firstname.lastname@example.org
Hereinafter the following terms, unless otherwise defined herein, shall have the following meaning:
i. “Us”, “Our” and “We” refers to doValue RE Services;
ii. “Website” means the website www.altamiraproperties.gr; and
iii. “You” and “User” refers to you as user and/or visitor of this Website.
2. Informative notice regarding the processing of personal data of doValue RE Services’ Website users
doValue RE Services, based at 27 Kyprou and Archimidous street, 18346, Moschato, Greece, is fully committed, as Data Controller, to respecting and protecting the privacy of your personal data, when you visit and browse the website www.altamiraproperties.gr. This Website is operated by doValue RE Services. This Privacy Notice relates to the services provided through the Website and through the application built in the Website (hereinafter referred as the “Platform”), through which you can register to benefit from our services, by providing us with your personal details.
Through this Privacy Notice, doValue RE Services aims to provide information on the processing of your personal data when you visit the Website, consult, or use the services of the Platform. The current information is provided by doValue RE Services, who acts as the Data Controller, with regards to your usage of the Platform but not for other websites, where you may be led via links contained on the Website (in relation to which, you need to read the respective privacy information/policies). doValue RE Services informs you that the personal data provided by you or in any case collected automatically from you when you request information and/or contact, register on the Platform and use the services, will be processed in compliance with the applicable Data Protection Legislation, more particularly in compliance with the General Data Protection Regulation (EU) 2016/679 on the Protection of Personal Data (“GDPR”), Greek Law 4624/2019 and other applicable provisions of Greek and European legislation on the processing of personal data (hereinafter referred as “Data Protection Legislation”).
3. Data collected through your browsing the Website
During their normal operation in supporting the Platform, the IT systems and software procedures used to operate the Platform may acquire some personal data, whose transmission, based upon the TCP/IP protocol, is implicit in the use of the Internet.
The aforementioned data is not collected in order to be associated with identified data subjects but –by its nature - it could be associated with data held by third parties, which would allow your identification.
This category of data includes the "IP addresses" or domain names of the computers that you use to browse the Website/ use the Platform, includes the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to your operating system and the IT environment.
4. Data provided by you
As a User you may be required to provide your personal data through the online forms available for the registration to the Platform, in order to receive, the requested services. With regard to the free text fields in particular, we urge you to avoid writing and revealing personal data that fall within the special data categories, such as data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning your physical or mental health, biometric or genetic data, data relating to your sex life or sexual orientation, etc. You shall be held solely liable for any damage caused to doValue RE Services or any third party as a result of the wrong, inaccurate or insufficient data/information provided via the Website forms.
The use of some features of the Platform, the e-mail communications, the processing of other sections of the Platform, may involve the processing of additional personal data of the User in order to follow up on the request for information, and/or to send documentation, brochures or informative leaflets which provide a comprehensive idea of the products and services offered by doValue Re Services.
Cookies stored on your device cannot be used to retrieve any data from your hard disk, to transmit computer viruses or to identify and use your e-mail address. Each cookie is unique in relation to the browser and device you use to access the doValue RE Services Website. For more information on what cookies are and how they work, you can consult the website "All about cookies" (http://www.allaboutcookies.org).
For detailed information on which Cookies we use in this Website and how you can disable them visit the " Cookies Policy" of doValue RE Services.
6. Purpose and preconditions of lawfulness for data processing
User’s personal data will be processed in order to receive the requested service, the access, the browsing and the provision of the Platform contents. Additional processing, other than that just indicated, may also be based upon the execution of contractual relationships of which you are part, or to fulfil pre-contractual requirements. In addition, if necessary in accordance with the Data Protection Legislation, your data will be processed based upon your free and express consent, for one or more given purposes.
Subject to the legal bases identified, your data will be processed within the limits of what is strictly necessary to pursue the following purposes:
A. Access and registration
With the aim of providing certain services, such as saving preferred searches, or receiving regular updates through automatic email alerts, the User can create an account by registering at "My Altamira Properties", through which the User will be able to have access to the saved content, manage the notifications that the User prefers to receive, send requests for additional information, modify the information inserted during the registration, as well as cancel the registration and delete the account.
In order to complete the registration process, the User is requested to insert the following data in My Altamira Properties:
ü Email address
ü Telephone number
ü Postal code
By accessing their personal section (hereinafter "Profile"), the User has the option to provide additional personal data (e.g. gender, address etc.) which will be collected by Us.
The User may also register by signing in through their Facebook or Google accounts.
The User has the option to delete his/ her Profile created at My Altamira Properties website, by sending a relevant email at the address email@example.com.
In order to provide you with the information requested, relating with a specific property, a “Contact” form is available which will allow you to forward your personal data to doValue RE Services and to the external real estate agent - appointed by doValue RE Services - who will contact you and provide you with the information you requested on the property, as well as arrange an appointment to visit the property. Investors may receive commercial and promotional information, according to their interests, by visiting the relevant page and entering their contact details and their preferences.
C. Commercial activity
In order to provide you with regular updates on additional services and properties, you can opt-in, by providing your explicit consent for such a service when creating an account at “My Altamira Properties” website.
Your free, prior and informed consent will give doValue RE Services the possibility to process your personal data for promotional activity. This consent is provided on a voluntary basis and does not imply additional consequences, except from the inability for doValue RE Services to provide you with regular updates about the properties portfolio and the available services.
In order to stop receiving any commercial and promotional information you may send an email requesting it at the email address firstname.lastname@example.org.
You can also unregister as a recipient of our commercial and promotional information or ask the deletion of your personal data from the Contact form, through by sending an email to the address email@example.com.
Investors may receive regular updates on additional services and properties, according to their interests, by opting-in and providing their free and explicit consent on the relevant page.
Processing of anonymous statistics on the use of the Platform and verifying that it operates properly and without problems.
E. Legal obligations
Fulfilling obligations under EU and national regulations, supervisory framework, as well as decisions of any authorities (public, supervisory, prosecutorial etc.) or courts.
F. Legitimate interests
This processing is subject to the condition that the legitimate interests of doValue RE Services do not override the fundamental rights and freedoms of the Users of the Website, which require protection of personal data, and is being carried out, inter alia, for the following purposes:
· The proper and more efficient operation and management of the Website.
· The investigation and resolution of technical issues connected to the provision of the services (e.g. code errors).
· The performance of studies allowing us to evaluate and improve our products and services.
· Contacting you in order to provide you with information on the utilization of our services, their capabilities, their characteristics, as well as any new developments.
Providing such personal data, is essential for doValue RE Services in order to execute correctly its services, not only the ones already detailed, but also those to be potentially incorporated; the potential refusal of this provision will imply the impossibility for the user to be registered at the Platform and hence, to enjoy the related services..
7. Processing methods, storage times and security measures
In order to carry out the aforementioned activities, doValue RE Services staff, which is in charge of the services and web services, will process User’s personal data, by way of computerized procedures and electronic communication systems, protected by suitable technical and organizational measures, as well as methods coherent with the pursued purposes and for the storage times strictly necessary to fulfil the purposes for which such data have been originally collected and further processed, otherwise for the time dictated by the relevant legal and/ or regulatory framework, or for the necessary period of time for the exercise of claims or the defense of legal rights and legitimate interests, i.e. for as long as i) you remain registered with My Altamira Properties and/ or you use the services of the Website and ii) your personal data is necessary in connection with the purposes set out in the Privacy Notice.
Please note that doValue RE Services will retain your personal data until the completion of the general limitation period and for an additional two months following the end of the applicable limitation period, in order to be able to identify you in case you bring a claim against doValue RE Services, at the end of the above limitation period. In any case, in the event of a legal dispute with doValue RE Services above retention period will be extended until the issuance of an irrevocable court decision.
In particular, in the website sections focusing on the particular services, if your personal data is requested, the data will be encrypted by way of security technology known as Secure Sockets Layer, abbreviated to SSL. SSL technology codifies the information before it is exchanged via the Internet between your computer and doValue RE Services' central systems, making it incomprehensible to unauthorized parties and thereby guaranteeing the confidentiality of the information sent.
Although concerted efforts are made to safeguard personal data, doValue RE Services cannot guarantee the security of data transmitted to its Website simply because sending information via the internet is not completely safe. It is the responsibility of the User to ensure that the equipment (e.g. personal computer), software, telecommunications equipment used is sufficiently secure and protected from malware (such as viruses). Be aware that without adequate security measures (such as securely configuring your browser, malware updates, misuse of software and equipment from questionable sources, etc.) there is a risk that the data will be reported to non-authorized third parties.
8. Indicative recipients of data
To pursue the purposes indicated above, your personal data will not be transferred outside the European Economic Area.
In order to provide you with our services for the purposes described above, your personal data will be processed by the authorized employees of doValue RE Services. Your personal data may be transferred to other companies that belong to doValue Group as well as external providers for specific purposes. Such purposes may include: brokerage services, IT services and/or support for electronic systems and networks, detection of security incidents, protection against fraudulent, or illegal activity, software hosting, cloud computing, customer service, processing of requests, provision of advertising or marketing services, provision of analytical services, undertaking internal research for development purposes. Therefore the recipients of your personal data may include IT developers, ad networks, security and fraud prevention consultants, hosting and communications providers, analytics providers, email sending providers, customer service providers.
In addition, the personal data may be also disclosed to the supervisory, judicial, prosecution, public and legal authorities, in compliance with the corresponding legal obligations or the demand for accountability in case of computing offences to the detriment of this Website, as well as third parties involved on the provision of telematic and computing services (for example, hosting or web development) responsible of supporting doValue RE Services on the technical and functional management of the site.
The entities belonging to the categories cited above may act as autonomous data controllers or when necessary, as data processors duly appointed by doValue RE Services.
9. Rights of the data subjects
At any time, you may exercise the rights recognized by the Data Protection Legislation, indicatively:
a) requesting confirmation of whether or not processing of personal data is taking place;
b) accessing your personal data and requesting information on the purposes pursued by us, the categories of data processed, the categories of the personal data recipients, the applicable storage period, the existence of automated decision-making processes;
c) requiring the rectification of your personal data that may be inaccurate and the respective notification to those to whom the data may have been sent by doValue RE Services;
d) requiring the erasure of your data and the respective notification to those to whom the data may have been sent by doValue RE Services, under certain circumstances, such as in case these data are no longer necessary or when you have withdrawn your consent, or in case the data have been unlawfully processed etc.;
e) requesting the restriction of processing, in certain circumstances;
f) objecting to the processing of your personal data, where possible;
g) requesting the portability of personal data - provided by you to doValue RE Services - in the established cases and in a structured, commonly-used and machine-readable format, also to send those data to another controller, with no impediment by doValue RE Services itself;
h) withdrawing your consent at any time, which shall not affect the lawfulness of processing based on the consent provided before its withdrawal. Re-granting of withdrawn consent is permitted. For processing based upon your consent, the consent may be withdrawn by the user at any time;
i) lodging a complaint before the Hellenic Data Protection Authority for any matter regarding the processing of your personal data. For the respective competence of the Authority and the procedure to be followed for filing a complaint, you may visit the Hellenic Data Protection Authority website (www.dpa.gr – Citizen Rights – Complaint to the Hellenic DPA), where detailed information is available.
Please note the following with regard to your abovementioned rights:
i) doValue RE Services has in any case the right to reject your request for restriction of processing or erasure of your personal data, if the processing or storage thereof is necessary for the establishment, exercise or defense of the rights of doValue RE Services or for the fulfillment of its obligations.
iii) The right to data portability does not include the erasure of the personal data from the records of doValue RE Services. The erasure is subject to the conditions of point (d) above.
In order to exercise your rights, please contact the Customer Service and Complaints Management Unit of doValue RE Services, at 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece or via email at firstname.lastname@example.org. doValue RE Services shall use its best endeavors to address your request within thirty (30) days from its submission. The abovementioned period may be extended by two (2) further months, if deemed necessary at reasonable discretion of doValue RE Services, taking into account the complexity and number of requests. doValue RE Services shall inform you in case of such extension within one month from the receipt of the request.
The abovementioned service is provided by doValue RE Services free of charge. However, where requests are manifestly unfounded, excessive or repetitive, doValue Greece may, after informing the User, either charge a reasonable fee or refuse to act on the request/requests.
10. Children’s Personal data
doValue RE Services fully understands the importance of the protection of children’s personal data. This Website is neither addressed nor is intentionally designed to be addressed to children. doValue RE Services has no intention of knowingly collecting or keeping children’s personal data who may have access to its Website.
However, if doValue RE Services finds that children’s personal data have been collected without the relevant legal conditions having been met, this data will be immediately deleted.
Data Controller: doValue Greece Real Estate Services S.A., 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece
E-mail address: email@example.com
Data Protection Officer:
doValue Real Estate Services Single Member S.A., 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece
This document will be subject to updates (the various versions of the same will in any case be available). You are therefore invited to visit this section of our website periodically to view any changes or additions.The updated version of which will always be posted on the Website.
"dovalue Greece Real Estate Services Single Member Société Anonyme”, headquartered in 19-21 Kyprou & Archimidous street, 18346, Moschato, Greece, with GEMI no. 121602601000 and distinctive title " dovalue Greece Real Estate Services S.M.S.A. " (hereinafter "doValue RES") informs you pursuant to the General Data Protection Regulation (EU) 2016/679 (hereinafter "GDPR"), Greek law 4624/2019 for the implementation thereof and the relevant Greek and European legislation on the protection of personal data, under its capacity as a controller with regard to the collection and further processing of your personal data as well as your rights as data subject.
1. Who does this Notice refer to
This Notice is addressed to suppliers, real estate management or investment companies, real estate agents, service providers and contractors of doValue RES, as well as third parties related to the aforesaid persons and/or entities, indicatively the personnel, partners, representatives, managers, executives, sub-contractors, assignees, vicarious agents etc., provided that their personal data are subject to processing for the purposes set out herein. It is noted that, in case a supplier and/or real estate management or investment company and/or real estate agent and/or service provider and/or contractor is a legal person or entity, the current Notice is addressed to its representatives, agents, employees, partners and management bodies, whose personal data are subject to processing on behalf of doValue RES in the context and for the purposes of the relevant agreement with doValue RES. This Notice may be supplemented by more specific notices and policies of doValue RES.
2. Data Controller
The data controller of your personal data is doValue RES, a company for the exploitation and management of real estate.
3. What personal data doValue RES processes and which sources it collects such data from
A. Categories of personal data processed by doValue RES
In view of the above, the personal data that doValue RES collects and processes may indicatively be the following and not all of them necessarily concern you:
a) Identification data: name and surname, father’s name, mother’s name, identity card and identity card number (ID) or passport and passport number, tax identification number, competent tax authority, social security number, date and place of birth, citizenship, sex, photo, electronic identification data such as username, signature data, etc.
b) Communication data: postal address/residence details, e-mail address, telephone number (home and mobile), etc.
c) Occupation and professional skills: such as, indicatively, information included in submitted CVs and/or offers you submit, in documents and supporting documents, such as professional certifications, recommendations and/or contact information for the receipt of recommendations or their confirmation by third parties, as well as professional experience or activity data, data provided in your professional card, etc.
d) Financial and invoicing data, including your bank account details.
e) Financial and insurance data: indicatively, in cases where there is a legal representative of a general partnership or an individual business, income tax declarations and tax statements, insurance and tax clearance, non-bankruptcy and non-insolvency certificate, non-filing of insolvency petition on certificate, non-filing of application for suspension of payments certificate, debt data, etc., as provided by the current legal and regulatory framework and the policies of doValue RES.
f) Data arising throughout the duration of your relationship with doValue RES: indicatively communications/correspondence with doValue RES or third parties in the context of your duties/activities, data concerning benefits/expenses, data concerning access to premises, systems, archives and any other related electronic equipment of doValue RES etc.
B. Sources from which doValue RES collects your personal data
doValue RES collects your above personal data from the following sources:
a) Directly from you or from third parties acting on your behalf (e.g. agents, authorized representatives etc.) or related to you. doValue RES is not responsible for any illegal processing of your personal data by the above third parties.
b) From our employees, as well as from third-party service providers, suppliers and partners/affiliates of doValue RES.
c) From publicly accessible sources.
It is noted that the above data can also be collected or verified from companies of the Group to which doValue RES belongs or from third parties which provide or verify recommendations about you.
According to the GDPR, personal data should be updated and accurate. Consequently, you are obliged to inform doValue RES about any change of the aforementioned personal data which have been transmitted to doValue RES by you.
Furthermore, if you provide us with personal data of third parties, you are obliged to fully inform them in advance, including by reference to this Notice, and obtain their relevant consent, where required.
4 Why doValue RES collects your personal data and for which purposes it processes them
doValue RES processes your personal data in the context and for the purposes of the execution of your agreement. In particular, doValue RES processes your data for the purposes mentioned below:
Α. For the execution of the agreement and the measures taken following your request prior to the conclusion of the agreement
The aforementioned processing of your personal data serves purposes, such as:
i) Your identification, the verification of your details and communication with you, including during both the pre-contractual and contractual stage.
ii) The management of the agreement with doValue RES, as well as the execution, management and in general the smooth operation of the agreement with doValue RES and the fulfillment of the mutual obligations thereunder.
Β. For the compliance of doValue RES with its legal obligations
doValue RES processes your personal data to the extent necessary, in order to comply with the obligations imposed by the relevant legal, regulatory and supervisory framework, as well as the decisions of authorities (public, supervisory, independent, prosecutorial, etc.) or courts (regular or arbitral) and for the protection of persons and goods.
C. For legitimate interest purposes pursued by doValue RES or third parties (indicatively, companies of the Group, affiliates etc.)
The processing of your personal data also serves purposes such as, indicatively, the establishment, exercise and defense of legal claims, the compliance with the policies of doValue RES, the compliance with terms of contracts of doValue RES with third parties, the security of IT systems and, in general, assets of doValue RES and/or a third party, the preservation of reputation, record keeping, the prevention and deterrence of criminal acts or fraud against doValue RES or a third party, etc.
5. Who are the recipients of your data
In the context of processing your personal data, doValue RES may transmit those data to the following recipients:
a) to the authorised employees, members of management/committees of doValue RES in the context of their duties and to companies of the Group to which doValue RES belongs.
b) to lawyers, law firms, court bailiffs, notaries, experts, accountants/auditors and providers of counselling services etc.
c) Companies for storage, archiving, management and destruction of files and data, providers of IT and maintenance services, providers of teleconference services, providers of electronic communications services, cloud computing, information society and postal services.
d) To supervisory, independent, judicial, prosecutorial, police, tax, public and/or other authorities or bodies, accredited intermediaries and centers of mediation services, arbitration courts and alternative dispute resolution bodies.
6. Transfer of your personal data outside the European Economic Area
doValue RES does not transfer your personal data directly to third countries or international organizations, unless such transfer is required by the applicable regulatory or legal framework.
If applicable, doValue RES may transfer your personal data to third countries under the following circumstances:
i) Where the European Commission has decided that the third country, a territory or one or more specified sectors within that third country or international organisation ensure an adequate level of protection, or
ii) If appropriate safeguards have been provided from the recipient, in accordance with the national and European legislation.
In the absence of the abovementioned circumstances a transfer may take place if:
i) You have provided your express consent to doValue RES; or
ii) the transfer is necessary for the performance of a contract between you and doValue RES, such as for the execution of your orders, or
iii) the transfer is necessary for the establishment or exercise or defense of legal claims and rights of doValue RES, or
iv) there is a relevant obligation arising from a legal provision or an international convention to which doValue RES is subject. In order to fulfill such obligation, doValue RES may transfer your personal data to competent national authorities so that such data are delivered through them to the respective authorities of third countries.
7. How long doValue RES stores your personal data
Your personal data shall be kept throughout your contractual relationship and your cooperation with doValue RES and for the time period which is deemed necessary under the relevant legal and/or regulatory framework and in any case, your personal data shall be kept until the fulfillment of the general limitation period set by the law, i.e. until the lapse of twenty (20) years from the -by any means- termination of your cooperation with doValue RES.
If there is ongoing litigation with doValue RES, the maintenance period of the personal data shall be extended until the issuance of an irrevocable court decision.
Also, very few necessary personal data of yours (indicatively, identification data, data included in the minutes of the management bodies of doValue RES etc.) may form part of the historical archive of doValue RES and therefore shall be kept throughout the time period of maintenance of such archive.
8. Your rights towards doValue RES with regard to the protection of your personal data
In accordance with the provisions of GDPR, you have the following rights:
i) Right of access to your personal data that are retained and processed by us, as well as to information concerning the processing thereof (origin of the data, purposes of processing, categories of recipients, storage period).
ii) Right to rectification of your personal data, in the event of inaccurate data or for the purposes of completing incomplete personal data by providing any necessary document justifying the need for rectification or supplementation.
iii) Right to object on grounds relating to your particular situation unless the processing is necessary for the purposes of the legitimate grounds of doValue RES or a third party.
iv) Right to restriction of processing of your personal data where the accuracy of the personal data is contested by you or the processing is unlawful or doValue RES no longer needs your personal data for the purposes of processing, or you have objected to the processing and the verification whether the legitimate grounds of doValue RES override yours, is pending.
v) Right to erasure of your personal data from doValue RES’ records.
Please note indicatively the following in relation with your above rights:
§ doValue RES has in any case the right to refuse the satisfaction of your request for the limitation of the processing or the erasure of your personal data if their processing or their maintenance is necessary for the exercise of your rights or the fulfillment of the obligations of doValue RES towards you as well as the establishment, exercise or defence of legal claims of doValue RES or the compliance of doValue RES with its legal obligations.
§ doValue RES also has in any case the right to refuse the erasure of your personal data, provided that some of them are not erased for filing purposes.
§ The exercise of the above rights acts for the future and does not concern already executed processing of data.
9. How you may exercise your rights towards doValue RES
For the exercise of the rights of the above section, you may address your relevant requests in writing, to 19-21 Kyprou & Archimidous street, 18346, Moschato, Greece or by e-mail at firstname.lastname@example.org .
doValue RES shall use its best endeavors to address your request within thirty (30) days from its submission. The abovementioned period may be extended by two (2) further months, if deemed necessary at reasonable discretion of doValue RES, taking into account the complexity and number of requests. doValue RES shall inform you in case of such extension within one month from the receipt of the request.
The abovementioned service is provided by doValue RES free of charge. However, where requests are manifestly unfounded, excessive or repetitive, doValue RES may, after informing the debtor, either charge a reasonable fee or refuse to act on the request/requests.
10. Data Protection Officer of doValue RES
You may contact the Data Protection Officer for any matter regarding the processing of your personal data, in writing at the address 19-21 Kyprou and Archimidous Street, 183 46 Moshato, Greece or by sending an email at email@example.com.
11. Right to appeal before the Hellenic Data Protection Authority
You have the right to lodge a complaint before the Hellenic Data Protection Authority for any matter regarding the processing of your personal data. For the respective competence of the Authority and the procedure to be followed for filing a complaint, you may visit the Hellenic Data Protection Authority website (www.dpa.gr – Citizen Rights – Complaint to the Hellenic DPA), where detailed information is available.
12. Security of your personal data
doValue RES implements appropriate technical and organisational measures to ensure the lawful protection and processing, as well as the effective protection of your personal data from unauthorised access to, disclosure of, processing, loss, alteration, accidental or unlawful destruction or corruption, prohibited transmission by third parties as well as any other form of unlawful processing.
13. Updating and modifying this Information on the processing of personal data
doValue RES may in accordance with its applicable policy on the protection of personal data and pursuant to the applicable legal and regulatory framework, modify or amend this Notice, the updated version of which will always be posted on the website at www.altamiraproperties.gr.
Last update of notice: April 27th, 2021