Altamira Real Estate

PRIVACY NOTICE ON THE PROCESSING OF THE PERSONAL DATA OF THE USERS / VISITORS OF DOVALUE GREECE REAL ESTATE SERVICES SINGLE MEMBER SOCIETE 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 RES”)

Registered Office: 25th Martiou, Thessalonikis and 15 Teo street, 17 778, Tavros, Greece

Data Protection Officer: You may contact the Data Protection Officer regarding data protection issues at the postal address 25th Martiou, Thessalonikis and 15 Teo street, 17 778, Tavros, or at the e-mail address: dpo@dovaluegreeceres.gr

1. Definitions

Hereinafter the following terms, unless otherwise defined herein, shall have the following meaning:

i. “Us”, “Our” and “We” refers to doValue RES;

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. Processing of your personal data

doValue RES, based at 25th Martiou, Thessalonikis and 15 Teo street, 1778, Tavros, Greece, is fully committed, as Data Controller and administrator of this Website, to respecting and protecting the privacy of your personal data, when you visit and browse the Website www.altamiraproperties.gr. This Privacy Notice describes the processing of your personal data during the use of services offered through the application of the Website (hereinafter referred as the “Platform”), which allows you to register and benefit from our services.

Through this Privacy Notice, doValue RES 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 relevant information provided to you do not concern third party 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 kept in the respective websites) which (links) We do not control, nor we are responsible for the correctness of the information and their content, nor for the way in which the personal data of the Users are processed. doValue RES informs you that the personal data provided by you or in any case collected when you submit a request for information, contact, and/or register on the Platform and during the use of services, will be processed always in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Greek Law 4624/2019 for its implementation and the relevant applicable provisions of Greek and European legislation on the protection of personal data (hereinafter referred as “Data Protection Legislation”).

3. Data collected by doValue RES while browsing the Website

When you visit and/or browse our Website or when you submit an electronic request, complaint or application, personal data may be automatically collected. Indicatively, such data may include: your URL address, date and time of your visit to our Website, information concerning your device and browser you use to access our Website, the IP address of your computer, information about software programs installed on your computer, basic connection information with the web server and data collected through the use of cookies and other technological media, such as web beacons and social plug ins. For further information about the use of cookies, please read the relevant Cookies Policy.

4. Personal Data provided directly by you

As a User you may be interested in receiving information about real estate or services of doValue RES. In this case, you can provide your personal data through the online forms available in the Website and are available either when creating an account to the Platform through the "Sign In" option, or if you do not want to create an account on the Platform, through the "Investors" option You shall be held solely liable for any damage caused to doValue RES or any third party as a result of wrong, inaccurate or insufficient data/information provided via the Website forms.

The use of some features of the Platform, the e-mail communications, or 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 ReS.

5. Cookies

A cookie is a short string of text that is sent by a website to your browser and stored on your computer (alternatively on your smartphone/tablet or any other tool used to access the Internet); this request generally occurs every time you visit a website. doValue RES uses cookies for different purposes, in order to offer you an improved and secure digital experience, for example, allowing you to keep the connection while browsing through the pages of the Website.

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 RES 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 RES.

6. Purpose and legal basis for data processing

Your personal data will be processed in order to receive the requested service, have access, and browse the Platform contents. Additional processing, other than that just indicated, may also be based to the fulfilment of pre-contractual requirements. In addition, if necessary in accordance with the Data Protection Legislation, your data may be processed upon your prior free and explicit consent, for one or more given purposes.

Subject to the legal bases identified, your data that will be processed will be the strictly necessary to pursue the following purposes:

A. Access and registration

With the aim of providing certain services, or receiving updates for properties that you express your interest for, you can create an account by registering at "My Altamira Properties", through which you shall gain access to the saved content, manage the notifications that the User prefers to receive, send requests for additional information that may needs, modify/update 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 the Website:

ü Name

ü Surname

ü Email address

ü Telephone number

ü Postal code

For the completion of the registration in MyAltamiraProperties, the User is asked to create a personal password, through which he/she will gain access to his/hers personal account. The User has the option, if wishes so, to provide additional personal data (e.g. gender, address etc.).

The User may also register to My AltamiraProperties by signing in through their Facebook or Google accounts. In this case and after logging in through these platforms we inform you that we do not control and we are not responsible for the data that will be transferred to these platforms under your initiative. For more information on the processing of your personal data in these cases you can refer to the Privacy Policy of the company that provides the respective platform.

The User may request the deletion of his/ her account in the MyAltamira Properties platform by selecting the relevant option available. Moreover the User may request further information for properties and services through the “Investors” option available in the Website.

B. Commercial activity

If you wish to receive regular updates from Us on additional services and properties that we may manage, you can opt-in, by providing your explicit consent for such a service selecting the relevant option in “MyAltamiraProperties” website.

Your consent will give doValue RES the possibility to process your personal data in order to get in contact with you for new services and properties that you may be interested in. This consent is provided on a voluntary basis and does not imply any additional consequences, except from the fact that in case you do not consent doValue RES will not be able to provide you with regular updates about the properties portfolio and the available services.

In addition to the above possibility, you can request the receipt of Newsletter through the option “Investors” by opting-in through the relevant option and providing your free and explicit consent on the relevant page of the Website.

In any case, you have the possibility to withdraw your consent to stop receiving the Newsletter, by sending a relevant e-mail to the e-mail address info@dovaluegreeceres.gr.

C. Service Quality Assessment

We may use your personal data to perform satisfaction surveys and quality assessments in relation to the services offered by Us for the properties of your interest, based on your legitimate interest.

D. Legal obligations

Fulfilling obligations under EU and national regulations, supervisory framework, as well as decisions of any authorities (public, supervisory, prosecutorial etc.) or courts.

E. Legitimate interest

This processing is subject to the condition that the legitimate interests of doValue RES 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 protection and security of the information systems, to prevent, deter and repress any illegal act, and to investigate the possible breach of the terms of use of the Website or this Notice.

· The performance of satisfaction surveys allowing us to evaluate and improve our products and services we offer you.

· Contacting you in order to provide you with information on the utilization of our services, their capabilities, their characteristics, as well as any new services.

7. Processing methods, retention period and security measures of personal data

For the execution of the aforementioned activities, doValue RES staff, which is in charge of the services and web services, will process User’s personal data digitally using electronic communication systems, protected by suitable technical and organizational measures and controls, only for the pursued purposes and for the period strictly necessary for the fulfilment of the purposes for which such data have been initially collected. For all other cases personal data shall be retained for the time period dictated by the relevant legal and/ or regulatory framework, or for the period necessary for the exercise of claims or for the defense of legal rights and legitimate interests of doValue RES, i.e. for as long as i) you remain registered with MyAltamiraProperties and/ or you use the services of the Website and ii) your personal data is necessary for fulfillment of the purposes described in this Privacy Notice.

It is noted that doValue RES will retain your personal data until the completion of legal limitation period for claims , in order to be able to identify you when you bring a claim against doValue RES. In case, of a legal dispute with doValue RES the aforementioned 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 RES 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 each 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 data recipients

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 RES. Your personal data may be transferred to other companies of the Group where doValue RES belongs, as well as to external providers only for specific purposes. Such providers may include indicatively: brokerage service providers, IT service and/or support for electronic and network systems providers, providers for the detection of security incidents, providers for the protection against fraudulent or illegal activity, providers for software hosting, cloud computing, customer service providers, service providers conducting research for development purposes/ services improvement.

In addition, the personal data may also be 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 electronic crime offences to the detriment of this Website, as well as third parties involved in the provision of telematic and computing services (for example, hosting or web development) responsible of supporting doValue RES 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, and/or as data processors if they have undertaken to provide their services to doValue RES.

9. Rights of the data subjects

At any time, you may exercise the rights regarding the processing of your personal data, as those laid down by the Data Protection Legislation, indicatively:

a) Right to be informed of whether or not processing of personal data is taking place;

b) Right to access to 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) Right to 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) Right to erasure of your data, under certain circumstances, such as in case that the retention of your personal data is no longer necessary or when you have withdrawn your consent, or in case the data have been unlawfully processed etc.;

e) Right to restriction of processing, of your personal data if you dispute the accuracy of these data, or the processing is unlawful, or doValue RES does not need your personal data for the purposes of processing;

f) Right to object to the processing of your personal data, where the processing has been entrusted to doValue RES for the performance of a task carried out in the public interest or in the exercise of public authority or the legitimate interest pursued by doValue RES , including profiling;

g) Right to data portability of your personal data - provided by you to doValue RES - in specific cases and in a structured, commonly-used and machine-readable format, to another controller;

h) Right to withdraw your consent at any time, which shall not affect the lawfulness of processing based on the consent provided before its withdrawal;

i) Right to lodge a complaint to 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 – My Rights – Lodge a Complaint), where detailed information is available.

Please note the following with regard to your abovementioned rights:

i) doValue RES 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 RES 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 RES. 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, at 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece or via email at dovaluegreece@dovaluegreece.gr.. 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 User, either charge a reasonable fee or refuse to act on the request/requests.

10. Minor’s Personal data

doValue RES fully understands the importance of the protection of minor’s personal data. This Website is neither addressed nor is intentionally designed to be addressed to minors. doValue RES has no intention of knowingly collecting or keeping minor’s personal data who may have access to its Website.

doValue RES, based on its applicable policy on the protection of personal data and within the framework of the applicable legislative and regulatory framework, may revise or amend this Privacy Policy, which will always be updated and available on the website of www.altamira properties.gr.

Last update of the Privacy Notice September 2022

Privacy Notice on the processing of personal data relating to suppliers, real estate agents, service providers and contractors of doValue RES in accordance with Regulation (EU) 2016/679, law 4624/2019 and the relevant applicable Greek and European legislation.

"dovalue Greece Real Estate Services Single Member Société Anonyme”, headquartered in 25^th Martiou, Thessalonikis and 15 Teo street, 17778, 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 applicable Greek and European legislation on the protection of personal data, under its capacity as a controller with regard to the collection and 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 managing and promoting real estate assets.

2. 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, 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) Data regarding your occupation and professional skills: such as, indicatively, information included in submitted CVs and/or offers you submit, in documents and supporting documents, such as 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) Data of financial behavior, in special cases where doValue Greece RES recognizes a high risk of fraud depending on the nature of the contract and the object of the services provided, and as provided by the applicable legal and regulatory framework.

e) Financial and invoicing data, including your bank account details.

f) 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.

g) 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.

h) Data collected through closed-circuit television from the premises of doValue RES as well as data concerning access to premises, systems, archives and any other related electronic equipment (such as portable storage media) of doValue RES or other companies of the Group to which doValue RES belongs.

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 for the transfer and processing of their personal data by doValue RES, 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.

This processing is preceded by a weighing that your interest or fundamental rights and freedoms that require the protection of your data doValue RES or the corresponding body of claims do not prevail over the legitimate interests of doValue RES or the respective body of claims.

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, , 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 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) Τhere 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 retains 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 the processing of your personal data, where the processing has been entrusted to doValue RES for the performance of a task carried out in the public interest or in the exercise of public authority or the legitimate interest pursued by doValue RES , including profiling.

iv) Right to restrict the 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 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 reject your request for restriction of 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 defense of legal claims of doValue RES or the compliance of doValue RES with its legal obligations.

§ doValue RES has also 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 27 Kyprou & Archimidous street, 18346, Moschato, Greece or by e-mail at dovaluegreece@dovaluegreece.gr .

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 25th Martiou Thessalonikis and 15 Teo Street, 17778 Tavros, Greece or by sending an email at dpo@dovaluegreeceres.gr.

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 – Individuals – Rights of Individuals – 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 the Privacy Notice: September 2022

Privacy Notice on the processing of personal data for interested purchasers of real estate promoted through doValue RES in accordance with the European Regulation (EU) 2016/679, Greek law 4624/2019 and relevant applicable Greek and European legislation

doValue Greece Real Estate Services Single Member Société Anonyme, headquartered in 25th Martiou, Thessalonikis and Teo 15 street, 17778, Tavros, 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 referred to as "GDPR"), Greek law 4624/2019 for the implementation thereof and the relevant applicable 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 persons who show interest, submit a question or request or wish to submit a bid for the acquisition of real estate, that is promoted, exploitedand/or is generally managed by doValue RES. It should be noted that, in the case of a legal person or entity, this Νotice is addressed to its representatives, agents, employees, partners and management bodies, whose personal data is processed by doValue RES in view of the abovementioned purposes. This Notice may be supplemented by more specific notices and policies of the doValue RES.

2. Data Controller

The data controller of your personal data is doValue RES.

3. What personal data doValue RES processes and which sources it collects such data from

(A) Categories of personal data processed by doValue RES

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, social media profile data (i.e., the name and email that you have registered in the Facebook or Gmail accounts, when choosing to register or connect as a user), etc.

b. Communication data: Postal address, e-mail address, telephone number (landline or mobile), etc.

c. Technical and electronic data, such as the name and user code and your registration data on https://www.altamiraproperties.gr/ , the Internet Protocol Address (IP address), the operating system that you use, the type and version of the browser, etc.

d. Data concerning your requests when communicating with doValue RES or with the staff of the customer service department or the network of employees of the doValue RES.

(B) Sources from which the doValue RES collects your personal data

doValue RES collects these data from the following sources

a) Directly from you or by third persons acting on behalf of you (e.g., representatives, agents, etc.) or related to you, when you contact doValue RES about any real estate, while browsing the website: https://www.altamiraproperties.gr/,when you register at doValue RES communication forms. 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 by third-party service providers, suppliers and partners/affiliates of doValue RES (including brokers, lawyers, law firms, notaries).

c) From publicly accessible sources.

Also, in the event that you provide us personal data from third parties, you have to inform them sufficiently in advance for the transfer and processing of their personal data, including a reference to this Notice, and to obtain their relevant consent, where required.

4. Why doValue RES collects your data and for which purposes it processes them

In particular, doValue RES processes your data for the following purposes:

A. For the management of your registration as a user of the services of doValue RES andof the requests you submit to us

If you decide to register as a user of doValue RES services, we need to process your data to identify you as a user and to give you access to your account and to the various functions and information that is available for you because of your status as a registered user. You can cancel the user account by contacting doValue RES as described below in Section 9.

You can create an account or a connection to your account via a social network platform (e.g., Facebook, Gmail) when this option appears on our website or the applications of doValue RES. In this case your credentials for the connection (your full name and email) will be added into your account via the selected social network platform. In addition to the abovementioned information, doValue RES will not collect or keep any additional information from the profile you maintain in the selected social network. The use of this function, however, may mean that you may provide some information about your activity in that social network platform. In any case, we inform you that we do not control and we are not responsible for the data that will be transferred to these platforms by you while we recommend that you check the privacy settings as well as the privacy policies of these platforms in which you keep accounts in order to be informed about the processing of your personal data.

B. For the execution of the agreement and the measures taken following your request prior to the conclusion of the agreement

The personal data processing serves particular purposes, such as your identification, verification of your details and communication with you, including both the pre-contractual level as well as the stages of the conclusion and smooth execution of the contract.

C. 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.

D. For legitimate interest purposes pursued by doValue RES or third parties (indicatively, companies of the Group, affiliates etc.)

E. For the purposes of promoting real estate of doValue RES (marketing), provided that you have given your consent

If you have chosen to receive personalised information through promotional actions carried out by doValue RES, we will process your personal data on the basis of the consent you have given us. In such cases, you have the right to withdraw your consent at any time. Such withdrawal acts for the future and does not concern already executed processing of data.

5. Who are the recipients of your personal 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 the companies of the Group where doValue RES belongs.

b. To associate brokers and other associates of doValue RES for the purpose of promoting real estate for which you have shown interest, etc.

c. To service providers 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 service.

d. To the owner or manager of the property.

e. To lawyers, law firms and notaries for the purposes of concluding and executing the contract of the sale of the property.

f. To supervisory, independent, judicial, prosecutorial, police, tax, public and/or other authorities or bodies.

g. To third parties submitting a request for information to the doValue RES only if the legal conditions are met.

6. Transfer of your personal data outside the European Economic Area.

doValue RES does not transfer your personal data 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:

· 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

· If appropriate safeguards have been provided from the recipient, in accordance with the national and European legislation.

If none of the above conditions apply, the transmission may be completed:

· If you have provided your express consent to doValue RES,

· If the transfer is necessary for the performance of a contract between you and doValue RES, such as for the execution of your orders,

· If the transfer is necessary for the establishment or exercise or defense of legal claims and rights of doValue RES,

· If 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 retains your personal data

Your personal data shall be retained throughout the entire period in which your user account remains active and for the entire period of your cooperation with doValue RES. If you wish to erase your data from our files and / or cancel your user account, please contact the doValue RES as described below in Section 9.

Moreover, your personal data will, if necessary, be maintained for the time period which is deemed necessary under the relevant legal and/or regulatory framework.

Especially, in the case of a legal dispute with doValue RES, the retention period of the personal data shall be extended until the issuance of an irrevocable court decision.

8. Your rights towards doValue RES with regard to the protection of your personal data

According to GDPR's provisions, 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 the processing of your personal data, where the processing has been entrusted to doValue RES for the performance of a task carried out in the public interest or in the exercise of public authority or the legitimate interest pursued by doValue RES, including profiling iv. Right to restrict 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 erase your personal data from doValue RES’ records.

vi. Right to portability of your personal data to any other data collector provided that the processing is based on your consent or on a contract and is carried out by automated means.

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 right to portability (above under vi) does not lead to the deletion of data from the archives of doValue RES, which (deletion) is subject to the conditions set out in the immediately preceding paragraph.

· The exercise of the above rights acts for the future and does not concern already executed processing of data.

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9. How can you exercise your rights towards doValue RES

In order to exercise the rights of the above section, you may address your relevant requests in writing to 27 Kyprou and Archimidous street, 18346, Moschato, Attiki, Greece, or by sending an e-mail at the address dovaluegreece@dovaluegreece.gr.

doValue RES shall use its best endeavors to address your request within one month 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 can contact the doValue RES Data Protection Officer for any matter regarding the processing of your personal data in writing at the address of 25th Martiou , Thessalonikis and 15 Teo street, 17778, Tavros, Attiki, Greece, or by sending an e-mail at the address dpo@dovaluegreeceres.gr

11. Right to appeal before the Hellenic Data Protection Authority

12. Security of your personal data

13. Updating and modifying this Information Notice on the processing of personal data

Last update of the Privacy Notice: September 2022