PRIVACY NOTICE REGARDING SUBJECT COMPLAINTS

PANAGIOTIS G. NIKAS SOCIETE ANONYME INDUSTRIAL AND COMMERCIAL COMPANY (P.G. NIKAS S.A.)

1. INTRODUCTION
1.1 As part of our complaint management process, our Company “PANAGIOTIS G. NIKAS SOCIETE ANONYME INDUSTRIAL AND COMMERCIAL COMPANY” with the distinctive title “PG NIKAS SA”, with registered offices at Agios Stefanos, Attica, 22nd km of Athens-Lamia national road, 14565, will collect and process your personal information in electronic and/or paper form. 
1.2 This Notice aims at providing you with information about how the Company manages your personal data and about the rights you have as data subjects. 
 
2. LEGAL BASIS FOR PROCESSING 
2.1 The legal basis on which the processing of the personal data of the subjects is based, is the consent of the subjects and the satisfaction of the Company’s legal interests within the meaning of an effective and substantial investigation of the complaints.
 
3. DATA PROCESSOR
3.1 In this Notice, “Panagiotis G. Nikas Societe Anonyme Industrial and Commercial Company” with the distinctive title “P.G. NIKAS S.A” is referred to as “the Company”, and/or “us”, or “we”. The Company is the Data Processor within the meaning of the law and the purposes and the way your personal data is collected, used and/or communicated to third parties by the Company are specified in this Notice. 
 
4. TYPE OF PERSONAL DATA AND MODE OF PROCESSING
4.1 To record and investigate your complaint, we will collect the following information:
(i) Full name,
(ii) Home address, City, Postal/Zip Code,
(iii) Home phone number
(iv) Mobile phone,
(v) Email address
(vi) any other information you may disclose to the Company on your own initiative when contacting us. 
4.2 Any data that you may have provided to the Company about other persons (e.g. relatives, associates, dependants, etc.) will be processed by us in accordance with the terms of this Notice. You are responsible for the accuracy of these data and information, and you are also required to ensure that the above subjects are aware of the personal data you have provided and the way these be processed by the Company. 
 
5. HOW WE USE YOUR PERSONAL DATA
5.1 The Company will use your personal data to investigate and manage your complaints about the Company’s products.  
5.2 Only such personal data which are relevant and related to a specific processing purpose will be processed, and we will always strive to limit the use of your personal data to what is strictly necessary. 
5.3 Your personal data may be used for additional purposes related to the investigation and handling of your complaints, for example:
(i) To contact you.
(ii) For statistical and historical purposes. 
(iii) Within any judicial and/or extrajudicial actions which are directly related to your complaint, in order to safeguard the Company’s legitimate interests.
 
6. WHO WE SHARE YOUR PERSONAL DATA WITH
6.1 Your personal data will only be accessed by the Company’s authorized employees, who are responsible for handling the Company’s consumer complaints. 
6.2 In addition, as part of such processing and to carry out the purposes set out above, the Company may use the services of third parties to whom the Company shall disclose your personal data, such third parties being the suppliers who provide us with services, such as IT services and other information technology services, as well as any natural or legal person with whom we cooperate or may cooperate in the future directly or indirectly for these purposes. We do not allow them to use the above information or to disclose it for any purpose other than for providing services on our behalf.
6.3 We may decide, for strategic or other business purposes, to sell or transfer our business in whole or in part. As part of such sale or transfer, we may transmit information we have collected and stored, including your personal data collected under this Agreement, to any party involved in the sale or transfer. 
6.4 Your personal data will be disclosed only to the third parties who are legally required to access them and have a contractual obligation to ensure their protection. We will ensure that your personal data is adequately and properly protected when disclosed to authorized third parties. 
6.5 Exceptionally, we may disclose your personal information to third parties, including the competent police and prosecuting authorities, only if there is a statutory obligation to do so, or we are obliged by judicial, regulatory or other competent public authority decision/order to do so.
 
7. WHERE IS YOUR PERSONAL DATA TRANSFERRED?
7.1 Your personal data is stored on secure servers located in the European Union (EU).
7.2 As part of the processing described in this Notice, we may assign the processing of or disclose your personal data to third parties established in non-EU countries. As a result, your personal information may be processed by staff outside the EU who work for us or for one of our suppliers. Said staff may work, inter alia, in providing support services. Regardless of the country your personal data is disclosed, we will disclose your personal data only on a need-to-know basis and always in accordance with the appropriate security guarantees (such as the Standard Contractual Clauses). 
7.3 You have the right to request a copy of the above by contacting us at the email address gdpr@nikas.gr.
 
8. RETENTION PERIOD
8.1 We will keep your personal data for as long as is strictly necessary for the purpose of collecting it, and in accordance with the relevant legislation. We will hold the personal data that we collect from you in accordance with this Notice until your complaint is investigated and resolved, including during any extra-judicial or judicial action, in order to safeguard the legitimate interests of the Company. 
8.2 Where your personal data is not required for the above purposes, it will be safely destroyed by our systems. 
 
9. YOUR RIGHTS
9.1 Without prejudice to the applicable legislation, you have the right to access, namely to request that you be informed on whether your personal data are being processed, and to receive further information thereon. In addition, you have the right to request the correction of any inaccurate personal data. Also, if legal requirements are met, you have the right to request deletion, the right to restrict the processing, the right to data portability and the right to object to the processing of your data.
9.2 Insofar as the data processing is based on your consent, you may withdraw your consent at any time without prejudice to the lawfulness of processing based on your consent before its withdrawal. 
9.3 Finally, you may file a complaint with the competent Data Protection Authority. 
9.4 You may exercise these rights by contacting us at the email address gdpr@nikas.gr
9.5 If as a result of such request there is a breach of obligations arising from the Company’s laws, regulations or codes of practice, or if the disclosure of such information would result in the disclosure of another person’s personal data, we may not be able to satisfy your request. In any case, however, you will be able to request the restriction of using of your data for further processing. 
 
10. DATA SECURITY
10.1 We are committed to ensuring that we will implement a range of security technologies and procedures to protect the integrity and security of all our information, including any personal data we hold. 
 
11. CONTACT US
11.1 If you have any questions regarding this Notice or if you wish to exercise any of the rights you have as a data subject, you may do so via the email address gdpr@nikas.gr.
 
12. NOTICE UPDATES
12.1 Should we modify this Privacy Notice, we will publish the revised notice on this page, and update the revision date.