PRIVACY AND PERSONAL DATA PROTECTION POLICY – GDPR COMPANY PRIVACY STATEMENT – GDPR COMPLIANCE

1. Introduction

For our Company , the privacy and security of our website Users and Visitors, as well as the End Users , are of utmost importance. Customers and Foreign Collaborators , you are considered the highest importance . Our Company is committed to protecting the personal data you share with us . This privacy policy covers the ways in which our Company processes information that can be used to directly or indirectly identify an individual ( “ Personal Data ” ) collected through the use of its website and other means of our Company .

Our website is located at compliance with the General Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the freedom of expression circulation of such data ( ” GDPR Regulation ” ) , which is directly binding legislative act . The GDPR Regulation creates some new rights for natural persons and strengthens some of the rights that already existed under Directive 95/46/EC. Directive 95/46/EC was repealed on 25 May 2018, when it was in GDPR Regulation in force .

The terms of this policy concern :

a) SUBSCRIBERS – CUSTOMERS. As subscribers – customers users who have implemented at least a purchase of a product or service from our Company . In this case, data processing is necessary for the performance of the contract with the contracting party .

b) VISITORS – USERS. As visitors or users visitors who use our website and / or any of its free features such as newsletter subscription , participation in webinars etc.

Any processing of personal data carried out by our Company is carried out in accordance with such way to ensure its confidentiality . All information is stored securely and access to it is only permitted in authorized personnel . Our Company implements and develops the necessary technical and organizational measures for the protection of Data . Personal Character of Users / Visitors , Final Customers , as well as Foreign Collaborators (all of them) understood as ” Subjects ” of personal data a ) by non- unauthorized or unlawful processing and use , as well as possible loss , destruction , damage , theft or unlawful entry .

2. Collection and Use of Personal Data

2.1 The legal basis for the use of your personal data

Our Company collects only All personal data is necessary in order to fulfill our contractual obligations as arising from the applicable legislative framework and related binding decisions of competent authorities . Whenever additional , optional information is requested , you will be informed relevant at the time of collection of this data and the previous one may be required your consent to processing .

We apply the current legislative framework and we process personal data only since we have the legal basis to carry out this action . The processing of personal data You are welcome . one or more of the following bases :

• Supply Consent : You may occasionally be asked for your consent in order for us to process some of your personal data . The processing of your data will be carried out with this consent . him way , only since agree explicitly for this ( article 6, paragraph 1a of the GDPR Regulation ).

• Implementation contract : In these cases, the processing of your personal data is necessary for the fulfillment of our Company ‘s obligations , as arising from the contract concluded between us ( Article 6, paragraph 1b of the GDPR Regulation ) or a related your written assignment to our Company .

• Legal obligation : This This occurs in cases where we are obliged to process your personal data in order to comply with a legal obligation , such as , for example : a ) to keep records for tax purposes purposes , b) to provide information in a public body , which has the relevant authorization by Law (e.g. tax authorities and insurance companies ) bodies ), c) to comply with legislative or regulatory requirements order or a court decision ( Article 6 (1) ( c) of the GDPR ) .

• Protection of your vital interests : In this case the processing of your personal data is necessary for the protection of your vital interests. your interests ( Article 6 (1) ( d) of the GDPR ).

• Fulfillment of a duty performed for the public interest or in the exercise public authority : This occurs in cases where the processing of your personal data is necessary for the performance of a task carried out by the public authority . interest ( article 6 paragraph 1e of the GDPR Regulation ).

• Legal interest : Your personal data may be processed if this processing constitutes lawful interest of our Company in the performance of its legitimate professional activity , in order to ensure the continuity of this activity . This processing , in in any case it cannot and will not exceed the interests , freedoms and fundamental your rights ( article 6 paragraph 1f of the GDPR Regulation ).

Our Company collects special categories of personal data , as defined in Article 9 of the GDPR Regulation , when the same natural persons , without our own requirement , they provide us with this data or if the data is required or the collection They are permitted by law .

The concept of “ special categories ” personal data includes personal data relating to a person ’s race , nationality , political opinions , membership of a trade union or other organisation . trade union membership , his religious beliefs , his philosophical beliefs , his physical or mental health , his sexual life and orientation , data relating to criminal convictions and punishable acts . Our Company rarely processes such kind data only provided that it is absolutely necessary within the framework of the above grounds .

2.2 How we collect your Personal Data .

Regarding the collection of your personal data , the Company collects your personal data when :

• You buy or rent ( online , via telephone or in person ) products or services from us .

• Register for purchase or rental of a product or the provision of Whose service ?

• Sign up in services in order to receive electronic newsletters .

• You are requesting information . about a product or service , or contact us about submitting questions or complaints .

• Participate in any surveys or competitions or webinars or exhibitions .

• Visit or navigate in the the Company ‘s website and in general you make use of electronic and / or digital products and services of the company , e.g. cookie identifiers , IP addresses or other identifiers identification data , according to the more specific terms use of the company ‘s applications .

• You are coming. in communication with our Company during the support of the company ‘s applications ( e.g. telephone , in person , electronic ) , in accordance with the legal requirements .

• You visit the Company ‘s facilities and store( s ) , where we may collect indoor image data CCTV for security and crime prevention purposes actions .

In any case required by the applicable legislative framework , you will be asked for the explicit your consent to the processing of your personal data , such as collected by our Company .

Your consent is completely voluntary but in some cases it may not be possible to provide the services or supply the products . without the required processing .

2.3 What personal data do we collect ?

The information we collect about you depend on the products and services of the Company in which you have register or use , as well as from the your general communication with the Company . In the information we collect about you The following are indicatively included :

• Name , address , VAT number, telephone number , date of birth , occupation and address e – mail address . We collect this data directly from you and / or from publicly available sources .

• preferences for specific products , services or activities , if you tell us or we infer them from your use of our products and services and your navigation on the Site . our Company ‘s website and the born use electronic and / or digital products and services of the company , e.g. cookie identifiers , IP addresses or other identifiers identification data , according to the more specific terms use of the company ‘s applications .

• Information and personal data that may be communicated by you in the context of communication between us , such as from recording or audio recording of a call you make to our call center , whenever This is permitted by law , whether by e-mail, letter or any other means . form of communication you are trying to use .

• Information which related to your account , such as payment dates , transactional behavior , registration in services you use , or any other information associated with an account . It is clarified that in concept of the above The collection of data from you also includes the collection of data by a third party acting on your behalf ( natural or legal person ) .

2.4 Use of your personal data

In the Our company processes your data for various purposes . purposes , such as for:

• To process the products and services you purchase or hire from us and to keep you informed about the progress of your order .

• Let us inform you generally about new products and services ( unless you have opted out of receiving promotions ) messages ).

• To provide you with products and services tailored to This processing concerns services that are not part of our agreement , services that use information about you . where you are , if you use portable devices ( location data ) , but also the communication with messages about changes in products or services .

• To communicate with you with offers or promotions actions based on how you use our products and services . Usage includes calls and texts messages , location data and navigation information ( note that you will not receive such messages , if you choose to do so).

• bill you for the use of our products and services or to complete the payment of your bills .

• To respond to your questions or concerns regarding the use of our products or services .

• inform you about products and services others partners that we think you will be interested in ( including discounts and offers we have ) ( insurance for our customers ) .

• To understand him how you use our products and services . With this him way , we can develop more products and services of interest , tailored to your needs , as well as to personalize the products and services we provide to you .

• To prevent and deal with fraud or other crimes , to collect debts and claims from our customers our debtors .

• To provide aggregated reports on third parties (such as reports that do not include information through which a person is made ) .

• To provide information to the competent authorities to deal with situations emergency .

Our Company collects collectively data concerning in the visitation in website , including the number of Visitors and the number of visits , data geographical location , the time devoted to website , and the number of clicks on its links .

In addition , our Company may process personal data using advanced technologies for securing legal our interests ( e.g. digital signature ).

Finally , our Company , for all the above categories , may process personal data if such processing is necessary for the purposes of legal purposes interests that she pursues sixth if , against these interests , the interest or fundamentals prevail rights and freedoms of data subjects which require the protection of personal data .

2.5 Use of the Website – Your acceptance of the terms .

With your visit to our Company ‘s website , you consent to collection , use and processing of your Personal Data , as described in this Policy .

If you do not agree with the conditions set forth herein , we request don’t continue your tour of the our website .

Our Company may collect , record and process the data of visitors to its website . We may record your IP address and use cookies as described below .

Our Company may provide information collected through page view activity . In addition , our Company may collect and process any Personal Data you provide to us . voluntarily on our website forms , such as when you register for information and newsletters bulletin a.

2.6 Cookies

Cookies are small text files that are stored in your browser while you are browsing the Internet . Their purpose is to notify the website visited by the user , for the previous activity . Cookies are not used to run programs or install viruses on your computer.

With the express acceptance from On your part , you agree to the placement of cookies on your device . If you choose not to accept our cookies, we cannot guarantee that your browsing experience will be in the Our website will be economical .

We may also place third-party cookies for operational purposes . purposes and marketing purposes . The use of cookies is widespread and beneficial the Visitor.

2.7 IP addresses

An IP address (Internet Protocol address) is a unique number used by devices to communicate with each other . their recognition and understanding on a computer network that uses the Internet Protocol Standard. An IP address is, in other words, a number assigned to your computer every time you access the internet . It is allowed on computers and computers network servers to recognize and communicate with each other The IP addresses from which visitors appear to originate may be recorded for information technology security and system diagnostics purposes . This data may also be used in centralized format in order to carry out analysis of trends and performance of the corporate website .

2.8 Links to other locations ( links )

Our Company is not responsible for the content or privacy policy of these websites .

3. RETENTION AND DELETION

Our Company will not maintain data for a longer period of time a period of time beyond that required to fulfill the purposes for which collected or as required by the respective current legislative framework . Users ‘ data will be retained for at least 5 years after the end of the legal relationship between our Company and the Customers . relationship ( execution) contract ) , after the others The purpose of collecting these , according to the above , is also to promote new products and services of our Company . In some cases , certain personal information may be retained beyond this period , due to possible legal obligations , legal interests of our Company , etc. Such cases are , indicatively , those related to each branch of law ( tax , civil, criminal) etc. ).

In case, however , you rent software applications from the Company , with a
license to use provisionally your life , your personal and financial data will be kept
practically for all of you electronic / digital format .

4. ACCEPTANCE OF THESE TERMS

We assume that all Visitors to our website have carefully read this Privacy and Personal Data Protection Policy and agree with its content . If Anyone who disagrees with this should not uses the website and the communication platform with us . Our Company reserves the right to modify the Privacy and Personal Data Protection Policy according to its needs . In any case , we are available for any further clarification .

5. THE RIGHTS OF SUBJECTS

The new GDPR Regulation provides you with the following : rights regarding the processing of your personal data :

• Right of Access : You can request access to your personal data . This gives you the opportunity to receive a copy of your personal data held by our Company .

• Right to Rectification : You can request correction of your personal data . With the This way you are given the opportunity to correct any incomplete or inaccurate data about you that our Company has . In this case, we will need to verify the accuracy of the new data. data that you will provide to us .

• Right to Erasure : You may request the erasure of your personal data . This gives you the opportunity to request that we erase or remove personal data where there is no legitimate reason for us to continue processing it . Please note , however , that your right to maybe you specific cases may not be possible for specific lawyers reasons that will be communicated to you , as the case may be, at the time of submitting your request .

• Right to Restrict Processing : You may request restriction of the processing of your personal data . Specifically , you may ask us to stop processing your personal data in the following cases :

(a) If you want us to re- determine the accuracy of your personal data ,

(b) if you consider that the use of your data is abusive , but you do not want us to delete your data ,

(c) if we need to keep your data , even if we no longer require it from you , in order to be able to use it in the event of a potential claim exercise your rights .

• Right to Object : You may object to the processing of your personal data at any time . However , our Company may not be able to implement this because of your right , provided there are compelling and legal processing grounds that override your interests , rights and freedoms or for the establishment , exercise or defence of legal claims , such as, but not limited to , in cases where the processing of your data is based on in the performance of a duty performed for the public interest or in the exercise public authority (case of paragraph 1 of Article 6 of the Regulation ), or if the processing is carried out legal purposes interests of our Company or a third party (case f of paragraph 1 of article 6 of the Regulation ).

• Right to Portability : You can request the transfer of your personal data in you or you third parties . We will provide in you or the third party you have chosen to share your personal data with largely usable , electronically readable medium form . Please note that, your right to this valid only for automated information that you initially provided us with your consent to use or whenever we used this information to perform a contract with you .

• Right of Withdrawal Consent : You may withdraw your consent at any time , in cases where you have already provided your consent for the processing of your personal data . However , this will not affect the lawfulness of any processing that took place before your consent was withdrawn . If you withdraw your consent , our Company may not be able to position to offer you certain products or services . You will be informed relatively about this at the time of submitting your request .

• Non – automated decision – making : Automated decision – making takes country if an electronic system uses personal data to obtain a decision without human intervention . In this case you have the right not to be subjected to in decisions taken exclusively by through automated processing including profiling , which produces legal consequences that concern you or affect you significantly with similar way , except if you provide us with your consent , or it is necessary for the conclusion or execution of contract between or as otherwise permitted by law . You also have the right to challenge decisions made regarding you through the above procedure .

Furthermore , we know that you have Right to file a complaint with the competent authority Data Protection Personal Character in case you believe they have affects your rights from the processing of your personal data by our Company .

6. LEGAL OBLIGATION TO DISCLOSE PERSONAL INFORMATION

We may disclose the User ‘s personal information without prior consent . with his praise, only if we have reasons to believe that disclosure of this data is necessary for identity verification , communication or movement legal proceedings against persons or persons suspected of acts of violation or endangerment of the Company ‘s property rights or other individuals who could be harmed by the activities of these Users or with respect to persons who could ( intentionally or otherwise ) non lawful way ) to commit similar ILLEGAL acts . It is made clear that the disclosure will be made in accordance with the provisions of the law criteria and conditions .

7. THE PROTECTION OF YOUR PERSONAL DATA BY OUR COMPANY

The personal data processing process is carried out in a manner that ensures its confidentiality . Specifically , it is carried out exclusively and only by personnel authorized for this purpose , while all appropriate organizational and technical measures are taken . measures for the security of data and their protection against accidental or unlawful destruction , accidental loss , alteration , prohibited dissemination or access and any other form of unfair processing . More specifically :

• Confidentiality

All personnel of our Company are subject to an obligation observance confidentiality , all Processors of personal data on behalf of our Company , as well as any subcontractors of processing , are obliged to comply with the rules confidentiality and we ask them to declare compliance in writing with the GDPR Regulation .

When authorized personnel have access to personal data , this access is possible exclusively via encrypted connection . When accessing data in a database , the IP address of the person accessing the data must also be authorized .

Devices on which personal data is temporarily stored are always , except when in use or in transit , locked . in safety point . Personal data is stored securely . media with composites security controls that prevent unauthorized access .

• Integrity

To ensure integrity , all transits data are encrypted to align with best practices for protecting data confidentiality and integrity . Information is transmitted encrypted through the implementation of appropriate security measures and in are then encrypted in the database maintained by our Company so that they are only accessible in those who have authorization of access to such systems and those who are obliged to comply with them confidential information .

• Transparency

Our Company will notify you at any time of changes to our privacy and security procedures , including our practices and policies , through this website . You may request information at any time . about where and how your data is stored , how it is secured and how are used .

• Personal data breach notification

In the event that your data is breached , our Company will notify you , as well as the relevant Supervisory Authority . Principle within 72 hours and through email or other means medium , will provide you with information regarding the scope of the breach and the affected data . Our Company, within the framework of its operation , will take any action required to limit such any damages consequences for the persons to whom the data refers .

NOTE : Communication over the internet (such as e-mails) is not secure . without encryption application . The communications you attempt They may include transportation . data through taxes countries , due to the nature of the internet . The Company does not undertake responsibility for any damage never unauthorized access or loss of personal data not subject to direct control her control .

8. RECIPIENTS

The personal data we collect may be transferred to third parties , provided that the lawfulness of the transfer is justified .

Furthermore , since If the lawfulness of the transfer is justified , your personal data may be communicated to the following categories of recipients :

We may share data about you with :

• Partners and associates , who participate in the process of providing the products and services you have ordered or use .

• Companies that have undertaken to provide services in the name or on behalf of the Company .

• Lawyers companies / lawyers , or media companies debtors , or organizations with related activities .

• Police and supervisory authorities , administrative bodies , courts or other public authorities to whom we are either required to provide information or to whom we are required to provide information They are authorized by law to request them .

Also :

• We will disclose data , if this is necessary . is deemed necessary , for protection against fraud , to protect our customers and to defend our rights and property .

• In the event that our Company is merged or sold in another organization , we may transfer the personal data we hold about you to the new organization .

• We may transfer your data to companies or service providers in countries outside the EEA ( European Economic Area) Zone ) under the conditions of applicable legislation . This will happen in the event that our partners or suppliers are established outside the EEZ or if you use products and services while visiting one of these countries .

9. CHANGES TO THE PERSONAL DATA PROTECTION POLICY

We try to review and update We are constantly reviewing this Privacy and Personal Data Protection Policy in order to comply with legal and regulatory requirements , while providing the best possible protection for your personal data Any such update will be communicated to you through the current website .

10. DATA PROTECTION OFFICER

Our Company has a “ Responsible Personal Data Protection ” , who is responsible for issues related to the protection of the privacy of individuals , as well as the secure and correct processing of Data Personal Character .

If you would like to receive more information or clarification regarding the data we collect and process , please contact us . in the address email info@strudleurope.eu