Privacy Policy

COMMA AGENCY PRIVACY POLICY

EFFECTIVE DATE: May 24, 2018

Data Protection Policy

The protection of your personal data is important to COMMA. This Data Protection Policy (hereinafter referred to as the "Policy") describes how the company "KAPPAS H.-KRIGOU A. O.E." operating under the trade name "COMMA" (hereinafter referred to as the "Company"), located at 308 Kifisias Avenue, Chalandri, Attica, processes your personal data (hereinafter referred to as "Data") when you use its website www.comma-abc.com. For any questions regarding the processing of your Data, feel free to contact us at [email protected].

1. About the Company

The Company provides comprehensive advertising services to corporate clients, including outdoor, print, digital, television, and/or radio advertising, product promotion in television or radio broadcasts, photography/videography for advertising purposes, television production of advertising spots, and website (e-shops) construction services.

2. What is personal data?

Personal data (hereinafter referred to as "Data") refers to information of natural persons such as name, postal address, email address, contact phone number, which identify or can identify your identity.

3. What is Personal Data Processing?

Processing of Personal Data refers to any act or series of acts performed on personal data or sets of personal data, with or without the use of automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Which Data does the Company process?

We ensure to collect only the absolutely necessary Data which are suitable and clear for the intended purpose. Indicatively, we collect:

- Identity Data such as name and surname.

- Contact Data such as postal address, email address, phone number.

- Data collected through Cookies (e.g., IP address) when using the Software.

- Identification details such as username.

5. For what purpose does the Company process your data?

Your Data is processed to provide you with the following services:

- Comprehensive advertising services: The Company processes your Data to fulfill its contractual relationship and comply with its legal obligations.

- Digital Marketing services: The Company processes your Data to provide you with digital marketing services.

- Photography/videography services: The Company processes your Data to provide you with photography/videography services.

- Website construction services (e-shops): The Company processes your Data to complete the construction of your company's website.

- Promotion of products on television and/or radio broadcasts: The Company processes your Data to promote your products on television and/or radio broadcasts.

- Communication: The Company uses your Data to respond to requests/inquiries you submit through the contact form.

- "START YOUR PROJECT" form: The Company uses your Data to contact you for the implementation of your project.

6. What is the legal basis for processing your Data by the Company?

The processing of your Data is conducted in accordance with:

- The terms of our contractual relationship.

- Your consent where required.

- The Company's obligations derived from the law (e.g., tax legislation, etc.).

- The legitimate interest of our Company.

7. Who processes your Data?

Along with the Company, it is possible that your absolutely necessary Data will be processed by its partners or third-party companies providing accounting services and IT services. In such cases, the partners/third-party companies act as Data Processors on behalf of the Company. However, the Company remains solely responsible for the security of your Data, taking all necessary measures. Besides these partners or third-party companies, the Company does not disclose, process, or publish your Data to third parties, except when required by the applicable legislative framework. Also, recipients of your Data may include third parties such as public authorities, services, or other entities.

8. How does the Company ensure that its partners respect your Data?

The Company's partners have agreed and committed:

- To maintain confidentiality.

- Not to send the Company's customers' Data to third parties without its permission.

- To take appropriate technical and organizational security measures.

- To comply with the legal framework for personal data protection, i.e., Regulation 979/2016/EU (otherwise GDPR) and Law 4624/2019.

9. Does the Company send your Data outside the EU?

The Company does not transfer your Data to countries outside the EU.

10. How long does the Company retain your Data and when does it delete it?

The Company retains your Data for as long as necessary to provide its services unless an extension is required due to legal claims or legal obligations. Data collected by Cookies is deleted according to the Cookies Policy (LINK TO BE PROVIDED).

11. Is your Data secure?

The Company is committed to safeguarding your Data and has taken the necessary and appropriate organizational and technical measures to protect it from any form of accidental or unlawful processing. These measures are reviewed and modified when deemed necessary.

12. What are your rights?

You have the right to access your Data, rectify inaccurate Data, delete your Data, transfer your Data, restrict processing, and withdraw/oppose the processing of your Data.

13. How can you exercise your rights?

To exercise your rights, you can submit a written request (LINK TO BE PROVIDED) to the Company's address at 308 Kifisias Avenue, Chalandri, Attica, or send an email to [email protected].

14. When does the Company respond to your requests?

The Company responds to your requests free of charge without delay and in any case within one (1) month from when it receives your request. However, if your request is complex or there is a large number of requests, the Company will inform you within the month if it needs a two (2) month extension to respond.

If you do not receive a response within the prescribed period (one month with an extension of two months under conditions) or if the response you receive is not satisfactory or the issue is not resolved, you can contact the Data Protection Authority (www.dpa.gr).

15. What law applies to the processing of your Data by the Company?

The applicable law is Greek Law as shaped by the General Data Protection Regulation 2016/679/EU and Law 4624/2019, as well as the applicable national and European legislative and regulatory framework for the protection of personal data.

16. Which courts are competent for any disputes related to the Data?

The competent courts for any disputes related to the Data are the Courts of Athens.

17. How will you be informed of any changes to this Policy?

The Company updates this Policy whenever necessary. If there are significant changes to the Policy or the way the Company uses your Data, an update of this Policy will be posted. The Company encourages you to read this Policy regularly to know how your Data is protected.