This website analyzes the usage behavior of visitors, with the help of cookies, among other things, for purposes of range measurement, optimization offers and personalization of content. Our analysis partners may combine this information with other data they have. You can obtain further information and change your data protection settings at any time under the link Learn more and settings. By continuing to browse the site, you agree to this data processing by the site operator and third parties – revocable at any time in the future.
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Data Privacy Statement

We respect your personal privacy
and will protect your data to the best of our ability.

Please find below our statement on the processing of personal data by our company in accordance with the legal requirements, especially with the EU General Data Protection Regulation (GDPR).

Contents:

  1. General information
    1. Definition of main terms
    2. Scope of validity
    3. Controller
  2. Itemisation of data processing operations
    1. General information about the data processing operations
    2. Accessing our services
    3. Newsletter subscriptions
    4. Prize draws and promotions
    5. Online shopping
    6. Tracking
    7. Application as employee in our company
  3. Rights of data subjects
    1. Right to object
    2. Right of access
    3. Right to rectification
    4. Right to erasure ("right to be forgotten")
    5. Right to restriction of processing
    6. Right to data portability
    7. Right to withdraw consent
    8. Right to lodge a complaint

General information

This section of the privacy statement contains information on the scope of validity, the person responsible for data processing, the data protection officer and data security. It also begins with a list of definitions of important terms used in the data privacy statement.

Definition of main terms

Browser: Computer program used to display websites (e.g., Chrome, Firefox, Safari)

Cookies: Text files which the web server places on the user's computer by means of the browser which is used. The stored cookie information may contain both an identifier (cookie ID) for recognition purposes and content data, such as login status or information about websites visited. The browser sends the cookie information back to the web server with each new request upon subsequent repeat visits to these sites. Most browsers accept cookies automatically. Cookies can be managed using the browser functions (usually under "Options" or "Settings"). The storage of cookies may be disabled in this way or it may be made dependent on the user’s approval in any given case or otherwise restricted. Cookies may also be deleted at any time.

Third countries: Countries outside the European Union (EU)

GDPR: Regulation (EU) 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 free movement of such data, and repealing Directive 95/46/EC General Data Protection Regulation

Personal data: Any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Profiling: Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Services: Our offers to which this data privacy statement applies (cf. Scope of validity).

Tracking: The collection of data and their evaluation regarding the behaviour of visitors in response to our services.

Tracking technologies: Actions can be tracked either via the activity records (log files) stored on our web servers or by collecting data from end devices via pixels, cookies or similar tracking technologies.

Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Pixel: Pixels are also called tracking pixels, web beacons or web bugs. These are small, invisible graphics in HTML emails or on websites. When a document is opened, this small image is downloaded from a server on the Internet and the download is registered there. This allows the operator of the server to see if and when an email has been opened or a website has been visited. This function is usually carried out by calling up a small program (JavaScript). Certain types of information can be detected on your computer system in this way and shared, such as the content of cookies, the time and date of the visit, and a description of the page on which the tracking pixel is located.

Scope of validity

This data privacy statement applies to the following offers:

All these offers are also collectively referred to as "services".

Controller

The following party is responsible for the processing of data in relation to the services, i.e., this is the person who determines the purposes and means of processing personal data:

Visual Hellas S.A.
28, Akademias St.
10671 Athens
Greece
Phone: +30 210 3611064
Email: visual@visual.com.gr

Itemisation of data processing operations

This section of the data privacy statement contains detailed information about the processing of personal data in the context of our services. The information is subdivided for greater clarity into certain functions in connection with our services. In case of the normal use of the services, different functions and therefore also different processing operations can be implemented consecutively or simultaneously.

General information about the data processing operations

The following applies to all the processing operations listed below, unless stated otherwise:

a. No obligation to provide personal data & consequences of failure to provide such data

The provision of personal data is not required by law or contract, and you are under no obligation to provide any data. We will inform you during the data entry process when personal information needs to be provided for the relevant service (e.g., by indicating 'mandatory fields'). In cases where the provision of data is required, the consequence of not providing data will be that the service in question cannot be provided. Otherwise, failure to provide data may result in our inability to provide our services in the same form and quality.

b. Consent

In various cases, you may also grant us your consent to the further processing of data (or some of the data, where applicable) in connection with the operations listed below. In this case, we will inform you separately in connection with the submission of the respective declaration of consent about all the procedures and the scope of the consent and about the purposes which we pursue in these processing operations. The processing operations based on your consent are therefore not listed again here (Art. 13, subs. 4, GDPR).

c. Transfer of personal data to third countries

When we send data to third countries, i.e., countries outside the European Union, the data are then transmitted strictly in compliance with the statutory conditions of admissibility.
If the transmission of the data to a third country does not serve the purpose of fulfilling our contract with you, if we do not have your consent, if the transmission is not required for the establishment, exercise or defence of legal claims, and if no other exemption applies under Art. 49 GDPR, we will only transmit your data to a third country if in possession of an adequacy decision pursuant to Art. 45 GDPR or appropriate safeguards under Art. 46 GDPR.
One of these adequacy decisions is the Commission Implementing Decision (EU) 2016/1250 of 12.07.2016 on the 'EU-US Privacy Shield' for the USA. The level of data protection is generally considered to be appropriate according to Art. 45 GDPR for transfers to companies which are certified under the EU-US Privacy Shield.
Alternatively or additionally, safeguards under Art. 46 subs. 2 c) GDPR through the conclusion of the EU standard data protection clauses adopted by the European Commission with the receiving body provide appropriate safeguards and an adequate level of data protection. Copies of the standard EU data protection clauses are available on the website of the European Commission at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

d. Hosting at external service providers

Our data processing work is carried out to a large extent with the involvement of hosting service providers who provide us with storage space and processing capacities at their data centres and who also process personal data on our behalf according to our instructions. It may be the case that personal data are transmitted to hosting service providers in respect of all of the functions listed below. These service providers process data either exclusively in the EU or subject to guaranteed levels of data protection which we have put in place based on the standard EU data protection clauses (cf. subsection c.).

e. Transmission to government authorities

We send personal information to government authorities (including law enforcement agencies) when required to fulfil a legal obligation to which we are subject (legal basis: Art. 6, subs. 1 c), GDPR) or when it is necessary for the assertion, exercise or defence of legal claims (legal basis: Art. 6, subs. 1 f), GDPR).

f. Period of storage

The time specified in the "period of storage" paragraph indicates how long we use the data for the purposes in any given case. At the end of this period, the data will no longer be processed by us but will be deleted at regular intervals, unless continued processing and storage are required by law (in particular, because it is necessary to fulfil a legal obligation or for the establishment, exercise or defence of legal claims) or unless you grant us extended consent.

g. Data categories

The category names listed below are used for specific types of data in the following sections:

Accessing our services

The passages below set out how your personal data are processed when you access our services (e.g., loading and viewing the website, opening the mobile app and navigating within the app). We would point out, in particular, that it is impossible not to send access data to external content providers (cf. subsection b.) due to the technical processes involved in transmitting information over the Internet. The third-party providers are themselves responsible for the privacy-compliant operation of the IT systems which they use. The service providers are required to decide how long the data will be stored.

a. Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

Data category Intended purposes Legal basis Legitimate interest, where applicable Storage period
Access data Establishing connection, presenting contents of the service, detecting attacks on our site due to unusual activities, fault diagnosis Art. 6, subs. 1 f), GDPR Proper functioning of services, security of data and business processes, prevention of misuse, prevention of damage through interference in information systems 4 weeks

b. Recipients of personal data

Recipient category Data concerned Legal basis Legitimate interests, where applicable
External content providers who provide content which is needed to display the service (e.g., images, videos, embedded postings from social networks, banner ads, fonts, update information) Access data Art. 6, subs. 1 f), GDPR; in case of transmission to the USA also Art. 45 GDPR in conjunction with the Commission Implementing Decision (EU) 2016/1250 of 12.07.2016 on the "EU-US Privacy Shield ” Proper functioning of services, (accelerated) display of content
IT security service providers Access data Art. 6, subs. 1 f), GDPR Prevention of attacks through exploitation of security gaps / vulnerabilities

Newsletter subscriptions

The tables below show how your personal data are processed when you subscribe to a newsletter:

a. Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

Data category Intended purposes Legal basis Legitimate interest, where applicable Period of storage
Email address Verification of the application (double opt-in procedure), sending of the newsletter Art. 6, subs. 1 b), GDPR Duration of newsletter subscription
Personal master data Personalisation of newsletter Art. 6, subs. 1 b), GDPR Duration of newsletter subscription
Login data Traceability of newsletter registration / confirmation / deregistration Art. 6, subs. 1 b), f), GDPR Proof of successful newsletter registration / confirmation / deregistration Duration of newsletter subscription
Newsletter user profile data Reflection of interests in the composition of the newsletter Art. 6, subs. 1 f), GDPR Improvement of our service, promotional purposes Duration of newsletter subscription

b. Recipients of personal data

Recipient category Data concerned Legal basis Legitimate interests, where applicable
Newsletter distribution service providers All data listed in 2.a. Processing on behalf of a controller (Art. 28 GDPR)

Prize draws and promotions

The tables below indicate how your personal data are processed when you enter prize draws or take part in promotions (e.g., events, polls, competitions).

a. Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

Data category Intended purposes Legal basis Legitimate interests, where applicable Period of storage
Personal master data Identification, age verification Art. 6, subs. 1 b), GDPR Duration of the prize draw / promotion
Address data Establishment of contact Art. 6, subs. 1 b), GDPR Duration of the prize draw / promotion
Contact data Establishment of contact Art. 6, subs. 1 b), GDPR Duration of the prize draw / promotion
Where applicable (according to the terms and conditions in any given case), answering of competition questions, provision of application information, voting information Execution of the relevant prize draw / promotion, selection of winners / entrants Art. 6, subs. 1 b), GDPR Duration of the prize draw / promotion

b. Recipients of personal data

Recipient category Data concerned Legal basis Legitimate interests, where applicable
Dispatch service providers Name, address data Art. 6, subs. 1 b), GDPR

Online shopping

The tables below set out how your personal data are processed in connection with an existing relationship between us and you as a customer in our online shop.

a. Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

Data category Intended purposes Legal basis Legitimate interests, where applicable Period of storage
Personal master data, address data, contact data Customer registration, identification, age verification, establishment of contact, provision of information relevant to your interests, issue of advertisements for own services and third-party services Art. 6, subs. 1 b), f), GDPR Customer relationship management, marketing of our services, promotional purposes 10 years after completion of the last purchase order
Purchase order data Purchase order processing, services relevant to interests Art. 6, subs. 1 b), f), GDPR Customer relationship management, marketing of our services, promotional purposes 10 years after completion of the last purchase order
Payment data Processing of payments for the service Art. 6, subs. 1 b), GDPR Duration of the contractual relationship

b. Recipients of personal data

Recipient category Data concerned Legal basis Legitimate interests, where applicable
Payment service providers Personal master data, address data, payment data Art. 6, subs. 1 b), GDPR
Collection service providers Personal master data, address data, payment data Art. 6, subs. 1 b), GDPR

Tracking

The passages below explain how your personal data are processed with the help of tracking technologies to analyse and optimise our services and to serve promotional purposes.

The explanation of the tracking methods also includes information on how to prevent or object to the processing of data.

Please note that this "opt-out” request, i.e., denial of consent to processing, is usually stored via cookies. If you use our services on a new end device or in a different browser, or if you have deleted the cookies set by your browser, you will need to reconfirm the refusal of consent.

The tracking methods presented here will only process personal data in pseudonymous form. No connection is made with a specific, identified natural person, i.e., the data are not merged with information which would reveal the identity of the person behind the pseudonym.

a. Tracking for the analysis and optimisation of our services and their use

(1) Purpose of processing

The analysis of user behaviour by means of tracking helps us to check the effectiveness of our services, to improve and adapt them to the needs of the users, and to correct errors. It also allows us to produce statistics on the use of our services (reach, intensity of use, surfing habits of users) – on the basis of uniform standard procedures – and thereby to obtain comparable figures across the market.

(2) Legal basis of processing
In cases where we provide services under a contract, the tracking and the associated analysis of user behaviour are carried out in order to fulfil our contractual obligations. The legal basis for this processing of personal data is Art. 6, subs. 1 b), GDPR. The evaluation of information obtained through tracking is necessary in order to optimise the provision of services according to the contractual purpose and to ensure the greatest possible benefit for you.

Otherwise, i.e., in cases where services are not connected with a contract, the legal basis for this processing of personal data is Art. 6, subs. 1 f), GDPR. We hereby pursue the legitimate interest in providing attractive services as efficiently as possible on the basis of the information gained through tracking and marketing them in the best possible way.

(3) Explanation of individual tracking methods

Name of service Mode of operation Option of preventing processing (opt-out) Data transfer to third country? Adequacy decision, where applicable (Art. 45 GDPR) Appropriate guarantees, where applicable (Art. 46 GDPR)
Google Analytics Our services use Google Analytics, a web analysis service of Google LLC ("Google"). Google Analytics uses cookies that enable an analysis of your use of the website. We use Google Analytics including the functions of Universal Analytics. Universal Analytics allows us to analyze the activities on our services across devices (e.g. for access via laptop and later via a tablet). This is made possible by the pseudonymous assignment of a user ID. The information generated by the cookie about your use of the website is usually transferred to a Google server in the USA and stored there. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. We have also added the code "anonymizeIP" to our Google Analytics services. This guarantees the masking (shortening of the last eight digits) of your IP address, so that all data is collected anonymously. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the services, to compile reports on activities within the framework of the services and to provide us with further services associated with the use of the services and the Internet. The data transferred and linked to cookies or user IDs will be deleted after 26 months. Data whose retention period has been reached is automatically deleted once a month. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our services. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following Link: http://tools.google.com/dlpage/gaoptout?hl=de. This plugin is provided by Google; please note that we cannot verify or control its functionality. As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking this link. An opt-out cookie is set that prevents future collection of your data when you visit the services. The opt-out cookie is only valid in this browser and only for the respective website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again. To prevent Universal Analytics from collecting data across different devices, you must opt-out on all used systems. Yes, USA Commission Decision (EU) 2016/1250 of 12.07.2016 on the so-called 'EU-US Data Protection Shield' ('Privacy Shield')

Application as employee in our company

In the following, we describe how your personal data is processed in connection with an existing application process between you and us for a position as an employee in our company:

a. Intended purpose of data processing and legal basis and, if applicable, legitimate interests, storage period

Category of data Intended purpose Legal basis Possibly justified interest Storage time
Personal master data, address data, contact data Identification, contact, communication for contract initiation Art. 6 para. 1 b) DSGVO 6 months
Cover letter, curriculum vitae, certificates, letters of recommendation and other application documents submitted by you Applicant selection & recruitment Art. 6 para. 1 b) DSGVO 6 months

Rights of data subjects

Right to object

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing with future effect, which includes profiling to the extent that it is related to such direct marketing.

You also have the right, at any time with future effect and for reasons relating to your particular situation, to object to the processing of personal data concerning you which is based on Art. 6, subs. 1 e) or f), GDPR, including profiling based on these provisions.

The right to object may be exercised free of charge. In order to be able to process your request, please contact us using the contact information provided in paragraph I.3 or alternatively via email to visual@visual.com.gr

Right of access

You have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and the other information listed in Art. 15 GDPR.

Right to rectification

You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay (Art. 16 GDPR). Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure ("right to be forgotten")

You have the right to obtain from us the erasure of personal data concerning you without undue delay if one of the reasons listed in Art. 17, subs. 1, GDPR is applicable and the processing operations are not required for one of the purposes approved in Art. 17, subs. 3, GDPR.

Right to restriction of processing

You are entitled to obtain from us the restriction of the processing of personal data if one of the conditions laid down in Art. 18, subs. 1 a) to d), GDPR is met.

Right to data portability

Under the conditions set out in Art. 20, subs. 1, GDPR, you have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance on our part. In exercising your right to data portability, you have the right to have the personal data transmitted directly by us to another controller where technically feasible.

Right to withdraw consent

If the processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authority responsible for our company. The supervisory authority responsible for our company is:

Hellenic Data Protection Authority, Kifissias 1-3, 115 23 Athens, Greece, http://www.dpa.gr

Date of Data Privacy Statement
May 2018