PERSONAL DATA PROTECTION POLICY

Lux & Easy Residences (brand name of the company “Nova Constructions SA”, which will be referred to as the “company” for the sake of brevity) has taken all necessary technical and organizational measures to fully ensure your privacy and the security of your personal data, in accordance with the applicable European and national legislation.

Please take some time to read this Privacy Policy (hereafter “Policy”) and learn about how the company, acting as a Data Controller, collects, stores, uses and generally processes your personal data when you visit, register or use the Company’s website as well as when you meet and interact at the Company’s offices, whose headquarters are located in Kallithea, at Alexandrou Pantou Street, no.33.

This Policy also describes how we use, share and protect your personal data, the choices you have regarding your personal data, and how you can contact us.

This Policy applies to all your personal data processed by the company in the provision of its services to you. In particular, it records and analyses: the type of personal data processed by the company, the legal basis of the processing, the period of data retention, the recipients of the personal data and the technical and organisational measures taken by the company to guarantee privacy security.

1) What is personal data?

The term “personal data” refers to information of natural persons, such as full name, postal address, e-mail address, contact telephone number, IBAN/ IBAN No. Account number, etc., which identifies or can identify you, hereinafter referred to as “Personal Data or Data”.

2) Data we process

The company collects your personal data when you contact us either by phone or by email or even during your visit to the Company’s offices.

In particular, the Company collects the following data and personal data:

-first and last name, maiden name, patronymic, maiden name

-email, mobile and landline phone contact,

-data on the conclusion of contracts and on payments/disbursements: VAT number, DOY, IBAN, occupation, copy of identity card

-address details

– Your image can be recorded on CCTV when you visit our offices

– your comments and reviews on social media and other networks

– Educational data, such as studies, skills, knowledge of foreign languages, professional experience (only if you are applying for a job)

We comply with the law and do not allow the processing of data of children under the age of 16 without written parental consent.

The processing by us of your above data is carried out solely to ensure the Company’s proper execution and provision of its services to you as well as for the conclusion of private agreements or purchase and sale contracts and for the issuance of the corresponding documents (receipt). In addition, and if you wish, we process and store your contact details for the purposes of promotional activities only, in order to send you information about any promotional activities, if you accept it.

In case you visit the company in our offices, we collect the data related to your easy service and only for this purpose (name and surname). In addition, in the context of the current coronavirus pandemic, you may be asked for a certificate of vaccination or Rapid Test when you enter the company’s offices.

Finally, we inform you that the processing of your Data is carried out either by the Company’s specially authorized personnel and, exceptionally, by third parties who, having been contractually bound to maintain confidentiality and protect your Data, carry out tasks necessary to achieve the purposes strictly related to the use of our website and the provision of our services to you. You will find information about this below:

3) Lawful basis for processing your data

H Lux & Easy Residences processes your basic personal data solely for the correct and legal provision of its services to you and for your easy convenience. Therefore, the expression of your interest and the provision of services to you in accordance with the purposes of our company is the legitimate basis for the processing of your data. Also a lawful basis for processing your data may be any request for the evaluation of your applications and CVs for the purpose of recruitment to our Company.

In particular, the basis for processing the data is :

Data protection legislation sets out various reasons why a company may collect and process your personal data, including: the terms of our contractual relationship

Your consent, where required. For example, when you choose to receive our newsletter. When collecting your personal data, we will always inform you which data is necessary in relation to a particular service.

The Company’s obligations arising from the law (e.g. tax legislation, e-commerce legislation, etc.)

The legitimate interest of our Company.In certain cases, we collect your Data in a way that is reasonably expected as part of the operation of our Company and that does not substantially affect your rights, freedom or interests.

4) Retention period of your data

We retain your personal data for as long as the purposes for which they were collected and mentioned above remain valid.

Our Company may retain your personal data even after the fulfilment of the purposes of their collection and processing in the following limited cases:

1) If we are legally obliged by a relevant legal provision.

2) For use before tax and social-insurance authorities and any other auditing authority within the legal limitation period.

3) If required for the proper organization and operation of our company (e.g. for statistical purposes) provided that anonymization and pseudonymization of your data takes place.

4) Until the statute of limitations for the defence of the rights and legitimate interests of the company before any competent court and other public authority.

Please note that, after the retention period, your personal data are destroyed from our files and system in accordance with our company’s policy and provided that their retention is no longer required to fulfill the purposes described above.

5) Recipients of your personal data

In order to serve the processing purposes set out in this policy, our company may provide access to or transfer the following types of your personal data to the following processors on its behalf and at its request:

-name/name, address details and contact telephone number of partner courier companies and post offices.

-Your personal data to the company’s web hosting and software maintenance and support service provider

-Your financial data to the credit institution with which we cooperate each time for the processing of payments to and from your bank and credit card accounts during the purchase.

-Your personal data to accountants, lawyers and notaries in the context of the performance of their services to our company or to auditors in case of an audit.

-The evaluation of applications and CVs for the purpose of recruitment in our Company.

-Access to your Data is provided to the Company’s staff, who are bound by confidentiality obligations, and to our partner companies or third party service providers, who process your Data as Processors on our behalf and in accordance with our instructions.

The processing of your personal data by the aforementioned partners is always carried out under our control and only on our instructions and is subject to the same data protection policy or a policy of at least the same level of protection.

In the event that we are obliged by a court or other administrative authority and in any other case where we are under a legal obligation to do so, our company may disclose your personal data to the extent provided by law and upon your notification,

It is clarified that the company is not responsible for the management of your personal data by third parties.

However, and for maximum assurance that your data will not be leaked even by third party partners (processors), the company provides the guarantee to third parties that:

Maintain confidentiality,

They do not send your Data to third parties without the Company’s permission,

Take appropriate security measures,

Comply with the legal framework for the protection of personal data and in particular Regulation 979/2016/EU (otherwise GDPR)

6) The security of your data

Our priority is to keep your personal data secure. Our company has taken and implements a number of measures to keep your personal data safe and secure. These measures include, where applicable, role based access control to the data as well as pseudonymisation, encryption or other technical and organisational measures.

7) Your rights

We inform you that you have the right to :

Access to your data:

This means that you have the right to be informed by us if we process your Data. In this case, you can request to be informed about the purpose of the processing, the type of your Data we hold, who we give it to, how long we store it, whether automated decision-making is carried out, and your other rights, such as rectification, erasure, restriction of processing and filing a complaint with the Data Protection Authority.

Correction of your data in case of inaccuracy:

If you find that there is an error in your Data, you may submit a request to us to correct it (e.g., to correct your name or update a change of address or other data).

Deletion of your data in specific cases / right to be forgotten:

You can ask us to delete your data if it is no longer necessary for the above mentioned processing purposes or you wish to withdraw your consent in case this is the only legitimate basis.

Restriction of processing of your data:

You can ask us to restrict the processing of your Data for as long as your objections to the processing are pending.

Sensitivity to the processing of your data:

You may object to the processing of your Data and we will stop processing your Data unless there are other compelling and legitimate reasons that override your right. If you have consented to the collection, processing and use of your Personal Data, you may withdraw your consent at any time with future effect.

Transfer of your data to another controller (portability):

You may request to receive the Data you have provided in a readable form or request us to transfer it to another controller.

Complain to the Data Protection Authority in the event of an unfortunate incident of a data breach.

Our company will respond to your above requests immediately and within a maximum of one month from their receipt, and this deadline may be extended by 2 more months, if your request is complex or further time is required due to a large number of requests.

If your requests do not meet the requirements of the law, our company reserves the right to either charge a reasonable fee taking into account the administrative costs of providing the information or the communication or performance of the requested action or to refuse to comply with your request.

Remember, if you choose not to share the Data with us or deny certain communication rights, we may not be able to provide some of the services you have requested. For example, if you have even asked us via email to let you know about the availability of a property, we may not be able to serve you if you have withdrawn your general consent to receive updates from us.

In the event of a breach of your personal data, which may pose a high risk to your rights and freedoms and provided that it does not fall within one of the exceptions expressly provided by law, we undertake to inform you without undue delay.

However, if there are doubts about the identity of the natural person submitting the request, we reserve the right to request additional information necessary to confirm the identity of that person.

In case you need clarification or further information about your above rights, you can contact our call centre or contact our Data Protection Officer (contact details below).

8) User obligations

By using our website and by providing your personal data after consent you acknowledge that you have the obligation to provide the true, accurate and complete information requested by our company.

9) Cookies

Our website works with cookies. Learn more about how we use cookies here.

10) Managers

We would like to inform you that you can contact us for any issue concerning the security of your data at the following telephone number 2130997060 and by email: in**@lu******************.com

The person responsible for the protection of your data in our company is Mrs. Argyriou Konstantina-Maria (tel. Contact: 33 Alexandrou Pantou no.33 Kallithea, P.O. Box: 17671)

If you are dissatisfied with the way your data is processed, you can lodge a complaint with the Data Protection Authority. However, we would welcome the opportunity to resolve any complaint as soon as possible before you make a complaint to the Data Protection Authority.

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