Privacy Policy

Notification of processing of Personal Data in accordance with article 13 of Regulation (EU) 2016/679 (“GDPR”)

Dear User, the limited liability company with the name “ETVA INDUSTRIAL AREAS S.A.” welcomes you to its website (hereinafter the “Website”) and invites you to pay attention to the following notice (hereinafter the “Notice”), which is issued in accordance with Article 13 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of their personal data and on the free movement of such data (hereinafter the “GDPR” or “Regulation”). The term “Personal Data” (or, hereinafter, simply “Data”) refers to any information concerning an identified or identifiable natural person, that is to say, information about natural persons, such as name, postal address, email address, contact telephone number, etc., which identifies or can identify you. This document contains a record of the processing carried out by the Data Controller, as defined below, through the Website, as well as the manner in which your Personal Data is used, disclosed and protected, the choices you have regarding your Personal Data, and how you can contact us. This Privacy Policy is in accordance with the terms arising from the Regulation and any other relevant applicable legislation. It is clarified that the information only concerns the Website, therefore excluding any website to which you may be redirected from the Website.

1. Data Controller The Data Controller is the company with the name “ETVA INDUSTRIAL AREAS S.A.” and the tax ID number “ETVA VI.PE. S.A.”, Tax Identification Number 999505936 Tax Office of Athens, with registered office in the Municipality of Filothei – Psychiko, no. 265 – P.C. 15451, e-mail address www.etvavipe.gr and telephone number 00302109540000 (hereinafter the “Company” or “We” or “our”). This means that the Company manages the Website and determines the purposes and manner of processing your Personal Data in accordance with the Regulation and generally applicable legislation. The Company has also appointed as its representative for Personal Data protection issues Ms. Hanioti Vasiliki, with whom you can directly contact to exercise your rights, as well as to receive any information regarding the processing of your Personal Data and/or this Notice, at the following email address: contact@etvavipe.gr and at the contact telephone number: 00302109540000
2. Sources of Personal Data Collection During the operation of the Website, the Company collects Personal Data directly from you and not from third-party sources. Specifically, the Company collects, stores and generally processes Personal Data: (a) of Land Owners within Industrial Areas/Business Parks/Industral Parks and their legal and authorized representatives, who wish to be certified on the Company’s Website and to participate in the dialogue on the Company’s proposals for the revision of the Operating Regulations, either/or in the Consultation and Voting procedures provided for in Law 4982/2022 for the revision of the Operating Regulations of the Industrial Areas/Business Parks/Industral Parks managed by the Company (“Personal Data for Operating Regulations”), or/or in the provisions of the applicable Operating Regulations of the Industrial Areas/Business Parks/Craft Parks Areas/Business Parks/Industral Parks Consultation and Voting procedures for the approval of Extraordinary Budgets
   (“Personal Data for Extraordinary Budgets”). The Personal Data for Operating Regulations
   are provided by you, in the context of your visit to the Company’s Website, when submitting an application as a Landowner for participation in the dialogue on the Company’s proposals for the revision of the Operating Regulations
   , or/and in the Consultation and Voting process for the revision of the Operating Regulations
   of Industrial Areas/Business Parks/Craft Parks and specifically when submitting a Responsible Declaration, after clicking on the relevant link on the home page. Accordingly, the Personal Data for Emergency Budgets is provided by you, in the context of your visit to the Company’s Website, when submitting a Land Owner application for participation in the Consultation and Voting process for the approval of Emergency Budgets of Industrial Areas/Business Parks/Craft Parks and specifically when submitting a Responsible Declaration, after clicking on the relevant link on the home page. In order to serve the above purpose and fulfill the service that you, as a user, request, it is deemed necessary to collect, through a Responsible User Declaration, and to process by us the following Personal Data, otherwise the provision of the service will be impossible:
   • The details (name, VAT number, Tax Office, G.E.MI. number, etc.) concerning the Land Owner, who wishes to participate in the dialogue on the Company’s proposals or/and in the Consultation and Voting process for the revision of the Operating Regulations of Industrial Areas/Business Parks/Craft Parks, or/and in the Consultation and Voting process for the approval of Extraordinary Budgets in Industrial Areas/Business Parks/Craft Parks.
   • The information concerning the legal representative (name, VAT number, Tax Office, capacity, etc.) of the Land Owner, provided that he is a legal entity, who wishes to participate, in the name and on behalf of the legal entity, in the dialogue on the Company’s proposals or/and in the Consultation and Voting process for the revision of the Operating Regulations of the Industrial Areas/Business Parks/Craft Parks, or/and in the Consultation and Voting process for the approval of Extraordinary Budgets in the Industrial Areas/Business Parks/Industrial Parks.
   • The information concerning the person (name, title, etc.), whom the Land Owner or his legal representative authorizes to participate, in the name and on behalf of the Land Owner, in the dialogue on the Company’s proposals or/and in the Consultation and Voting process for the revision of the Operating Regulations of Industrial Areas/Business Parks/Industrial Parks, or/and in the Consultation and Voting process for the approval of Extraordinary Budgets in Industrial Areas/Business Parks/Industrial Parks.
   • Any personal information available via e-gov.gr to the recipient of the Responsible Declaration, in the event that the User chooses to issue the Responsible Declaration via e-gov.gr.
   • Any personal information that is available and becomes known to the recipient of the Responsible Declaration, in the event that the User chooses to have the original signature of the Responsible Declaration verified through another Public Authority.

   (b) Business entities within Industrial Areas/Business Parks/Industrial Parks and their partners – users of the Website, who wish to submit to the Company data regarding the electricity and water consumption of the facilities they maintain within the Industrial Areas/Business Parks/Craft Parks (“Personal Data for Public Utilities”), for the purposes of: (i) Providing a service to established businesses of bulk transmission of their utility data to competent bodies, in order to avoid double charging of remunerated services. It is noted that the Company assumes no responsibility in the event of non-response or non-timely response of the competent bodies to their own obligations, (ii) Research and improvement of the quality of the services provided by the Company for the Administration and Management of Industrial Areas/Business Parks/Industrial Parks. The above Personal Data for Public Utilities are provided by you, in the context of your visit to the Company’s Website and specifically to the Public Utilities Registration Platform maintained on the Website (“Platform”), after you complete and submit the corresponding fields provided for in the Platform and/or submit/”upload” to the Platform Electricity Bills and/or Water Bills (“Accounts”) of your business. In order to serve the above purposes and fulfill the service that you, as a user, request, but also for the purposes of research and improvement of the Company’s services, it is deemed necessary to collect, through the information that you complete and submit and/or through the Accounts that you submit/”upload”, the following Personal Data:

   • The data (name, full name, VAT number, Industrial Area/Business Park/Industrial Park of establishment) concerning the Entity of the established business, which wishes to participate in the fulfillment of the processing purposes.
   • The data concerning the user of the Platform (name and surname, capacity/relationship with the established business, contact email), who submits the data of the Entity of the established business, who wishes to participate in the fulfillment of the processing purposes.
   • Data regarding electricity supplies (provider, total number of supplies, number and exact location within the Industrial Area/Business Park/Industrial Park of each supply, user name and address of the user of each supply, type of invoice, agreed power, installed power, electricity consumption, value of energy consumed, etc.), municipal fees/taxes (square meters of installation, charging factor, day factor, result, etc.), water consumption and charges and generally any personal or other information available in the Accounts that the User will submit/”upload” to the Website Platform.
3. For what purposes do we process your Personal Data and what is the legal basis for the processing?
   Purpose of processing your Personal Data, which includes, among other things, personal
   User identification data and contact details and which (processing) is based on the article
   6 par.1 of the General Data Protection Regulation, are:
   (a) With regard to Personal Data for Operating Regulations, the identification and authentication of
   User for participating in the dialogue on the Company’s proposals for the revision of the Regulations
   Operation, or/and the determination of its fulfillment of the criteria provided for in Law 4982/2022 for its participation in the Consultation and Voting process for the revision of the Operating Regulations of Industrial Areas/Business Parks/Industrial Parks, as the processing is necessary for compliance with a legal obligation of the Company (article 6(1)(c) of the General Data Protection Regulation).
   (b) Regarding Personal Data for Extraordinary Budgets, the identification and authentication of the User for his participation in the Consultation and Voting processes for the Approval of Extraordinary Budgets in the Industrial Areas/Business Parks/Industrial Parks managed by the Company, in accordance with article 45 par. 4 of the Operating Regulations in force, as the processing is necessary for the performance of a contract (article 6(1)(b) of the General Data Protection Regulation).
   (c) With regard to Personal Data for Public Utilities, the identification and authentication of the User and the use of the data and information that he, with his consent (article 6(1)(a) of the General Data Protection Regulation), provides for the purposes of: (i) Providing a service to established businesses of mass transmission of their utility data to competent bodies, in order to avoid double charging of remunerated services. It is noted that the Company assumes no responsibility in the event of non-response or untimely response of the competent bodies to their own obligations, (ii) Research and improvement of the quality of the Administration and Management services provided by the Company for Industrial Areas/Business Parks/Industrial Parks.
4. Security The Company processes your Personal Data in a manner that ensures its protection, taking all appropriate organizational and technical measures for the security of the Data and its protection from accidental or unlawful destruction, accidental loss, alteration, prohibited dissemination or access and any other form of unlawful processing.
5. Disclosure to third parties and categories of recipients In order to achieve the purposes described in paragraph 3 above, your Personal Data may, in addition to the Company’s specially authorized personnel, which is limited to the absolutely necessary persons, be brought to the attention of external service providers who have contracted with the Company for these purposes or, where applicable, to the attention of other public authorities to satisfy your requests. In particular, Personal Data for Public Utilities may be transmitted to third parties (e.g. to competent local authorities, electricity, water and sewage service providers), for the purpose of serving and implementing their respective processing purposes. The Company does not transmit your Personal Data to a third country or international organization.
6. Geolocation Data The Site may collect and process data locating geographic location for the provision of services, requested by the User, only with the special consent of the interested party, which can always be revoked. In this case the consent will requested through what is known as a pop-up window.
7. Subject Rights This section presents your rights in relation to your Personal Data and their processing by the Company. These rights are subject to certain exceptions, reservations or limitations. Please submit your requests responsibly. The Company will respond to you as soon as possible and in any case within one (1) month from receipt of the request, a period that may be extended up to a maximum of two (2) months, in case of complexity of the request or if there is a large number of requests, at which time you will be informed accordingly. To exercise your rights, you can contact the email: legal@etvavipe.gr The Company ensures the smooth exercise of your following rights:
   7.1. The right to information/notification You have the right to request and receive clear, transparent
   and easily understandable information about how we process your Personal Data,
   in accordance with the Company’s current policies and procedures.
   7.2. The right to access You have the right to be informed by us whether we process your Data
   and for what purposes and to access them free of charge, in accordance with the Company’s current policies and
   procedures, except in the following cases, where a reasonable charge may be made
   to cover the Company’s administrative costs:
   • manifestly unfounded or excessive/repeated requests, or
   • additional copies of the same information.

   7.3. The right to rectification You have the right to request the rectification of your Personal Data, if it is inaccurate or incomplete, in accordance with the Company’s policies and procedures. The Company is not obliged to check the accuracy or truthfulness of the Personal Data submitted to the Website, nor is it liable in any way for any inaccuracy or untruthfulness.
   7.4. The right to erasure / right to be forgotten You have the right to request the deletion or removal of your Personal Data, when it is no longer necessary for the purposes for which it was collected or there is no legitimate reason for continuing to process it, in accordance with the Company’s policies and procedures. The right to erasure is not absolute, to the extent that there is a specific legal obligation or other legitimate reason for the Company to retain your Personal Data.
   7.5. The right to restriction of processing In certain cases, you have the right, in accordance with the Company’s policies and procedures, to restrict or eliminate the further processing of your Personal Data. In cases where processing has been restricted, your Personal Data will remain stored without being further processed.
   7.6. The right to data portability You have the right to request that the Personal Data concerning you, which you have provided to us, be transferred to a structured, commonly used and machine-readable format, and to transmit such Data to another controller, in accordance with the Company’s policies and procedures.
   7.7. The right to object You have the right to object, at any time and for reasons relating to your particular situation, to the processing of your Personal Data, which is based on Article 6(1)(f) of the Regulation (processing for reasons of legitimate interest of the Company), in accordance with the said provision. In such a case, the Company as controller shall no longer process the Personal Data, unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
   7.8. The right to withdraw In the case of Personal Data for Public Benefit Services and to the extent that the processing thereof is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing that was based on your consent before its withdrawal.
   7.9. Rights regarding automated individual decision-making and profiling The Company does not carry out automated individual decision-making, including profiling.
   7.10. How to exercise your rights The exercise of the aforementioned rights requires the submission of a written request to the Company entitled “Exercise of a right regarding Personal Data”, in accordance with its respective policies and procedures.

8. Retention period of Personal Data For each category of Personal Data, the Company determines the retention period in accordance with the provisions of the Law for each category of Personal Data and its internal policies and procedures. In any case, the retention period of the Data will not exceed five (5) years from the completion of the implementation of the respective purposes for each category of Personal Data.
9. Contacting the supervisory authority For further information and advice regarding your rights or to submit a complaint, you can contact the Personal Data Protection Authority: Postal Address: Personal Data Protection Authority, Offices: Kifisias Avenue 1-3, P.C.
   115 23, Athens.
   Telephone Center: +30-210 6475600
   Fax: +30-210 6475628
   Email: contact@dpa.gr
10. Revisions to this Notice Our aim is to continually review and update this Notice in order to comply with Personal Data legislation and new developments. Any update to this Notice will be posted on the Website and will be effective from the date of its posting. We encourage you to read this Policy periodically to be aware of how your Data is protected.