Privacy and Personal Data Protection Policy

1. Who is responsible for your data – Where do you go to exercise your rights?

1.1. The person responsible for processing your data is "IBS INFORMATION SYSTEMS LTD", based at Notara 108, Piraeus, and legally represented, with telephone center 2104224242 and contact e-mail [email protected] ("The company").

1.2. The above Responsible Processing Company has appointed a Personal Data Protection Officer by e-mail contact the [email protected]. You can address all requests to exercise your rights below (under 3.1-3.7.) to the Data Protection Officer's email address.

2. General principles of the Company regarding transparent information.

2.1. Any information we give you in this document as well as any information you may request in the future is provided free of charge, provided that the request is not repeated, exaggerated or manifestly unjustified (see more in 2.3.)

2.2. For each of the above rights exercised by the Company will respond to you within one (1) month of receipt of the request or in case of objective difficulty, complexity of the request or the number of requests, the Company will respond to a maximum period three (3) months regarding either the termination of your application or the justified refusal to execute what you requested for legal reasons that are explicitly specified in General Regulation 679/2016.

2.3. In the event that the Company deems that any of the above rights are exercised manifestly unfounded or the request is excessive or (much more) has a recurring nature, it is entitled on the one hand to impose your charge with a reasonable fee on the provision of further information (which is in principle free of charge) and on the other hand to refuse to comply with the request.

2.4. In the event that the Company has reasonable doubts about your identity when you request the exercise of any of the above rights, it may request the provision of additional information necessary to confirm your identity before processing the request.

2.5. In the event that the Company delays beyond the justified period to respond to your request as well as in any case where you consider that your rights are violated or the Company is not consistent with its obligations to keep your data, you have the right to file a complaint with the supervisory authority. (Personal Data Authority, Athens Kifisias 1-3, P.O. 115 23, Athens, [email protected], +30-210 6475600.)

2.6. You reserve the right to withdraw your consent (if any) provided at any time by submitting a relevant document of your request to the e-mail address of the Personal Data Protection Officer [email protected]. (see 1.2.)

3. What are your Rights in relation to the Personal Data you have provided to us?

3.1. Right to Information
You reserve the right to request information about the personal data we received from you and keep for one or more purposes as described below under paragraphs 5.1 and 5.2. This text as a whole is a manual of basic information and understanding of the philosophy of the regulatory framework that governs the protection of your personal data. Updates, deepening and clarifications in this text can be given to you after submitting a relevant request to exercise the right to information. (see how in 1.2)

3.2. Right of Access
You reserve the right to request from our Company access to your information which we maintain and confirmation in relation to whether they are processed and more specifically information about the purposes of processing, the categories of personal data, the recipients or the categories of recipients, the time retention and processing, the existence of a right of complaint to the Personal Data Protection Authority, any available information on the origin of the data when it has not been made available by you, the existence or non-automated decision-making including profiling and related methodology, guarantees regarding the policy we follow when the transfer takes place in third countries, a copy of the personal data that is kept and processed. (see how in 1.2.)

3.3. Right of Correction
You reserve the right to request from our Company correction of your data in case any of the items for which we have the right to edit has changed or has been entered incorrectly. (see how in 1.2.)

3.4. Right of Deletion
You reserve the right to request from our Company the complete or partial deletion of your data in which we have the right to keep and process either because they are no longer necessary for the fulfillment of the purposes for which they were collected, or because you withdraw your consent, or because data was collected for a purpose you deem illegal. Our Company, in a reasonable time (not more than one month and under conditions if there is a difficulty of not more than three months in total) will respond by confirming the total or partial deletion of your data or the inability to delete specific data if a law or the performance of a duty in the public interest, whether the right to freedom of expression and information or the exercise or support of a legal claim requires that they be maintained. In this case, on the one hand, you have the possibility to complain to the supervisory authority, and on the other hand, to file a court appeal. (see how in 1.2.)

3.5. Right of Restriction
You reserve the right to request from our Company a restriction on the processing of your data, quantitatively, temporally or in relation to the purpose of their processing and more specifically (a) either because you question the accuracy of your data and for how long the Company needs to confirm their accuracy, (b) either because you consider the processing illegal but instead of deletion you choose restriction (c) or because their use is no longer necessary by the Company but you do not want to delete them as their retention will serve you for some court claim, (d) or in the event that you have objections regarding the processing of the data and until it is verified whether your rights as a Subject prevail over the legal reasons for processing the Company. (see how in 1.2.)

3.6. Right to Portability
You reserve the right to receive the personal data you have provided to us in a structured commonly used and machine-readable format as well as the right to transmit it further without objection, as your data is processed on the basis of consent. In the context of the exercise of this right, you also have the opportunity to request immediate transfer from the Company to the third party without your mediation. This right is exercised without prejudice to the restrictions of the right of deletion (see above under 3.4.) And its exercise may not adversely affect the rights and freedoms of others. (see how in 1.2.)

3.7. Right of Objection
3.7.1. You reserve the right to object to the use of your personal data for the purpose of direct marketing and in particular the creation of a profile related to this direct marketing. (see how in 1.2.)
3.7.2. There is no relevant right in the case of Employees/Employee Candidates and visitors to the company's facilities as this data is not transmitted to the Marketing department and is not treated as such.

4. Can your data be promoted elsewhere?

Your data is not intended to be the object of transmission to any organization outside the Company and its subsidiaries with the exception of (a) our Company's electronic systems and network support service providers – and for the sole purpose of their performance of the contract to support our Company and (b) the competent tax authorities in the context of our mandatory compliance with tax legislation and to the extent (and under the condition) that this is required.

5. Guarantees

We assure you that the Company will exhaust every technical and organizational Data protection measure and will only make the optimal, minimal and absolutely necessary use and processing of the Data as defined by law and strictly and exclusively for the purpose for which you have made it available to us. Special provisions for the individual categories of Personal Data Subjects that coincide cumulatively with the above general provisions of the Policy.


5.1.1. Purpose: The reception, processing and preservation of your data provided exclusively in the context of communication is done to satisfy the exclusive purpose of informing you about the Company's products and actions. All your data is kept only for this purpose and is processed only by the Company's marketing department.

5.1.2. Legal basis of processing: The legal basis for the processing of your data is your consent to it in order to fulfill the above-mentioned purposes, according to article 6 par. 1 point a of the Regulation on the protection of personal data.

5.1.3. Data Retention Time: For the fulfillment of the above purpose of processing, i.e. informing you about our products and actions, we consider a reasonable and necessary time to retain your relevant data for a period of three (3) years. After the expiration of three years from the time of obtaining your consent, the relevant data will be deleted unless you provide a new consent under the above conditions.


5.2.1. Purpose – Legal Basis: during the pre-contractual stage and especially in the case of filling out an electronic contact form on our website or directly sending an email or telephone communication or filling in a printed form, (when you provide us with your name/e-mail address and/or telephone and/or address and/or property and/or our products that interest you), the purpose is to investigate the possibility of a transaction with the Company and the legal basis is to serve the legitimate interest of the Company to pursue its commercial purposes by responding to the requested communication to investigate the possibility of doing business with you. In the event that a transaction takes place with the Company, your Data that you have provided us pre-contractually (as well as what you will provide us in the context of our transaction) will be processed for the purpose of implementing the contract between us and our compliance with tax legislation. In this case, the legal basis for the processing is the execution of the contract between us as well as our compliance with the legislation (Article 6 par. 1b and 1c of the Regulation on Personal Data Protection.

5.2.2. Data Retention Time:
We will maintain the above under par. data for five (5) years and then we will delete it. Regarding the above under par. data will be kept for as long as necessary by tax legislation.

5.2.3. Especially for the personal data of the subjects we receive during trade shows, the Privacy Policy applies, which is an integral part of the "Attendee Form" that interested parties are asked to fill out.


5.3.1. Purpose: The reception, processing and storage of your data concerning the determination of your identity and the time of your stay in the company's premises is done for the satisfaction of the exclusive purpose of the safety and protection of both the persons who are in the company's premises (e.g. employees, visitors) and the company's equipment in general (indicative of building, electronic, etc.).

5.3.2. Legitimate Processing Base: The legal basis for the processing of your data is your consent to it in order to fulfill the above-mentioned purpose, according to article 6 par. 1 item a of the Regulation on the protection of personal data.

5.3.3. Data Retention Time: In order to fulfill the processing purpose related to the safety and protection of both the persons on the company's premises (e.g. employees, visitors) and the company's equipment in general (indicative of building, electronic, etc.), we consider a reasonable and necessary period of time for keeping your relevant data to be fifteen (15) days. After fifteen (15) days have passed from the time you entered the company's facilities, the relevant file with all your information will be deleted.

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