We are very pleased about your interest in our company. Data protection is of a particularly high priority for the management of XANTHIS S.A. The use of the Internet pages of XANTHIS S.A. is generally possible without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website, processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to XANTHIS S.A.By means of this privacy policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights under this privacy policy.
As the controller responsible for the processing, XANTHIS S.A. has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, such as by telephone.
1. Definitions
The privacy policy of XANTHIS S.A. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for both the public and our customers and business partners. To ensure this, we would like to first explain the terminology used.
We use the following terms, among others, in this privacy policy:
a) Personal Data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, particularly 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.
b) Data Subject
Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing is 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
d) Restriction of Processing
Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future.
e) Profiling
Profiling means 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, particularly to analyze or predict aspects concerning the natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
f) Pseudonymization
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or Controller Responsible for the Processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third Party
Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent
Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the Controller
The controller, within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union, and other provisions related to data protection, is:
XANTHIS SA
Polydefkous 57-59
185 45 Piraeus
Greece
Tel.: +30 210 4110306
Email: xsa@xanthis.gr
Website: https://xanthis.gr/
3. Collection of General Data and Information
The website of XANTHIS S.A. collects a series of general data and information each time a data subject or an automated system accesses the website. This general data and information are stored in the server’s log files. Collected data may include:
- Browser types and versions used,
- The operating system used by the accessing system,
- The website from which an accessing system reaches our website (referrer),
- The sub-websites that are accessed via a system on our website,
- The date and time of access to the website,
- An Internet Protocol address (IP address),
- The Internet service provider of the accessing system, and
- Any other similar data and information that may be used in the event of attacks on our IT systems.
When using this general data and information, XANTHIS S.A. does not draw any conclusions about the data subject. Instead, this information is required to (1) deliver the content of our website correctly, (2) optimize the content and advertising of our website, (3) ensure the long-term operability of our IT systems and website technology, and (4) provide law enforcement authorities with necessary information in case of a cyberattack. The anonymous data in the server log files are stored separately from all personal data provided by a data subject.
4. Routine Erasure and Blocking of Personal Data
The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or as provided by the European legislator or another competent legislator in laws or regulations to which the controller is subject.
If the storage purpose ceases to apply or if a retention period prescribed by the European legislator or another competent legislator expires, personal data are routinely blocked or erased in accordance with legal requirements.
5. Rights of the Data Subject
a) Right of Confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to exercise this right of confirmation, they may contact any employee of the controller at any time.
b) Right of Access
Every data subject has the right granted by the European legislator to obtain from the controller free information about their personal data stored at any time and a copy of this information. Additionally, the European legislator has granted data subjects access to the following information:
- The purposes of the processing
- The categories of personal data concerned
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly recipients in third countries or international organizations
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- The existence of the right to request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
- The existence of the right to lodge a complaint with a supervisory authority
- Where the personal data are not collected from the data subject, any available information as to their source
- The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for the data subject
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or an international organization. If this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, they may contact any employee of the controller at any time.
c) Right to Rectification
Every data subject has the right granted by the European legislator to request the rectification of inaccurate personal data concerning them without undue delay. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of a supplementary statement.
d) Right to Erasure (Right to be Forgotten)
Every data subject has the right granted by the European legislator to request the controller to erase personal data concerning them without undue delay, and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies and provided the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies and a data subject wishes to request the erasure of personal data stored by XANTHIS S.A., they may contact any employee of the controller. The employee shall ensure that the erasure request is complied with immediately.
Where XANTHIS S.A. has made the personal data public and is obliged pursuant to Article 17(1) of the GDPR to erase the personal data, XANTHIS S.A., taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, insofar as processing is not required.
e) Right to Restriction of Processing
Every data subject has the right granted by the European legislator to obtain from the controller the restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification of whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met and a data subject wishes to request the restriction of personal data stored by XANTHIS S.A., they may contact any employee of the controller. The employee will arrange the restriction of processing.
f) Right to Data Portability
Every data subject has the right granted by the European legislator to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided, where the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and where it does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may contact any employee of XANTHIS S.A. at any time.
g) Right to Object
Every data subject has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to the processing of personal data concerning them, which is based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.
XANTHIS S.A. shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.
If XANTHIS S.A. processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing. This includes profiling to the extent that it is related to such direct marketing. If the data subject objects to XANTHIS S.A. to the processing for direct marketing purposes, XANTHIS S.A. will no longer process the personal data for these purposes.
Additionally, the data subject has the right to object, on grounds relating to their particular situation, to processing of personal data concerning them which is carried out by XANTHIS S.A. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may directly contact any employee of XANTHIS S.A.
h) Automated Individual Decision-Making, Including Profiling
Every data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) it is based on the data subject’s explicit consent, XANTHIS S.A. shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.
If the data subject wishes to exercise rights concerning automated decision-making, they may contact any employee of XANTHIS S.A..
i) Right to Withdraw Consent
Every data subject has the right granted by the European legislator to withdraw their consent to the processing of their personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, they may contact any employee of XANTHIS S.A. at any time.
6. Legal Basis for Processing
The processing of personal data by XANTHIS S.A. is based on Article 6(1) of the GDPR, which provides the legal basis for processing operations. Specifically:
- Processing is lawful if the data subject has given their consent for one or more specific purposes (Article 6(1)(a)).
- Processing is necessary for the performance of a contract to which the data subject is a party (Article 6(1)(b)).
- Processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6(1)(c)).
- Processing is necessary to protect the vital interests of the data subject or another natural person (Article 6(1)(d)).
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (Article 6(1)(e)).
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, except where overridden by the interests or fundamental rights and freedoms of the data subject (Article 6(1)(f)).
7. Legitimate Interests Pursued by the Controller or a Third Party
If processing is based on Article 6(1)(f) of the GDPR, our legitimate interest is to conduct our business in favor of the well-being of all our employees and shareholders.
8. Duration for which Personal Data Will Be Stored
The criterion used to determine the storage period of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data are routinely deleted, provided they are no longer necessary for contract fulfillment or contract initiation.
9. Legal or Contractual Requirement for the Provision of Personal Data
We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information about the contractual partner). In some cases, it may be necessary for a data subject to provide personal data to conclude a contract, which must then be processed by us.
Before providing personal data, the data subject may contact any employee of XANTHIS S.A., who will clarify whether the provision of personal data is legally or contractually required or necessary for contract conclusion and what consequences the failure to provide the personal data would have.
10. Existence of Automated Decision-Making
As a responsible company, we do not use automated decision-making or profiling.
