The management and protection of the personal data of the users of the website are governed by the provisions of the current legislation regarding the protection of personal data, decisions of the competent authority, and these terms.
Our company considers the lawful processing, security, and protection of your personal data to be of utmost importance, regardless of how you communicate or collaborate with us, such as potential or active customers, representatives and legal representatives of companies, website visitors, employees, suppliers, external partners of the company. The company provides telephone directory services for its customers and possesses the necessary knowledge, experience, and personnel for this purpose. You can contact the company at the email address hello@sunpages.comwith the website: www.sunpages.com.
Please read these terms and conditions carefully. By using our website, you unconditionally accept the practices described herein, the terms of which govern our contractual relationship and are incorporated into the terms of use of our services.
1. What are your personal data?
Your personal data includes any information in printed or electronic form, which can lead, either directly or in combination with other information, to your unique identification or the ability to identify you as an individual. This category includes, depending on the case, information such as name, identity number, Tax Identification Number (TIN), your physical and electronic address, phone numbers, IP, cookies, and any other information that allows your unique identification, in accordance with the provisions of the General Data Protection Regulation 2016/679 (“GDPR”), Law 4624/2019, applicable Greek and European legislation, and decisions of the Personal Data Protection Authority.
2. What is the processing of personal data?
Any action or series of actions performed, with or without the use of automated means, on personal data or sets of personal data, such as collection, registration, organization, structuring, storage, adaptation or modification, retrieval, search for information, use, disclosure by transmission, dissemination or other provision, alignment or combination, restriction, erasure, or destruction.
3. What personal data do we collect?
We process the personal data you provide when you fill out applications and expressions of interest for our services, when you contact us with inquiries about the services we provide, when you browse our website, and when you sign a contract with our company and use our services, either yourself or on behalf of legal or natural persons you lawfully represent. The data we collect include, but are not limited to: a) Basic personal data: Name, surname, father’s name, other identity details b) Contact details: Residential address, work address, contact phone numbers (work, mobile), email addresses, etc. c) Professional profile: Status, profession, position in the company, responsibilities, etc. d) Financial data: Tax Identification Number, bank account, IBAN, debts to the company, payments, etc.
4. Legal Processing
The company will use your information for the following legal and specific processing purposes (according to the relevant articles of the GDPR), depending on the case, with your explicit consent, which you can revoke freely at any time, or for the execution of a contract or pre-contractual relationship with you, or for the servicing of our legitimate interest or for the protection of your vital interests or the vital interests of our employees and partners, as well as for the servicing of the legitimate interests of our company, namely:
- For employees and job applicants, for the conclusion and execution of the employment contract, for compliance with labor, social security, and tax legislation in general,
- Regarding customers, prospective customers, their partners, and their legal representatives:
- For the preparation and execution of the contract the company enters into with its customers and suppliers, to provide services
- For the servicing, support, and monitoring of your contractual relationships with the company and the proper execution of our contract
- For the pricing of the company’s services
- For the company’s compliance with tax and insurance obligations
- For the company’s compliance with the applicable legal and regulatory framework
- To safeguard the company’s legal interests,
- To safeguard the vital interests of employees and the assets of the company,
- For the provision of services to our customers
- To manage your inquiries about our services, fulfill your requests, and improve our services,
- For communication and information purposes, such as sending emails, SMS, or newsletters related to the company’s activities and services that may interest you, provided you have given your consent (Opt-in). You may withdraw your consent (Opt-out) at any time.
- For the promotion of the company’s services on social media and professional networking pages we manage, provided you have explicitly consented to this
- For our internal operations and analyses, such as internal management, fraud prevention, the use of management systems, billing, accounting, invoicing, and information control systems, as well as compliance with tax regulations. For external partners and suppliers:
- For the preparation and execution of contracts that the company enters into with them for the purchase of products or the provision of services
- For compliance with tax legislation
- For necessary communication, either at a pre-contractual stage or during contract execution For website visitors:
- For the purposes of electronic communication and service through the website, as outlined in the website’s terms of use, which you can view here: sunpages.com/oroi-chrisis/ In every case, you can change your preferences at any time by sending an email to hello@sunpages.com.
5. What are the principles of collection and processing?
This privacy and personal data protection policy aims to inform you about the terms of the collection, processing, and transmission of your personal data, which we may collect as the Data Controller or while processing personal data. The company and its trained personnel comply with the ten principles of processing under GDPR 2016/679 (lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability). The company protects and ensures your eight rights regarding the use of your personal data (information, access, rectification, deletion, restriction of processing, notification, data portability, objection, and non-automated decision-making based on profiling, as defined by Greek law). These apply without discrimination and are implemented in all processes we carry out and all services we provide.
6. What are the ways we collect your personal data?
The company collects your personal data by accepting the terms of use for each of our services, such as:
- When you call our numbers, send us an email, or fill out an application for us to provide our services to you or your partners.
- When you draw up and sign a contract with us for the provision of our services to you, in which case you voluntarily provide us with your personal data and the personal data of your partners or legal representatives, employees, partners, or suppliers.
- When you contact our offices or customer service staff or call center, either for service provision or to express your opinion, complaints, or comments.
- When you send us your postal address and other details for issuing or sending an invoice or receipt for services rendered.
- When you voluntarily sign up for a form or electronic document to receive printed, electronic, SMS, email, or newsletter information or other material.
- When you visit our website, through which we collect, with your explicit consent, via cookies, information from your terminal device, such as your IP address, address, operating system, browser type and version, etc.
- When we receive your CV with your consent
- When we receive documents, requests, orders, applications, warrants, etc., from third parties, such as supervisory, prosecutorial, judicial, or tax authorities.
7. Minimization, storage, and deletion of your data
The company will always request the minimum personal data required by law in order to provide our services and enable communication with us.
Our company keeps your personal data only for as long as required by law or the contractual terms of each service, in combination with the relevant regulations regarding social security, taxation, labor law, and general legislation, based on the specific purpose of processing. After this period, the data is anonymized or destroyed. Employee personal data is retained for at least five (5) years from the end of the year in which the employee left the company in any way. After this period, and provided the relevant legislation allows it (tax, etc.), such personal data will be destroyed if kept in paper form, or deleted or anonymized if kept electronically.
Videos and recordings in audiovisual material as part of the provision of our services that constitute personal data (visual image, voice sound, movements, etc.) are kept for a period of three (3) months from their reception.
You can ask us to find out what data we collect about you and correct or delete it by completing a relevant application we provide, unless their retention is required by law for tax, social security, investigative, or judicial purposes, or for the prosecution of illegal acts.
8. Cookie Policy on our website
In accordance with European Directive 2009/136/EC on the protection of personal data (which has been replaced by the regulation for the protection of privacy in electronic communications) and the guidelines of the Personal Data Protection Authority, our website www.sunpages.com accepts the use of “cookies.” These are online tools for collecting and analyzing information from social media platforms or third-party partner websites to measure traffic, improve functionality, content, and the overall appearance of our website, and tailor it to the needs of our customers. Cookies are classified into four categories:
- Necessary cookies (first-party) that need to be activated during browsing for the website to function properly. These necessary cookies are on the whitelist and exempted from GDPR consent.
- Preference cookies that remember user choices, such as language, currency, or color settings.
- Statistics cookies from third-party services, such as Google Analytics, that track website traffic and statistics.
- Marketing cookies from technology companies or third-party advertisers, aiming to display advertisements to visitors or collect personal data from them for future marketing purposes.
When using our website, your personal data is processed by third parties (“third parties”), such as social networks and search engines (e.g., Google Analytics, Facebook, social plug-ins, Facebook Pixel, etc.), without any involvement, influence, or control by the company, and is transferred either within or outside the European Economic Area (27 EU member states plus Iceland, Liechtenstein, and Norway), for which those third parties are exclusively responsible. If you do not want third parties (such as Google, Facebook, Instagram, etc.) to receive information from your browser when you visit the company’s websites, you can opt out according to the terms provided by the respective Privacy Policy on any such third-party website. Although most browsers automatically accept cookies, you can always change the settings on your computer to refuse cookies or be asked to accept them individually. However, please note that this will limit your browsing capabilities on any website and your user experience.
9. Transfer of your data to third parties
In general, our Company does not transfer your personal data to third parties, except to the extent required to provide our services, fulfill requests for the services we offer, and as required by applicable legal framework. Specifically, only the essential company personnel (employees/partners/associates) for fulfilling the above purpose have access to and the ability to process your personal data and are committed to confidentiality.
Your personal data may be disclosed and transferred to:
- The competent Public Authorities due to the company’s legal obligations (tax authorities, EFKA, etc.) as independent Personal Data Controllers.
- Accountants, computer engineers, IT technicians, suppliers, electronic platforms such as Zoom or Teams, etc., who collaborate with the company under independent service contracts and are jointly responsible for processing personal data, and are committed to maintaining professional confidentiality toward the company’s clients.
10. Security of your personal data
In any case, we take appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of your data. Our goal is to ensure that your personal data is transmitted, stored, and processed in accordance with appropriate international standards and security procedures. We have trained and responsible personnel, and we recognize the importance of protecting your privacy and all your personal data. To this end, we have suitable security policies and use appropriate technical and operational tools, such as anonymization, pseudonymization, data encryption, use of firewalls, establishment of access levels, authorized personnel and partners, staff training, periodic security audits, and compliance with international security standards to protect personal data from unauthorized or unlawful processing, accidental destruction, damage, or loss.
Any of our partners who have access to the above information and your personal data, as data processors, use it exclusively for the above purposes. We share the information you provide us exclusively in the ways described in this policy and in accordance with your explicit and specific consent for each type of processing, which you may revoke at any time by contacting us.
11. How do we ensure that personal data processors respect your personal data and the personal data of your partners, associates, etc.?
Personal data processors on behalf of the company have agreed in writing and are contractually bound:
- To maintain confidentiality and are bound to the corresponding obligations toward their staff, in the case of external collaborators.
- Not to transfer personal data to third parties without our written consent.
- To take organizational and technical security measures to protect the data.
- To inform us of any incident involving the breach of your personal data.
- To delete and/or return your personal data after the expiration of our contract.
- To comply with the legal framework for personal data protection, especially the General Data Protection Regulation (GDPR) and relevant legislation in general, as well as decisions of the Personal Data Protection Authority.
12. Display of targeted advertisements
After obtaining your written consent, we may use your personal data along with other data we have collected, after human intervention from our marketing department, to display ads related to your apparent preferences on our website or any other website.
However, we do not use automated tools to track and assess your consumer profile and general preferences with other personal data (such as your email address) for the display of ads or sending personalized offers unless you have accepted cookies for marketing purposes. Additionally, we do not share your personal data with third parties for the purpose of sending related advertisements unless you have explicitly and in writing consented to it. If you wish to stop receiving updates, emails, or newsletters from us, you can use the unsubscribe link at the end of any email or newsletter you may have received from us.
13. Links to third-party websites
Our company’s website contains links to other third-party websites, independent entities, which are operated and maintained exclusively by them and are not under our control. Therefore, we have no responsibility for the content, actions, or policies of these websites. Please carefully read the respective data protection policies on the websites you visit, as they may differ significantly from ours.
14. Unsolicited commercial communication
Our company does not allow the use of our services or website for sending bulk or unsolicited commercial emails (spam). We also do not allow sending emails to/from our clients that use or contain invalid or forged headers, invalid or nonexistent domain names, techniques for hiding the origin of any message, false or misleading information, or violate the terms of use of the websites. We do not allow or approve any attempt to use our services in a way that could harm, disable, overload any part of our services or prevent anyone from legally using our services.
In relation to our website www.sunpages.com and the email address hello@sunpages.com, if we believe there is unauthorized or inappropriate data usage in any of our services, we may, without prior notice, at our sole discretion, take appropriate actions to block messages from specific internet domains, email servers, or IP addresses. We also have the right to immediately delete any account that uses our services and transmits or is associated with transmitting messages that violate this policy.
15. Rights of Data Subjects and Contact for Questions or Comments
Under personal data protection law and the GDPR, you have the following rights:
● Right to information and access to your data: The right to know whether your data is being processed, how, and for what purpose.
● Right to rectify your data: The right to request the correction of inaccurate or incomplete personal data.
● Right to erase your data (“right to be forgotten”): The right to request the deletion or removal of personal data, under certain conditions.
● Right to restrict the processing of your data: The right to request the restriction of processing of your personal data when certain conditions are met.
● Right to data portability: The right to request the transfer of your data to a third party.
Requests to exercise these rights, as well as questions or comments regarding this Privacy Policy, or if you believe we have not adhered to the principles outlined in it, can be submitted electronically to the Data Protection and Security Officer of our company, Thomas Soldatos, at the following email: thomas@sunpages.com, with the subject: “Data Protection Officer.” In the case of exercising any of the above rights, our company will respond within (1) month from receiving your request, although this period may be extended for (2) months depending on the complexity of the request and the number of requests.
Finally, you have the right to file a complaint with the Personal Data Protection Authority (www.dpa.gr) 1-3 Kifisias Avenue, 115 23 Athens, +30 210 6475600, email contact@dpa.gr, if you believe that the processing of your personal data violates the applicable national and regulatory data protection legislation.
16. Applicable Law for Processing Your Data
The applicable law is Greek law, as formed under the General Data Protection Regulation (GDPR) 2016/679/EU, and generally the applicable national and European legislative and regulatory framework for personal data protection. The courts of Athens, Greece, are the exclusive competent courts for any disputes arising from the processing of your personal data.
17. Validity of the Privacy and Data Protection Policy
This Policy was published by the company on 18/12/2024 and is subject to periodic improvement and review.
Our company reserves the right to change or modify the Privacy Policy at any time without notifying users. Such changes, modifications, additions, or deletions will take effect immediately upon posting. Any use of the website after such changes or modifications will be considered as acceptance of the changes, modifications, additions, or deletions by the user.
