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I. INTRODUCTION

Our company, under the tradename “LEFCOMETAL COMMERCIAL SOCIÉTÉ ANONYME” (hereinafter referred to as the “Company”), is engaged in the business of manufacturing and trading of tinplate products.

The present statement is addressed to natural persons (employees/ partners/ customers/ suppliers, hereinafter collectively referred to as “Data Subjects”), the personal data of whom the Company, in its capacity as Data Controller, processes (i.e. collects, transmits and stores - hereinafter referred to as the “Processing”).

“Personal Data” means any information that can be used to identify, directly or indirectly, the identity of a natural person, in particular by reference to an identifier, such as a name, an identification number (hereinafter referred to as “Personal Data”).

Such data are disclosed to the Company either within the context of its production activities or for the purposes of its employment/ professional relationships with its employees (e.g. contracts with employees of the Company), in accordance with the General Regulation (EU) 2016/679 “On the protection of individuals with regard to the processing of personal data and on the free movement of such data” (hereinafter referred to as the "Regulation") and the applicable labor and social security legislation, as may be applicable.

As far as the Company concerns, ensuring the implementation of all rules related to the Protection of Personal Data of Individuals constitutes a priority issue, and the Processing of Individual’s Personal Data is taken place in a fair and legitimate manner for specific, explicit and lawful purposes. The Company's policy is to collect only the Personal Data of Individuals, which are provided either due to legal and regulatory requirements and/or freely by any Data Subject. The data Processed by the Company are limited to what is necessary, are accurate and kept up to date whenever required. Within this framework, the Company has implemented all appropriate legal, organizational and technical measures to protect the Personal Data of Individuals from loss, misuse, alteration, unauthorized disclosure or access, or unauthorized processing and use, including securing your consent to the processing of the Personal Data of Individuals under this Privacy and Personal Data Statement (hereinafter referred to as “Privacy Statement”).

ΙΙ. PARTICULARLY ON THE PROCESSING OF PERSONAL DATA

1. Personal Data Collection and Use 

The Company generally collects only those Personal Data that are necessary for its operation in accordance with the existing legal requirements for personnel, recruitment, and payroll matters, and for its commercial transactions with natural persons (customers or suppliers). Within this context, the Personal Data processed by the Company are submitted to it voluntarily and with data subject’s explicit consent, except as otherwise required or permitted by law. In more particular, by execution of the relevant employment or work contract or services agreement with the Company, they expressly and unconditionally recognize and accept the right of the Company to process their Personal Data for labor-related and professional purposes and always in accordance with the relevant legal regime and the present Privacy Statement.

The Company declares that no Personal Data held by it will be given to a third party/ organization without the relevant legal obligation or without the written consent of the Data Subject. The Company also declares that it is taking every possible measure to ensure that there is no breach or loss of the Personal Data it lawfully holds.

The Company understands the importance of protecting your Personal Data, but if it is required by the nature of its activities to collect and manage Personal Data of Individuals, it ensures in every way that there will be no transmission of such data to any third parties without the written consent of the Data Subjects and, as noted above, takes every possible measure to prevent any breach or loss of such legally held Personal Data. Where additional, optional information is sought, the Data Subject is informed at the time of the data collection.

The Company collects “sensitive” Personal Data only when these individuals freely submit them or when such data are required or when their collection is required/ permitted by law. The Company kindly asks any natural person with an employment relationship or an individual conducting business with the Company to not provide sensitive data to the Company, unless strictly required for legitimate business purposes.

 

2. Rights of Data Subjects and Personal Data Exercise Method.

Any Data Subject who has provided Personal Data to the Company retains the following rights, arising from the provisions of the Regulation, as well as from the applicable national law. In more particular, Data Subjects have the following rights:

• Right of access to, personal data concerning them, the purposes of the processing, the relevant categories of personal data, the recipients or categories of recipients of personal data, the period for which the personal data are stored, and the right to request copy of their personal data, held by the Company.
• Right to rectification, revise/amend any incorrect personal data and complete any missing information.
• Right to erase (“right to be forgotten”) any of their Personal Data.
• Right to restriction of Processing of their Personal Data.
• Right to submit a written complaint before the competent supervisory authority regarding the protection of their Personal Data, i.e. Personal Data Protection Authority (for more information please visit the website of the Authority at www.dpa.gr).
• Right to judicial remedy if they believe their Personal Data have been infringed.
• Right to withdraw their consent to the Processing of their Personal Data (without retroactive effect),

and in general, to exercise any right, provided for by the legislation on the protection of Personal Data.

Moreover, for any matter relating to the Processing of Personal Data of any Data Subject, associated with the Regulation and the present Privacy Statement, all individuals may contact the Data Controller at 210.4125464 or send a written letter to fax number 210.4134683 or an e-mail to the electronic address   This email address is being protected from spambots. You need JavaScript enabled to view it.

3. Safety and Integrity of Personal Data

The Company applies reasonable policies and technical and organizational security measures, to protect all personal data and information from loss, misuse, alteration or destruction. In addition, it has ensured that access to the Personal Data of its Affiliates or Employees is limited to those who need to be aware of them and strictly within the context of the proper execution and fulfillment of the purpose of their Processing, as disclosed through the present Privacy Statement. Any individuals within the Company who have access to such Personal Data are required to keep them confidential.

Upon receipt of Personal Data, strict security measures and procedures are taken place in order to prevent access to those who have not been expressly authorized to do so. We would like to inform you that it is taken place every reasonable effort in order to keep the Personal Data collected exclusively for the period for which the personal data are processed or until their erase is requested (if this occurs earlier), unless otherwise required by law.

4. Use of Cookies

We would like to inform you that the Company uses "cookies" on its website (www.lefcometal.gr) to improve your online experience. By granting your consent to this Privacy Policy regarding the processing, use and storage of your Personal Data, you acknowledge at the same time you have accepted and have been informed about the use of “cookies”.

Cookies are small text files that are stored in your browser, while browsing the Internet, without harming your computers or files. They are only used for your convenience on specific services of our website (www.lefcometal.gr) and for statistical purposes, in order our Company to determine its popular products and services. You have the option to modify your browser to prevent the use of “cookies”. In case, however, you disable them, and if you choose to delete them, you will not be allowed to take advantage of all the features of our website (www.lefcometal.gr) and/or have no access to them.

Through “cookies”, third-party suppliers may display Company ads on web pages.

 

5. Changes to the present Privacy Statement

This Privacy Statement is subject to frequent reviews and might be amended or revised by the Company at its sole discretion. Any amendments will be recorded as modified or reviewed in the present Privacy Statement. The updated Privacy Statement will be posted on the Company's website (www.lefcometal.gr) and will apply for the Data Subjects and their details starting from such date. Data Subjects are encouraged to periodically review the present Privacy Statement, in order to examine whether there are any amendments to the way the Company manages their Personal Data.

This Privacy Statement was last updated on September 15^th, 2018.