TESCO FOOD TECHNOLOGY (TFT) S.A.  hereinafter the “Company” recognizing the great importance of the lawful processing of your data, under any capacity (e.g as a candidate, customer, consumer, website visitor, employee, supplier, tradesman, individual), recommends that you read this Policy carefully in order to understand what the Company does with your personal information. By using our websites, you unconditionally accept the practices described herein, the terms of which govern the contractual relationship between us and are incorporated into the terms of use of each of our services.

1. What are personal data

Your personal data includes any information on paper or electronic media, which may lead, either directly or in combination with others, to your unique identification or identification as a natural person. This category includes, as the case may be, information such as your name, VAT number, social security registration number, your physical and electronic addresses, your landline and mobile phone numbers, recipients of SMS / MMS messages, your bank / debit / prepaid card details, your email addresses, your equipment or terminal IDs, computer, smartphone, tablet, web browsing history (log files, cookies, etc.), and any other information that allows your unique identification according to the provisions of the General Data Protection Regulation (GDPR 2016/679), the current Greek legislation, as well as the Decisions of the competent Personal Data Authority.

2. What personal data we collect

We process your personal data in accordance with the law, when you contact us and / or buy our products and services directly and/or online, when you call us in order to receive information, value-added services aimed towards the Consumer (B2C) or third-party services (B2B), or to receive other services, information, entertainment, e-government, mobile marketing and information or services related to any other activity of the company.

3. Legal processing

The Company will use your information for the following lawful processing purposes (under Article 6 of the GDPR), as the case may be, either under your express consent that you are free to revoke at any time, or for the performance of a contract or pre-contractual relationship with you, or to serve our legal interest or to defend your vital interests, namely:

• To search for information aimed at completing your requests, purchases and orders.
• To answer your requests and questions about our products / services as well as to provide information and respond to your suggestions and comments on improving our products and services.
• To announce the results of surveys and/or competitions in which you may have participated.
• To analyze our website traffic, improve your experience and to provide you with information related to products, services, special offers and promotions.
• For our internal operations and analysis such as internal management, fraud prevention, facilitation of accounting, billing and control information systems.

You can change your preferences at any time using the unsubscribe link at the end of each email you receive from us (unsubscribe).

4. What are the principles of collection and processing

This Privacy Policy is intended to inform you of the terms of collection, processing and transmission of your personal data that we may collect as Controllers of your data. The Company and its trained staff apply all processing principles of Regulation 2016/679 (legality, objectivity, transparency, purpose limitation, data minimization, accuracy, limitation of storage time, integrity, confidentiality and accountability). The Company protects and secures your Rights regarding the use of your Personal Data (information, access, correction, deletion, restriction of processing, portability, opposition and non-automated decision-making based on profile, as specified in Greek law). The above applies to all services provided either by us or our affiliate companies.

5. What are the ways of collecting your personal data

The Company collects your personal data by accepting the terms of use of each of our services, such as:

• when you call our numbers or our short codes, when you send us an email, or fill out an application or order.
• when contacting our offices or our customer service staff, and our call center, either for purchases or to express your opinion, complaints, or comments.
• when you send us the postal address of issue or dispatch of invoice or receipt of services as well as home delivery details of your order.
• when you purchase a product and / or service, in order to verify your age and credentials to determine if you are legally permitted to enter into a valid contract with us.
• when you voluntarily subscribe to our printed or online catalogs, in order to receive information or other marketing material or to renew your preferences or to participate in contests, questionnaires and surveys.
• when you visit our websites through which we collect, with your explicit consent, via cookies information from your terminal device, such as your Internet Protocol (IP) address, the operating system you use, the type and version of your browser (browser) etc.
• when we receive documents, requests, orders, petitions, warrants, etc. by third parties, such as supervisory, prosecutorial, judicial, tax authorities, to investigate crimes and protect you against fraud or any form of crime and to prevent the infringement of legal property (e.g intellectual property rights, software).

6. Minimize, save and delete your data

The Company will always ask you for the minimum required by law personal data to connect to our online platforms and services, to purchase products / services, to communicate through websites with other users or to participate in competitions and promotions. Our Company keeps your personal data only for as long as required by the contractual terms of each service, in combination with the current legislation, based on the respective purpose of processing, while then anonymizing or destroying them. You can ask us and find out what data we collect about you and correct or delete it by completing a relevant application that we have available, unless required to be retained by law for tax, evidentiary or judicial purposes and to prosecute crime.

7. Your lawful rights as a Data Subject

• Request access to your Personal Data.The right to access, update or delete your Personal Data. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• Correction of DataYou have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your Personal Data.This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object in case we are processing your Personal Data for direct marketing purposes.
• Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data in case:

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) You withdraw the consent on which the processing is based, and there is no other legal ground for the processing; (c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing; (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with an EU legal obligation or under Member State law to which the controller is subject; (f) the personal data have been collected in relation to the offer of information services.

• Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain functionalities or services.

8. Non-recognition:

In some cases, we may not be able to retrieve your personal information because of a lack in identification information you provide in your application. In such cases, where we cannot identify you as the data subject, we are unable to comply with your request to enforce your legal rights, unless you provide us with additional information that allows your identification.

9. Restriction of access:

In some cases, we may not be able to provide access to all or some of your personal data under the provisions of applicable law. If we refuse your request for access, we will notify you of the reason for that refusal.

10. Cookies

According to the European Directive 2009/136 our website accepts the use of “cookies”. These are online tools for collecting and analyzing information from social networking platforms or third-party websites, in order to measure traffic, improve the functionality, content and overall appearance of our website and adapt to the needs of our customers. When using our website, your personal data is being processed by third parties, such as social networks and search engines, e.g. Google Analytics, Facebook social plug-ins, etc, without any involvement, influence or control of our Company and are transmitted either inside or outside the European Economic Area (27 EU Member States plus Iceland, Liechtenstein and Norway), for which these third parties are solely responsible. If you do not wish third parties, such as Google, Facebook, Twitter, to receive information from your browser when you visit the Company’s websites, you can opt out of the terms provided by the respective User Policy on the website of any such third party. Although most browsers automatically accept the use of cookies, you can always change the settings on your computer by choosing not to accept cookies, or you may be asked to accept each one individually. However, you should be aware that this will limit the range of browsing capabilities available to you on any website and user experience.

11. Transfer of your data to third parties

As a rule, our Company does not transmit your personal data to third parties, except when we act as intermediaries and to the extent that it is required to complete your order and fulfill requests regarding the services provided by us. Such third parties may be official state and supervisory bodies, when we are called upon to comply with the law and prevent illegal actions against us and our customers (eg telecommunications fraud, defamation, insult of personality, etc.). Third parties may also be telecommunication companies, television stations, cloud providers, professional associations, audiovisual content providers, reservation systems and other global distribution systems. In our Company we select reliable providers and we try to set contractual restrictions on any third party, which might receive your personal data based on your choices, in order to ensure their lawful use. However, we cannot guarantee their compliance with data protection regulations. For this reason, we encourage you to carefully review the privacy practices of any third-party providers whose products or services you purchase through our websites. In order to process your data, we may need to transfer your information to other countries, including countries primarily within the European Economic Area (EEA) and exceptionally outside the EEA, solely based on EU adequacy decisions, corporate binding rules, standard contracts and approved codes of conduct.

12. Security of your personal data

We take all the appropriate technical and organizational measures to ensure the confidentiality, integrity and availability of your data. Our goal is to ensure that your personal information is transferred, stored and processed in accordance with appropriate international security standards and procedures. Our Company recognizes the importance of protecting privacy and all your personal information and for that reason has adequately trained its personnel and operates along the guidelines of a competent Data Protection Officer. Furthermore, we have established appropriate security policies and use the appropriate technical and operational tools, such as anonymization, pseudonymization, data encryption, tokenization, use of firewalls, establishment of access levels, authorized employees, staff training, periodic audits, security and business continuity standards. Any of our partners who has access to the above personal information, uses it to serve exclusively the above purposes. We share the information you provide to us exclusively in the ways described in this Policy and in accordance with your express and specific consent per type of processing which you can at any time and freely revoke by contacting us.

13. View targeted ads

In case you have given us your written consent we may use your personal data along with other information we have collected, after human intervention by our competent department, to display ads related to your obvious preferences on our website or on another website. However, we do not use automated tools to track and evaluate your consumer profile and your general preferences with other personal information (such as your email address) to display ads or send you personalized offers. In addition, we do not share your personal information with third parties, so that they may send you relevant ads, unless you have expressly consented in writing to them. If you would like us to stop sending you updates or offers, you can use the unsubscribe link at the end of any unsubscribe email you may have received from us.

14. Links to third party websites

Our Company websites may contain links that lead to other websites of third parties, independent entities, such as telecommunications companies, content providers, entertainment producers, professionals, transportation service providers, payment service providers, etc. which are operated and maintained exclusively by them, and which we do not control. Therefore, we maintain absolutely no responsibility for the content, actions or policies of these websites. We suggest you read carefully the respective data protection policies on the websites you visit, as they may differ significantly from ours.

15. Unsolicited commercial communication

The Company does not allow the use of our website or our services for the transmission of bulk or unsolicited commercial e-mails (spam). Also, we do not allow the sending of messages to and from our customers which use or contain invalid or falsified headings, invalid or non-existent domain names, techniques of hiding the origin of each message, false or misleading information or violate the terms of use of websites. We do not in any way allow the collection of e-mail addresses or general information of our customers and subscribers, through our website or our services. We do not authorize or authorize any attempt to use our services in a way that could harm, disable, encumber any part of our services or prevent anyone wishing to use our services lawfully. If we consider that any unauthorized or inappropriate use is made on any of our services, we may, without notice, in our sole discretion, take all appropriate steps to block messages from a specific web space (domain). We maintain all rights to immediately delete any account that uses our services, which, in our sole discretion, transmits or is associated with the transmission of any messages that violate this Policy.

16. Communication for questions or comments

If you have any questions or comments regarding this Privacy Policy or if you feel that we have not followed the principles set out in it, please email us at dpo@inergion.com or contact us at our Offices in Paradisou 10 str. Maroussi, Attica, 15125.

17. Applicable Law

Applicable law is the Greek Law, as formulated in accordance with the General Data Protection Regulation (2016/679/EU) and the current national and European legislative and regulatory framework for the protection of personal data. The competent courts for any disputes arising related to your Data are the competent Courts of Athens.

18. Right of Complaint

In case you consider that your Personal Data have been violated, you have the right to submit a formal complaint to the Personal Data Protection Authority (1-3 Kifissias, 11523, Athens, tel. 210.6475600, contact@dpa.gr).

19. Validity of Security Policy and Personal Data Protection

This Policy was published by the Company on 18/11/2021 and is subject to periodic improvement and revision.