PRIVACY POLICY
Information on the processing of personal data
The Company
The Public Properties Company is a public limited company that aims to exploit, by all appropriate means, the real estate assets under its ownership and management of the assets entrusted to it by the State, according to the statutes governing Legal Persons of Public Law, Legal Persons of Private law belonging to the general public sector, and by other limited liability companies whose share capital belongs directly or indirectly to the Greek State (hereinafter referred to as HPPC or the Company).
HPPC was formed by the merger of the public limited companies: Hellenic Tourist Properties S.A., Olympic Properties S.A., Public Real Estate Company S.A. and Attica Coastal Front S.A.
HPPC activities include:
- Administration/management of public property (tourist facilities, Olympic venues, urban, agricultural and other properties)
- Management of leasing contracts or property concessions
- Operation of tourist business units as subsidiaries (ski centers, marinas, beaches, thermal springs)
- Utilizing private investment for property development through leases awarded in competitive tenders
- Real estate development through co-funded projects
- Short-term rental of facilities and outdoor spaces throughout Greece for the conduct of various kinds of events (exhibitions, concerts, conferences, workshops, receptions, etc.)
- Participations (shareholder participation in corporate development projects, utilization and exploitation of tourist properties)
The priority of HPPC is to manage and develop the properties in its portfolio with modern financial instruments, in accordance with the objectives and priorities of the country’s development policy, contributing to the development of the economy, tourism and local communities. The Company’s intent is to attract private investment and promote synergies between the public and private sectors, with the aim of protecting the environment and cooperating with local communities.
The share capital of HPPC is 100% owned by the Hellenic Corporation of Assets and Participations S.A. (HCAP S.A.) as established under Law 4389/2016.
HPPC operates in the public interest and in accordance with market principles.
Privacy Notice
We would like to assure you that HPPC sets as its primary objective the protection of the personal data of its customers as well as other persons, for example its contractors and their staff. For this reason, we take appropriate measures to protect the personal data we process and to ensure that the processing is always carried out in accordance with the obligations set forth in regulation, both by the business units and third parties who process personal data on its behalf.
Data Protection Officer (DPO)
HPPC, headquartered in Athens (Voulis 7, Postal Code 10562), tax registration number (ΑΦΜ) 094537454, Tel.: (+30) 2103339416, website: https://www.hppc.gr, email: [email protected] and Fax: (+30) 2103339507 hereby informs that for the purpose of exercising its business activities, it collects and processes the personal data of its clients, as well as other persons involved with the Company such as, for example, contractors and their employees, in accordance with national law and European Regulation 2016/679 for the protection of individuals with regard to the processing of their personal data and the transmission of that data (General Data Protection Regulation).
For any matter regarding the processing of personal data, contact the Data Protection Officer (DPO) Ms. Marilena Bellou directly at email: [email protected].
What personal data do we process?
The personal data that you make available to us, for example, your name, address, telephone number, email, as well as various other data, such as information relating to your educational and professional experience for the purpose of filling job vacancies, your tax and social security status, certifications of financial standing for participating in tenders and procurement procedures, are used only when there are legitimate reasons for processing your personal data.
What are the legitimate grounds for processing your personal data?
Legitimate grounds for the processing of your personal data include:
(a) To provide the services you have requested and wish to receive from us. Specifically, in the context of our activities, we promote through our website properties which are available for sale or lease through an online auction conducted through an electronic platform, as well as competitive tenders (specifically for procurement and award of services, tenders for the award of studies and technical works). We also collect and process data you provide to us in order to participate in tenders by the Company or when you register in our online catalogue of vendors e-Katalogos.
(b) Your declaration of consent, in accordance with specific conditions set by regulation, when you request to receive information relating to properties the Company is making available for public tender as well as other information related to our business activities. We assure you that your personal data is processed solely for the purpose for which you provide your consent.
(c) The collection of criminal records, in the context of a tender participation, is undertaken on a case-by-case basis and under special circumstances (e.g. where the applicant is a member of a company’s board of directors and represents the company), while we ensure that adequate safeguards for the protection of your data, your rights and freedoms are provided, as defined under the current legislative framework.
(d) The processing of personal data where necessary to comply with legal obligations of the Company, such as compliance with legislation relating to the conduct of public/private tenders, environmental legislation governing the use of public properties with particular characteristics, as well as compliance with tax legislation.
(e) For the preservation and protection of legitimate interests, primarily of our own and of our business. For example, to ensure the security of natural persons, materials and our facilities, we use security cameras in the public reception areas of the Company and its business units in order to operate a closed circuit television system.
How and why do we use your personal data?
- To offer quality services to our interested customers, for the lawful conduct of public tenders, and to provide the best possible service.
From our contractual relationship and even from pre-contractual activities, we derive and process the information necessary to ensure unimpeded cooperation between us, for example from the personal data you submit to the electronic platform of our website, in order to communicate with you and fulfill your requests. Through our website, and specifically through the contact form and its mandatory fields (name, surname, email), as well as optional fields (telephone, company), you declare your interest in participating in tenders and may pose related questions, which we are obliged to answer in detail. We also use your personal information to register you in the catalogue of vendors and service providers, and we process your personal data in order to provide you with important information about our website and any changes in this privacy statement.
- For presenting and promoting properties through our marketing activities
If you have consented to this, we inform you about the properties we are going to make available for public tender as well as other news relating to our activities. A precondition for receiving such electronic messages is your prior consent.
- To comply with our legal obligations
We are obliged to comply with laws governing public/private tenders, environmental regulations for the management and development of properties with particular characteristics, as well as tax laws, which collectively set the legal and regulatory rules for our operation.
- To safeguard our legitimate interests and protect people and goods
We process the personal data of our customers to optimize our services, for the better operation of our website, and the marketing of properties that are available for sale or lease. Please be advised that the use of closed circuit television and security cameras ensures the security of individuals (i.e. our visitors and staff), as well as the materials and facilities of our Company.
Where is your data shared?
HPPC shares your personal data to the following categories of recipients:
- State authorities, law enforcement bodies
We are obliged to disclose personal data to public bodies (e.g. ministries) where necessary, for example in the course of a public tendering procedure, in the case of a tax audit, to police and/or a judicial authorities in the event of a judicial dispute, state financial authorities for certifying tax status (e.g. arrears under Article 68 para. 2 of Law 4484/2017), and in any case in order to safeguard our business interests and the reputation of our business.
- Business associates of our Company (suppliers, agencies, advertisers etc.)
HPPC maintains partners to whom it entrusts the processing of personal data on its behalf (e.g. equipment suppliers, associate accountants, legal advisers). In these cases the Company remains responsible for the processing of your personal data and defines the individual elements of the processing, and receives from the partners to whom it assigns the execution of processing activities all necessary assurances (Data Privacy Assignment), in order to ensure that the processing is carried out in accordance with the applicable legal framework and that any natural person may freely and without hindrance exercise the rights conferred by the legal framework.
Further, the Company may transmit your data to third party associates (marketing companies) in order to inform the public about the services we provide, the promotion of our properties and services, and the presentation of our offerings, provided that consent has been given by any natural person, as referred to above, and that the aforementioned activities relate to the contractual terms assigned to the data processor.
- To the shareholder company Hellenic Corporation of Assets and Participations
HPPC may transmit the personal data that it processes, such as for employees, customers, employees, etc., to its parent company and sole shareholder, Hellenic Corporation of Assets and Participations (HCAP), for the sake of setting, approving or reviewing its strategic plans, its economic activities and financial position, and in general for HCAP to exercise all its rights as sole shareholder and in order to serve the purposes for its establishment and operations as defined by law 4389/2016 in conjunction with law 2190/1920.
Transmission of personal data outside the EEA
Your personal data is not transferred to third countries (i.e. countries outside the European Economic Area).
To exercise this right you can contact the Data Protection Officer (DPO) at email: [email protected].
Length of time that data is stored
The length of time that data is stored is decided on the basis of the following specific criteria as appropriate:
Where the processing is required to comply with provisions of the existing legal framework your personal data will be stored for as long as the relevant provisions require and as long as necessary for the establishment, exercise, support or rebuttal of legal claims arising from the contract and up to their lawful limitation period. The above personal data may also be retained as long as is determined by other tax or more specific legislative provisions.
For the purposes of promoting our products and services and in so far as the use of your personal data is based on your consent, your personal data is kept until you withdraw that consent. This can be done by you at any time. Withdrawal of consent shall not affect the lawfulness of the data processed in the period prior to your withdrawal of consent.
What are your rights in relation to your personal data?
Any natural person whose data is processed by HPPC enjoys the following rights:
Right of access
You have the right to be informed and to verify the legality of the data processing. That means you have the right to access the data and receive additional information about the data processing.
Right of rectification
You have the right to review, correct, update or modify your personal data through contact with the Data Protection Officer (DPO).
Right to delete data
You have the right to request deletion of your personal data when we process it on the basis of your consent or in order to protect our legitimate interests. In all other cases (such as where there is a contract, or a legal obligation to process personal data based on public interest), this right is subject to specific restrictions or may not exist depending on the circumstances.
Right to restrict processing
You have the right to request restrictions on the processing of your personal data in the following cases: (a) when you dispute the accuracy of the personal data and until verification is made, (b) when you object to the deletion of personal data and instead request restrictions on use, (c) When personal data is not needed for the purposes of processing, it is however necessary for the establishment, exercise, and support of legal claims, and (d) when you oppose the processing of data and until it is verified that there are legitimate reasons that concern us and which override the reasons why you oppose the processing.
Right to object to the processing
You have the right to object at any time to the processing of your personal data in cases where, as described above, this is necessary for our legitimate interests to process the data.
Right to data portability
You have the right to receive, free of charge, your personal data in a format that will allow you to access the data, use it and edit it with commonly available processing methods. You also have the right to ask us, if technically feasible, to transmit the data directly to another party responsible for the processing of data. This right exists for the data you have provided to us and has been processed by automated means based on your consent or in the performance of a relevant contract.
Right to withdraw consent
Where the processing of data is based on your consent, you have the right to withdraw that consent without affecting the lawfulness of processing based on your consent prior to the revocation of consent.
To exercise any of the above rights you may contact the Data Protection Officer (DPO) at email: [email protected].
Right of complaint to the HDPA
You have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr): Tel.: (+30) 2106475600, Fax: (+30) 2106475628, email: [email protected]
Security of personal data
HPPC applies appropriate technical and organizational safeguards to ensure the secure processing of personal data and to prevent accidental loss or destruction and unauthorized and/or unlawful access to, use, modification or disclosure of that data. But given the nature and open access of the internet, no guarantees can be provided that unauthorized third parties will never be able to violate the technical and organizational safeguards, applied by the Company, to gain access and possibly make use of the personal data for unauthorized and/or undesired purposes.
Links to other websites
Our website may contain links to other websites. HPPC is not responsible for the privacy practices or the content of other websites that do not belong to our Company. We therefore suggest that you carefully read the privacy statements posted on the website of the respective websites.
Changes to the privacy statement
The information about our privacy policy reflects the current state of data processing. In the event of changes in data processing procedures, the information regarding data protection will be updated accordingly. Our website will always provide latest version of the Company’s privacy policy so that you are informed about the scope of data processing on our website and by the Company. We recommend that you always be aware of how we process and protect your personal information. All changes to this privacy statement will be made known in good time before any changes take effect.