Personal Data Processing Notice for the processing of personal data relating to suppliers, real estate agents, service providers and contractors of doValue RES in accordance with Regulation (EU) 2016/679, law 4624/2019 and the relevant Greek and European legislation.

“dovalue Greece Real Estate Services Single Member Société Anonyme”, headquartered in 19-21 Kyprou & Archimidous street, 18346, Moschato, Greece, with GEMI no. 121602601000 and distinctive title ” dovalue Greece Real Estate Services S.M.S.A. ” (hereinafter “doValue RES”) informs you pursuant to the General Data Protection Regulation (EU) 2016/679 (hereinafter “GDPR”), Greek law 4624/2019 for the implementation thereof and the relevant Greek and European legislation on the protection of personal data, under its capacity as a controller with regard to the collection and further processing of your personal data as well as your rights as data subject.

1. Who does this Notice refer to

This Notice is addressed to:

suppliers,

real estate management or investment companies, real estate agents, service providers and contractors of doValue RES, as well as third parties related to the aforesaid persons and/or entities, indicatively the personnel, partners, representatives, managers, executives, sub-contractors, assignees, vicarious agents etc.,

provided that their personal data are subject to processing for the purposes set out herein.

It is noted that, in case a supplier and/or real estate management or investment company and/or real estate agent and/or service provider and/or contractor is a legal person or entity, the current Notice is addressed to its representatives, agents, employees, partners and management bodies, whose personal data are subject to processing on behalf of doValue RES in the context and for the purposes of the relevant agreement with doValue RES.

This Notice may be supplemented by more specific notices and policies of doValue RES.

2. Data Controller

The data controller of your personal data is doValue RES, a company for the exploitation and management of real estate.

3. What personal data doValue RES processes and which sources it collects such data from

A. Categories of personal data processed by doValue RES  

In view of the above, the personal data that doValue RES collects and processes may indicatively be the following and not all of them necessarily concern you:

1. Identification data: name and surname, father’s name, mother’s name, identity card and identity card number (ID) or passport and passport number, tax identification number, competent tax authority, social security number, date and place of birth, citizenship, sex, photo, electronic identification data such as username, signature data, etc.
2. Communication data: postal address/residence details, e-mail address, telephone number (home and mobile), etc.
3. Occupation and professional skills: such as, indicatively, information included in submitted CVs and/or offers you submit, in documents and supporting documents, such as professional certifications, recommendations and/or contact information for the receipt of recommendations or their confirmation by third parties, as well as professional experience or activity data, data provided in your professional card, etc.
4. Financial and invoicing data, including your bank account details.
5. Financial and insurance data: indicatively, in cases where there is a legal representative of a general partnership or an individual business, income tax declarations and tax statements, insurance and tax clearance, non-bankruptcy and non-insolvency certificate, non-filing of insolvency petition on certificate, non-filing of application for suspension of payments certificate, debt data, etc., as provided by the current legal and regulatory framework and the policies of doValue RES.
6. Data arising throughout the duration of your relationship with doValue RES: indicatively communications/correspondence with doValue RES or third parties in the context of your duties/activities, data concerning benefits/expenses, data concerning access to premises, systems, archives and any other related electronic equipment of doValue RES etc.

B. Sources from which doValue RES collects your personal data

doValue RES collects your above personal data from the following sources:

a) Directly from you or from third parties acting on your behalf (e.g. agents, authorized representatives etc.) or related to you. doValue RES is not responsible for any illegal processing of your personal data by the above third parties.

b) From our employees, as well as from third-party service providers, suppliers and partners/affiliates of doValue RES.

c) From publicly accessible sources.

It is noted that the above data can also be collected or verified from companies of the Group to which doValue RES belongs or from third parties which provide or verify recommendations about you.

According to the GDPR, personal data should be updated and accurate. Consequently, you are obliged to inform doValue RES about any change of the aforementioned personal data which have been transmitted to doValue RES by you.

Furthermore, if you provide us with personal data of third parties, you are obliged to fully inform them in advance, including by reference to this Notice, and obtain their relevant consent, where required.

4. Why doValue RES collects your personal data and for which purposes it processes them

doValue RES processes your personal data in the context and for the purposes of the execution of your agreement. In particular, doValue RES processes your data for the purposes mentioned below:

Α. For the execution of the agreement and the measures taken following your request prior to the conclusion of the agreement

The aforementioned processing of your personal data serves purposes, such as:

1. Your identification, the verification of your details and communication with you, including during both the pre-contractual and contractual stage.
2. The management of the agreement with doValue RES, as well as the execution, management and in general the smooth operation of the agreement with doValue RES and the fulfillment of the mutual obligations thereunder.
   
   

Β. For the compliance of doValue RES with its legal obligations

doValue RES processes your personal data to the extent necessary, in order to comply with the obligations imposed by the relevant legal, regulatory and supervisory framework, as well as the decisions of authorities (public, supervisory, independent, prosecutorial, etc.) or courts (regular or arbitral) and for the protection of persons and goods.

C.  For legitimate interest purposes pursued by doValue RES or third parties (indicatively, companies of the Group, affiliates etc.)

The processing of your personal data also serves purposes such as, indicatively, the establishment, exercise and defense of legal claims, the compliance with the policies of doValue RES, the compliance with terms of contracts of doValue RES with third parties, the security of IT systems and, in general, assets of doValue RES and/or a third party, the preservation of reputation, record keeping, the prevention and deterrence of criminal acts or fraud against doValue RES or a third party, etc.

5. Who are the recipients of your data

In the context of processing your personal data, doValue RES may transmit those data to the following recipients:

1. to the authorised employees, members of management/committees of doValue RES in the context of their duties and to companies of the Group to which doValue RES belongs.
2. to lawyers, law firms, court bailiffs, notaries, experts, accountants/auditors and providers of counselling services etc.
3. Companies for storage, archiving, management and destruction of files and data, providers of IT and maintenance services, providers of teleconference services, providers of electronic communications services, cloud computing, information society and postal services.
4. To supervisory, independent, judicial, prosecutorial, police, tax, public and/or other authorities or bodies, accredited intermediaries and centers of mediation services, arbitration courts and alternative dispute resolution bodies.

6. Transfer of your personal data outside the European Economic Area

doValue RES does not transfer your personal data directly to third countries or international organizations, unless such transfer is required by the applicable regulatory or legal framework. If applicable, doValue RES may transfer your personal data to third countries under the following circumstances:

1. Where the European Commission has decided that the third country, a territory or one or more specified sectors within that third country or international organisation ensure an adequate level of protection, or
2. If appropriate safeguards have been provided from the recipient, in accordance with the national and European legislation.

In the absence of the abovementioned circumstances a transfer may take place if:

• You have provided your express consent to doValue RES; or
• the transfer is necessary for the performance of a contract between you and doValue RES, such as for the execution of your orders, or
• the transfer is necessary for the establishment or exercise or defense of legal claims and rights of doValue RES, or
• there is a relevant obligation arising from a legal provision or an international convention to which doValue RES is subject. In order to fulfill such obligation, doValue RES may transfer your personal data to competent national authorities so that such data are delivered through them to the respective authorities of third countries.

7. How long doValue RES stores your personal data

Your personal data shall be kept throughout your contractual relationship and your cooperation with doValue RES and for the time period which is deemed necessary under the relevant legal and/or regulatory framework and in any case, your personal data shall be kept until the fulfillment of the general limitation period set by the law, i.e. until the lapse of twenty (20) years from the -by any means- termination of your cooperation with doValue RES.

If there is ongoing litigation with doValue RES, the maintenance period of the personal data shall be extended until the issuance of an irrevocable court decision.

Also, very few necessary personal data of yours (indicatively, identification data, data included in the minutes of the management bodies of doValue RES etc.) may form part of the historical archive of doValue RES and therefore shall be kept throughout the time period of maintenance of such archive.

8. Your rights towards doValue RES with regard to the protection of your personal data

In accordance with the provisions of GDPR, you have the following rights:

• Right of access to your personal data that are retained and processed by us, as well as to information concerning the processing thereof (origin of the data, purposes of processing, categories of recipients, storage period).
• Right to rectification of your personal data, in the event of inaccurate data or for the purposes of completing incomplete personal data by providing any necessary document justifying the need for rectification or supplementation.
• Right to object on grounds relating to your particular situation unless the processing is necessary for the purposes of the legitimate grounds of doValue RES or a third party.
• Right to restriction of processing of your personal data where the accuracy of the personal data is contested by you or the processing is unlawful or doValue RES no longer needs your personal data for the purposes of processing, or you have objected to the processing and the verification whether the legitimate grounds of doValue RES override yours, is pending.
• Right to erasure of your personal data from doValue RES’ records.

Please note indicatively the following in relation with your above rights:

• doValue RES has in any case the right to refuse the satisfaction of your request for the limitation of the processing or the erasure of your personal data if their processing or their maintenance is necessary for the exercise of your rights or the fulfillment of the obligations of doValue RES towards you as well as the establishment, exercise or defence of legal claims of doValue RES or the compliance of doValue RES with its legal obligations.
• doValue RES also has in any case the right to refuse the erasure of your personal data, provided that some of them are not erased for filing purposes.
• The exercise of the above rights acts for the future and does not concern already executed processing of data.

9. How you may exercise your rights towards doValue RES

For the exercise of the rights of the above section, you may address your relevant requests in writing, to 19-21 Kyprou & Archimidous street, 18346, Moschato, Greece or by e-mail at dpo@dovaluegreeceres.gr .

doValue RES shall use its best endeavors to address your request within thirty (30) days from its submission. The abovementioned period may be extended by two (2) further months, if deemed necessary at reasonable discretion of doValue RES, taking into account the complexity and number of requests. doValue RES shall inform you in case of such extension within one month from the receipt of the request.

The abovementioned service is provided by doValue RES free of charge. However, where requests are manifestly unfounded, excessive or repetitive, doValue RES may, after informing the debtor, either charge a reasonable fee or refuse to act on the request/requests.

10. Data Protection Officer of doValue RES

You may contact the Data Protection Officer for any matter regarding the processing of your personal data, in writing at the address 19-21 Kyprou and Archimidous Street, 183 46 Moshato, Greece or by sending an email at dpo@dovaluegreeceres.gr.

11.  Right to appeal before the Hellenic Data Protection Authority  

You have the right to lodge a complaint before the Hellenic Data Protection Authority for any matter regarding the processing of your personal data. For the respective competence of the Authority and the procedure to be followed for filing a complaint, you may visit the Hellenic Data Protection Authority website (www.dpa.gr – Citizen Rights – Complaint to the Hellenic DPA), where detailed information is available.

12. Security of your personal data

doValue RES implements appropriate technical and organisational measures to ensure the lawful protection and processing, as well as the effective protection of your personal data from unauthorised access to, disclosure of, processing, loss, alteration, accidental or unlawful destruction or corruption, prohibited transmission by third parties as well as any other form of unlawful processing.

13. Updating and modifying this Information on the processing of personal data

doValue RES may in accordance with its applicable policy on the protection of personal data and pursuant to the applicable legal and regulatory framework, modify or amend this Notice, the updated version of which will always be posted on the  website at www.altermiaraproperties.gr .

Last update of notice: [September 2024]