Privacy Notice on the processing of personal data of doValue RES in accordance with the European Regulation (EU) 2016/679, Greek Law 4624/2019 and relevant applicable Greek and European legislation.

doValue Greece Real Estate Services Single Member Société Anonyme, headquartered in 25th Martiou, Thessalonikis and Teo 15 street, 17778, Tavros, Greece, with GEMI no. 156425101000 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 referred to as “GDPR”), Greek law 4624/2019 for the implementation thereof and the relevant applicable 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 this Notice concerns

This Notice is addressed to the following persons:

(a) to persons who show interest, submit a question or request, or wish to submit a bid for the acquisition of real estate, that is promoted, exploited and/or is generally managed by doValue RES,

(b) to clients of doValue RES in the context of real estate management agreements and/or brokerage for the promotion of real estate, including the owners of the real estate that doValue RES presents, promotes, operates and/or generally manages, as well as the persons who expedite the auction of real estate that doValue RES promotes,

(c) especially in the case of the promotion by doValue RES of real estate to auction on the order of the auctioneer, to the successful bidders and to the execution defendants – the owners of the auctioned real estate.

It should be noted that, in the case of a legal person or entity, this Νotice is addressed to its representatives, agents, employees, partners and management bodies, whose personal data is processed by doValue RES in view of the abovementioned purposes. This Notice may be supplemented by more specific notices and policies of the doValue RES.

2. Data Controller

The data controller of your personal data is doValue RES.

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

Α. Categories of personal data processed by doValue RES.

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

a. Identification data: name, a copy or the number of identity card or passport, tax identification number (TIN), social media profile data (i.e., the name and email that you have registered in the Facebook or Gmail accounts, when choosing to register or connect as a user), etc.

b. Communication data: Postal address, e-mail address, telephone number (landline or mobile), etc.

c. Technical and electronic data, such as the name and user code and your registration data on https://www.altamiraproperties.gr/ , the Internet Protocol Address (IP address), the operating system that you use, the type and version of the browser, etc.

d. Data concerning your requests when communicating with doValue RES or with the staff of the customer service department or the network of employees of the doValue RES.

e. Data relating to the real estate that doValue RES promotes or assigns for promotion to third parties or about which it provides services to its clients: Identification and contact details of doValue RES’ client (the owner of the real estate or the person who expedites the auction of the real estate), details of the successful bidder and the execution defendant – owner of the auctioned property which relates to the auction, address of the property, any encumbrances and attachments on the property, as well as information related to them and the auction (details of secured claims, the claims of the seizing party-claimant), property valuation reports, bidding reports of auctioned real estate, correspondence and general communication with doValue RES’ clients (owners of the real estate or the persons expediting the auction of the real estate) and doValue RES’ partners (brokers, evaluators, lawyers, notaries, bailiffs, other service providers), etc.

B. Sources from which the doValue RES collects your personal data

doValue RES collects these data from the following sources:

a) Directly from you or by third persons acting on behalf of you (e.g., representatives, agents, etc.) or related to you, when you contact doValue RES, including your expression of interest about any real estate, while browsing the website: https://www.altamiraproperties.gr/,when you register at doValue RES communication forms. 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 by third-party service providers related to the management, promotion, presenting, valuation or exploitation of real estate, suppliers and partners/affiliates of doValue RES (including brokers, lawyers, law firms, notaries).

c) From publicly accessible sources, including courts, cadastral offices, land registries, etc., the media, the internet, commercial registries, the e-auction service and the Legal Fund’s Judicial Publications Bulletin.

d) From clients of doValue RES, i.e. the owners of the real estate that doValue RES presents, promotes, operates and / or generally manages, as well as the persons who expedite the auction of real estate promoted by doValue RES (i.e., credit and / or financial institutions, including loans and credits claim management companies of Greek Law 4354/2015, acting as the claimants of the real estate auction).

In the event that you provide us personal data from third parties, you have to inform them sufficiently in advance for the transfer and processing of their personal data, including a reference to this Notice, and to obtain their relevant consent, where required.

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

In particular, doValue RES processes your data for the following purposes:

A. For the management of your registration as a user of the services of doValue RES andof the requests you submit to us

If you decide to register as a user of doValue RES services, we need to process your data to identify you as a user and to give you access to your account and to the various functions and information that is available for you because of your status as a registered user. You can cancel the user account by contacting doValue RES as described below in Section 9.

You can create an account or a connection to your account via a social network platform (e.g., Facebook, Gmail) when this option appears on our website or the applications of doValue RES. In this case your credentials for the connection (your full name and email) will be added into your account via the selected social network platform. In addition to the abovementioned information, doValue RES will not collect or keep any additional information from the profile you maintain in the selected social network. The use of this function, however, may mean that you may provide some information about your activity in that social network platform. In any case, we inform you that we do not control, and we are not responsible for the data that will be transferred to these platforms by you while we recommend that you check the privacy settings as well as the privacy policies of these platforms in which you keep accounts in order to be informed about the processing of your personal data.

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

The personal data processing serves particular purposes, such as your identification, verification of your details and communication with you, including both the pre-contractual level as well as the stages of the conclusion and smooth execution of the contract.

C. 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.

D. 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, including real estate management and promotion agreements, as well as agreements concluded in the context of the provision of brokerage services by doValue RES, the achievement of doValue RES’ corporate objectives, which consist in particular in the provision of real estate brokerage services and services relating to real estate management, 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.

E. For the purposes of direct promotion (marketing) of real estate by doValue RES to you, provided that you have given your consent.

If you have chosen to receive personalised information through promotional actions carried out by doValue RES, we will process your personal data on the basis of the consent you have given us. In such cases, you have the right to withdraw your consent at any time. Such withdrawal acts for the future and does not concern already executed processing of data.

5. Who are the recipients of your personal data.

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

a. To the authorised employees, members of management/committees of doValue RES in the context of their duties and to the companies of the Group where doValue RES belongs.

b. To associate evaluators, brokers and other associates of doValue RES for the purpose of promoting and managing real estate etc.

c. To service providers 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 service.

d. To the clients of doValue RES, i.e. the owners of the real estate that doValue RES presents, promotes, exploits and/or generally manages, as well as to the persons who expedite the auction of real estate promoted by doValue RES (i.e., credit and / or financial institutions, including claims management companies of Greek Law. 4354/2015, acting as the claimants of the real estate auction).

e. Prospective buyers of the real estate that doValue RES is promoting (including prospective successful bidders in the context of promoting real estate at auction).

f. To lawyers, law firms and notaries for the purposes of concluding and executing the contract of the sale of the property.

g. To supervisory, independent, judicial, prosecutorial, police, tax, public and/or other authorities or bodies.

h. To third parties submitting a request for information to the doValue RES only if the legal conditions are met.

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

doValue RES does not transfer your personal data 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:

· 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

· If appropriate safeguards have been provided from the recipient, in accordance with the national and European legislation.

If none of the above conditions apply, the transmission may be completed:

· If you have provided your express consent to doValue RES,

Or

· If the transfer is necessary for the performance of a contract between you and doValue RES, such as for the execution of your orders,

Or

· If the transfer is necessary for the establishment or exercise or defense of legal claims and rights of doValue RES,

Or

· If 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.

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7. How long doValue RES retains your personal data.

Your personal data shall be retained throughout the entire period in which your user account remains active and for the entire period of your cooperation with doValue RES. If you wish to erase your data from our files and / or cancel your user account, please contact the doValue RES as described below in Section 9.

Moreover, your personal data will, if necessary, be maintained for the time period which is deemed necessary under the relevant legal and/or regulatory framework.

Especially, in the case of a legal dispute with doValue RES, the retention period of the personal data shall be extended until the issuance of an irrevocable court decision.

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

According to GDPR’s provisions, you have the following rights:

i. 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).

ii. 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.

iii. Right to object the processing of your personal data, where the processing has been entrusted to doValue RES for the performance of a task carried out in the public interest or in the exercise of public authority or the legitimate interest pursued by doValue RES, including profiling

iv. Right to restrict 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.

v. Right to erase your personal data from doValue RES’ records.

vi. Right to portability of your personal data to any other data collector provided that the processing is based on your consent or on a contract and is carried out by automated means.

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 right to portability (above under vi) does not lead to the deletion of data from the archives of doValue RES, which (deletion) is subject to the conditions set out in the immediately preceding paragraph.

· The exercise of the above rights acts for the future and does not concern already executed processing of data.

9. How can you exercise your rights towards doValue RES.

In order to exercise the rights of the above section, you may address your relevant requests in writing to 27 Kyprou and Archimidous street, 18346, Moschato, Attiki, Greece, or by sending an e-mail at the address dovaluegreece@dovaluegreece.gr.

doValue RES shall use its best endeavors to address your request within one month 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 can contact the doValue RES Data Protection Officer for any matter regarding the processing of your personal data in writing at the address of 25th Martiou , Thessalonikis and 15 Teo street, 17778, Tavros, Attiki, Greece, or by sending an e-mail at the address 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 – Individuals – Rights of Individuals – 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 Notice 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.altamiraproperties.gr.

Last update of the Privacy Notice: November 2023