1. INTRODUCTION

1.1 We are committed to ensuring the privacy of visitors to our website and users of our services, making every reasonable effort to safeguard their personal data.

1.2 This policy applies when we act as a data controller concerning the personal data of visitors to our website and users of our services, in other words, when we determine the purposes and means of processing such personal data.

1.2 We use cookies on our website. If these cookies are not strictly necessary for providing [our website and services], we will ask for your consent to use cookies when you first visit our website.

1.3 Our website includes consent controls that affect how we process your personal data. Using these consent controls, you can specify whether you wish to receive direct marketing communications and limit the publication of your information. You can opt out of receiving direct communications by unsubscribing via the relevant link in electronic messages or by submitting a request to dpo@septona.gr.

1.4 In this policy, “we,” “us,” and “our” refer to SEPTONA. For more information about us, please see Section 12.

2. How We Collect and Use Your Personal Data

2.1 In this section, we describe:

(a) The general categories of personal data we may process.

(b) If we did not obtain the personal data directly from you, the source and specific categories of such data.

 (c) The purposes for which we may process personal data; and

(d) The legal bases for processing.

2.2 We may process data related to your use of our website and services (“usage data”). Usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, visit duration, page views, and website navigation paths, as well as information about the frequency, timing, and pattern of your visits]. The source of the usage data is Google Analytics. This usage data may be processed for the purpose of analyzing the use of the website and services. The legal basis for this process is your consent (cookie acceptance) and/or our legitimate interests, namely, monitoring and improving our website and services.

2.3 We may process your basic account details (“account data”), including your full name and email address, to enable you to submit inquiries to the Care for Heroes service and receive responses. We may also process your account details, including your username and password, to store them for the purpose of operating our website and the Care for Heroes service, ensuring the security of our website and services, and maintaining backups of our database. The source of the account data is you. The legal basis for this process is our legitimate interests, namely, the proper management of our website, your consent, and the performance of our contract (Terms of Use).

2.4 Your account details may be processed for the purpose of enabling and monitoring your use of our website and services or informing you about new service and product offers through newsletters. The legal basis for this process is your consent, our legitimate interests (i.e., the proper management of our website), and/or the performance of our contract (Terms of Use).

2.5 We may process your personal data when you use the Care for Heroes communication platform, where you can watch live sessions with experts on care-related topics on scheduled days and times, as well as access advice and articles.

• During the live session, you may submit your question by registering through the corresponding form on the Live page.
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• To register, you will be asked to provide your full name and email address and set your username and password.
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• The question you submit will be visible to the expert and the website administrators.
• Submitted questions must be relevant to the discussion topic as stated on the page. Otherwise, they will be deleted, and no response will be given.
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• The expert will answer your question during the live session without referencing your personal details.
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• If your question is not answered during the live session, you will receive a response from the expert via email (careforheroes@septona.gr) within the following days at the email address you provided.
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• The content is informational and does not constitute recommended medical treatment. In case of an emergency, please do not rely on this feature.
• Your queries and comments should not harass or threaten the personal safety or property of others, nor should they contain false statements, defamation, or impersonate others.
• Every 3 months your communication is deleted.

The source of this data is you. The data from services may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining databases, and communicating with you. The legal basis for this process is your consent, our legitimate interests, i.e., the proper management of our website and services, or/and the performance of a contract between you and us. (Terms of Use)

2.6 We may process information contained in any inquiry you submit to us regarding products, services, or surveys we conduct (“survey data”). Survey data may be processed to offer, market, and sell relevant goods and/or services to you. The legal basis for this process is consent.

2.7 We may process information you provide to subscribe to email notifications and/or newsletters (“notification data”). Notification data may be processed to send you the relevant notifications and/or newsletters. The legal basis for this process is your consent. Specifically, the processing of users’ personal data for sending informational and promotional material is carried out only if the user has completed the relevant field and has consented to its delivery, or if their email address has been lawfully collected as part of a previous transaction.

2.8 We may process information contained in or related to any communication you send us (“communication data”). Communication data may include the content of the communication and metadata (contact form) associated with the communication. Our website will generate data related to communications made through contact forms on the website. Communication data may be processed for the purpose of responding to you. The legal basis for this process is your consent and our legitimate interests, namely, the proper management of our website and communications with users.

2.9 We may process any of your personal information identified in this policy when necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings, administrative proceedings, or out-of-court settlements. The legal basis for this process is our legitimate interests, namely, the protection and enforcement of our legal rights, your legal rights, and the legal rights of third parties.

2.10 We may process any of your personal data identified in this policy where necessary for the purpose of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this process is our legitimate interests, namely, the proper protection of our business against risks.

2.11 In addition to the specific purposes for which we may process your personal data as set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal or regulatory obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12 Please do not provide personal data of any other person unless we request you to do so.

3. Transfer of Your Personal Data to Others

3.1 We may transfer your data to our suppliers or their subcontractors to the extent that is reasonably necessary for the maintenance and operation of this website. You may request a list of our current suppliers by submitting a request via dpo@septona.gr.

4. International Transfers of Your Personal Data

4.1 In this section, we provide information regarding the circumstances under which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 Our company and other companies in our group have offices in Greece and Bulgaria (within the EEA). If your data is transferred to a country outside the EEA, this will only occur if the European Commission has issued an “adequacy decision” regarding that country’s data protection laws. Additionally, the data will be protected by appropriate safeguards, specifically through the use of standard data protection clauses agreed upon between us and the recipient or approved by the European Commission. You may request a copy of these clauses (if applicable).

4.3 Our website hosting facilities are located within the EEA.

4.4 You acknowledge that any personal data you submit for publication via our website or services may be available online worldwide. We cannot prevent the use (or misuse) of such personal data by others.

5. Retention and Deletion of Personal Data

5.1 Section 5 sets out our data retention policies and procedures, designed to ensure compliance with our legal obligations regarding the retention and deletion of personal data.

5.2 Personal data that we process for any purpose(s) shall not be retained for longer than necessary for that purpose or those purposes.

5.3 Data collected via the website’s contact form when an inquiry is submitted is retained for 3 months after the completion of communication and is then deleted.

In the case of newsletter/subscription notifications, we will retain your contact personal data for 10 years.

In the case of registration in the “Care for Heroes” service:

• We will retain your account personal data for 5 years.
• If you submit a question on the platform, we will retain the question and the communication with you for 3 months after the completion of the communication.

At any time, you may withdraw your consent and request deletion of your data.

5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation or for the protection of your vital interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are satisfied with any changes to this policy.

6.3 We will notify you of significant changes to this policy via email or through our website’s private messaging system.

7. Your Rights

7.1 In this Section 7, we summarize the rights you have under data protection law. Some of these rights are complex, and not all details are included in our summaries. Therefore, you should read the relevant laws and guidance from regulatory authorities for a full explanation of these rights.

For any questions related to personal data, please contact us at dpo@septona.gr.

7.2 Your main rights under data protection law are:

1. a) The right to access
2. b) The right to rectification
3. c) The right to erasure
4. d) The right to restrict processing
5. e) The right to object to processing
6. f) The right to data portability
7. g) The right to lodge a complaint with a supervisory authority
8. h) The right to withdraw consent

7.3 You have the right to confirm whether or not we process your personal data, as well as certain additional information. This additional information includes details about the purposes of processing, the categories of personal data involved, and the recipients of the personal data. Provided that the rights and freedoms of other individuals are not affected, we will supply you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to correct any inaccurate personal data about you and, considering the purposes of the processing, to complete any incomplete personal data.

7.5 In certain circumstances, you have the right to request the erasure of your personal data without undue delay. These circumstances include:

• The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed
• withdraw your consent when processing is based on consent.
• object to processing under certain rules of applicable data protection law.
• The processing is for direct marketing purposes and the personal data has been unlawfully processed.

However, there are exceptions to the right to erasure. For example, when processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise, or defense of legal claims.

7.6 In certain cases, you have the right to restrict the processing of your personal data. These circumstances include:

• You contest the accuracy of the personal data.
• The processing is unlawful, but you oppose its deletion.
• We no longer need the personal data for our processing purposes, but you require it for the establishment, exercise, or defense of legal claims.
• You have objected to processing.

Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only process it in the following ways: with your consent, for the establishment or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

7.7 To the extent that the legal basis for processing your personal data is:

(a) consent, or

(b) the necessity of processing for the performance of a contract to which you are a party, and such processing is carried out by automated means.You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.8 If you believe that the processing of your personal data violates data protection laws, you have the legal right to lodge a complaint with a data protection supervisory authority. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

7.9 To the extent that the legal basis for processing your personal information is consent, you have the right to withdraw that consent at any time. The withdrawal will not affect the lawfulness of processing before the withdrawal.

7.10 You may exercise any of your rights regarding your personal data by providing us with written notice. See Section 12 for contact details.

8. About Cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies:

A persistent cookie will be stored by a web browser and will remain valid until its expiration date unless deleted by the user before that date. A session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.

8.3 Cookies typically do not contain information that personally identifies a user, but the personal information we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies We Use

9.1 We use cookies for the following purposes:

Strictly Necessary Cookies

These cookies are essential for the website to provide services requested by the user, such as remembering items added to their shopping cart.

Performance Cookies

This category of cookies collects anonymous information about how each user interacts with the website. The data is aggregated with that of other users and helps improve the website’s functionality. For example, these cookies help us understand how customers find, navigate, and use our website, highlighting areas for improvement such as browsing, shopping experience, and advertising campaigns. The data collected by these cookies does not include personally identifiable information.

Functionality Cookies

These cookies remember user preferences, such as language settings or search parameters like size, color, or product line. This information allows users to enjoy a more personalized experience when visiting our website and helps us enhance their visits. These details are also aggregated anonymously with other users’ data to improve website functionality.

Targeting & Advertising Cookies

These cookies collect information about browsing habits to tailor advertisements to users’ interests. They remember the pages visited and the information shared with third parties, such as advertisements.

10. Cookies Used by Our Service Providers

10.1 Our service providers use cookies, and these cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use through cookies. The information collected is used to generate reports on website activity. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

11. Managing Cookies

11.1 Most web browsers allow you to refuse cookies and delete existing cookies. The methods for doing so vary by browser and version. However, you can find up-to-date information on blocking and deleting cookies through the following links:

(a) https://support.google.com/chrome/answer/84536?hl=el (Chrome).

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox).

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera).

(d) https://support.microsoft.com/el-gr/help/16332/windows-internet-explorer-delete-manage-cookies (Internet Explorer).

(e) https://support.apple.com/kb/PH21210 (Safari). και

(f) https://privacy.microsoft.com/en-us/windows-9-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will negatively impact the usability of many websites.

11.3 If you block cookies, you may not be able to use all the features of our website.

12. Our Details

12.1 This website is owned and operated by SEPTONA SA.

12.2 We are registered in Greece under general commercial register number 13389617000, with our headquarters located in Inofita, Viotia.

12.3 Our main place of business is in Greece.

12.4 You can contact us:

(a) by mail at: Inofita, Viotia, PO Box 95, Greece

(b) Using the contact form on our website.

(c) By phone, using the contact number published on our website or

(d) By email, using the email address published on our website.

13. Data Protection Officer

13.1 For any request regarding personal data, please contact us at dpo@septona.gr.