Germanikis Sholis Athens 10
151 23 Marousi
ON PERSONAL DATA PROTECTION
The société anonyme under the trade name “EMPORIKI EISAGOGIKI AFTOKINITON DITROCHON KAI MICHANON THALLASIS SOCIETE ANONYME” and the distinctive title “MOTODYNAMICS S.A.” (“Company”) is the exclusive distributor in Greece of YAMAHA and PORSCHE vehicles. Our Company, as the controller, in compliance with GDPR and Greek Law 4624/2019, hereby provides you with the following information for the processing of your personal data, as well as your rights as data subject.
Β. PRIVATE DATA THAT WE COLLECT
Our Company, as data controller under the meaning of article 4 (7) of GDPR, collects, and processes further personal data that you voluntarily provide us with, as well as data obtained from third parties, that is necessary for our transactions and the communication between us. In particular, we may collect personal data from you, for the purposes mentioned herebelow, especially when we sell a vehicle or parts or spare parts or other marketing products of our Company to you, when we provide after-sale services to you (e.g. repairing / servicing your vehicles), when we clear your vehicles through customs, during test-rides and test-drives, when you send us your resume to apply for a job posting, when you associate with the Company within the frame of its business activity, when you participate as shareholders or shareholder representative in the Company’s General Assemblies, when you use our website or other websites accessible through our website, when you sign up for our electronic services, when you create an account on our website and / or our mobile apps, when you request to receive our Company’s newsletter, when you become a member or comment on the Social Media accounts of the Company (such as Facebook, Instagram, Twitter, YouTube etc.), when you participate in a survey or contest that our Company organizes and when you submit requests, complaints, comments, reviews or contact us on any matter.
More specifically, we may collect, directly from you or from third associates of our Company (our subsidiary “MOTODIKTYO SINGLE-MEMBER S.A.” or/and from our dealers’ network), the following categories of data that concern you:
C. LEGAL BASIS FOR PROCESSING
The legal basis for processing your personal data may be, per case, the following:
a) The fulfillment of our contractual and pre-contractual obligations (article 6(1), first section, case (b) of GDPR): It is necessary to provide us with the personal data required in order to prepare and carry-out the contractual relationship between us. Without this data, we are not able to process your request or to execute the contract between us;
b) The processing is necessary for the conclusion of an employment contract or, after the conclusion, for its execution (article 27 par. 1 of Law 4624/2019);
c) Compliance with the Company’s legal obligations (article 6(1), first section, case (c) of GDPR): If the required data is not provided to us, we may not be able to abide by our obligations under law;
d) The fulfillment of the legitimate interests of the Company or third parties (article 6 (1), first section, case (f) of GDPR);
e) Your consent (article 6(1), first section, case (a) of GDPR): If you have provided your consent for specific purposes, these purposes arise from the corresponding content of that consent. In cases where you have to provide data for this purpose, we will explicitly mention it to you. If this data is not provided to us, we will not be able to comply with your will, as set forth in your consent. You can withdraw your consent at any time, which, however, will not affect the lawfulness of the processing based on your consent before its withdrawal;
f) Your consent as an employee of the Company (article 27 par. 2 of Law 4624/2019), for specific purposes of processing arising from the content of the consent, which you can withdraw at any time, but without prejudice to the lawfulness of the processing based on your consent before its withdrawal;
g) In the cases of article 25 par. of Law 4624/2019. 4624/2019.
Specifically for the processing of special categories of your personal data, within the meaning of article 9 par. 1 of GDPR, the legal bases for its processing are, per case, the following:
a) Your consent (article 9 (2) case (a) of GDPR) which you have expressly provided to us for one or more specific purposes that arise from the respective content of the consent. You can withdraw your consent at any time, but without prejudice to the lawfulness of the processing based on your consent before its withdrawal;
b) The exercise of rights or the fulfillment of legal obligations deriving from labor law, social security law and social protection (article 27 par. 3 of Law 4624/2019);
c) The data has been manifestly made public by the data subject (article 9 (2) case (e) of GDPR);
d) Processing is necessary for the establishment, exercise or defense of legal claims (article 9 (2) case (f) of GDPR);
e) The processing is necessary for the purposes of assessing the ability to work (article 22 par. b of Law 4624/2019);
f) In the cases of article 25 par. 2 of Law 4624/2019. 4624/2019.
D. DATA CONCERNING MINORS
Any processing of personal data of minors under 15 years of age is carried out if and to the extent that consent has been given by their legal representatives.
Ε. PURPOSES FOR PROCESSING
We process personal data that concern you for the following purposes:
a) to communicate on any matter arising from our contract/transaction, especially for the preparation / processing / submission of tenders, the processing of contracts concluded, the execution / delivery of the order at your place, the confirmation of your details and your identification, in any case required, the receipt / activation of any gifts after a lottery, the answer to specific requests / questions / complaints that you direct to us, as well as your general service;
b) for the collection of the consideration for our products or services and the issuance of the legally required documents, for the avoidance of property infringements (especially for the cases of fraud, theft, embezzlement), as well as for the assessment of your creditworthiness by receiving the corresponding information from credit bureaus;
c) for the defense of the legal rights and the exercise of the legal claims of the Company before judicial or other authorities;
d) for the fulfillment of the Company’s compliance obligations with domestic and foreign supervisory authorities;
e) to ensure the correctness and accuracy of the data, so that any transaction can be executed properly;
f) to communicate with you in case of an existing risk related to a vehicle or any other goods imported by our Company.
We process your data in the context of market surveys, as well as for conducting studies and general reports, which, in addition, allow the Company to ensure its compliance with applicable law.
We process your data for the purpose of providing warranty and insurance coverage with regards to the products we trade. Especially for the fulfillment of the purpose of providing warranty, we may disclose your personal data that are necessary to the manufacturers.
We contact you electronically and provide you with information about offers and products of our Company, following a previous transaction or communication between us. However, you can choose whether or not to receive such communications. In particular, if you have provided your consent, the Company may process your data for the following purposes:
a) promotion of products and services;
b) conducting qualitative / quantitative research, and / or analysis;
c) participation in promotions and invitations to events;
d) optimizing offers to our customers and all our business processes, as well as for your personalized care as customers and prospective customers;
e) optimizing our online presence.
We process your personal data in order to comply with disclosure duties to the authorities and to comply with processing requirements as defined by commercial and tax legislation.
F. RECIPIENTS OF DATA
a) employees of the Company, only to the extent necessary, which are bound by confidentiality clauses;
b) affiliated and cooperating companies, such as manufacturers of the products that we trade for warranty purposes or defects of such products, companies that provide services in the fields of telecommunications, technical support, insurance, advertising, printing, etc., as processors under the meaning of article 4 (8) of GDPR, which process your data on our behalf and are subject to our instructions and mandates;
c) certified auditing companies that audit the financial statements of our Company;
d) external associates of the Company, such as customs’ agents, legal, insurance and other consultants, to whom the Company entrusts the execution of certain actions and which are bound by confidentiality clauses;
e) associates and service providers in general, to whom the data is transmitted to process a request or to execute a contract with you or to safeguard legitimate interests, e.g. credit institutions, transport service providers or providers of similar services;
f) public authorities or prosecutor and judicial authorities or tax and customs authorities to whom we are obliged to disclose personal data that concern you.
Besides the aforementioned persons, your personal data will not be further disclosed to third parties.
G. DATA RETENTION PERIOD
We retain your personal data only for the duration necessary to achieve the purposes, as entailed in this document, or generally in our contractual documents or -if your consent has been granted- until you withdraw your consent. We further retain your data within the required period for commercial and tax retention obligations. In any case, this period shall not exceed twenty (20) years.
After the expiration of the above period, your personal data is destroyed. In particular, we delete your personal data immediately, when the legal basis for its processing does no longer exist, if it is no longer necessary for the purpose of drafting and executing our contract and if no other special legal basis for processing exists, in case of objection on your part, unless further processing is permitted according to the relevant legal provisions, if we are obliged to do so for other legitimate reasons and in any case after twenty (20) years. It is especially pointed out that any CV that you may send us in order to apply for a job posting in the Company and is subject to par. 6 of article 27 of Law 4624/2019 is retained by the Company for a period of six (6) months from sending it to the Company, after which it is deleted.
In case retention of personal data is necessary for the exercise or defense of the Company’s legitimate rights before judicial or other authorities provided for under the applicable law, the above period is extended until the end of the period during which such data is no longer necessary for the above purposes.
We make every effort to minimize the personal data we use over time and, if possible, to anonymize it, so that it can no longer be associated with you or render you identifiable. In the case of anonymized data, we may use it without further notice.
Η. COMMUNICATE WITH THE COMPANY AND EXERCISE YOUR RIGHTS
According to the applicable data protection legislation you have the following rights:
For the exercise of the above rights, as well as for the communication between us or for any questions regarding the processing of your personal data, you can contact the Data Protection Officer, in writing to the postal address: MOTODYNAMICS S.A., 10, Germanikis Scholis Athinon Str., Maroussi, Attica, Greece, PC 15123, or at the e-mail address: firstname.lastname@example.org, or by phone at +30 210 6293-500, or by fax: +30 210 6293-521, and we will make sure to reply to you as soon as possible.
I. OBLIGATIONS OF THE COMPANY
The Company is under an obligation to undertake all reasonable measures to ensure the confidentiality and security of data processing and its protection against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access by any other form of unfair treatment.
J. COMPANY OBLIGATIONS The Company is obliged to take every reasonable measure to ensure the confidentiality and security of data processing and its protection against accidental or unlawful destruction, accidental loss, alteration, prohibited dissemination, abuse or access by anyone and any other form of unlawful processing. Your personal data will not be processed for any purpose other than those provided herein, without your prior knowledge and / or consent.
K. CHANGES IN DATA PROTECTION POLICY