Ελληνικά
Privacy Policy
This Privacy Policy of the Data Controller, with the following details:
ALPHA TRUST-ANDROMEDA S.A. Portfolio Investment Company
Head Office: 1 Aristeidou St., Kifissia, P.C. 14561
Tel.: +30 210 62 89 100
Email: [email protected]
is addressed to natural persons and provides information and details regarding the collection, use, transfer, and protection of your personal data (hereinafter also referred to as “Data”), as well as your rights in accordance with national legislation and the General Data Protection Regulation (EU) 2016/679, commonly known as the GDPR (General Data Protection Regulation).
Collection and Processing of Personal Data
Your personal data includes any information that can lead, either directly or in combination with other data, to your identification as a natural person. This category includes, for example, full name, tax identification number (TIN), address, telephone number, email addresses, and any other information that enables your identification according to the provisions of the General Data Protection Regulation (GDPR) and the applicable Greek legislation and decisions of the Hellenic Data Protection Authority (HDPA).
ALPHA TRUST Andromeda S.A. Portfolio Investment Company (hereinafter “Andromeda” or the “Company”), as the Data Controller, collects and processes personal data as defined in Article 4(7) of the GDPR:
In the context of maintaining the Company’s shareholder registry and informing its shareholders (e.g., full name, father’s name, occupation, ID card details, physical and electronic address (email), phone number, TIN, nationality, financial/shareholding information).
When you request information related to financial data, decisions, updates, or when you submit requests, questions, complaints, comments, reviews, or otherwise communicate with us via phone, email, or regular mail.
When you subscribe (via email) to the Company’s newsletter.
When you send us your résumé (CV) in connection with a job application.
When you visit or browse the Company’s website. We use cookies to collect information on how you use our website. This allows us to adapt to your interests and needs by recording details that enable us to recognize you during future visits to the website (see the Cookie Policy).
If you visit the Company’s premises, we collect (and retain for the period required by applicable law) closed-circuit television (CCTV) footage for security purposes and to prevent unlawful activities.
Why We Process Your Personal Data and on What Legal Basis
We process your data for various purposes, including:
To distribute dividends or capital returns as applicable and to inform you in accordance with the provisions of the applicable legislation (Article 6(1)(b) GDPR).
To comply with our regulatory and legal obligations (Article 6(1)(c) GDPR and Article 25(1) of Law 4624/2019).
To safeguard and protect the legitimate interests of the Company (Article 6(1)(f) GDPR).
To inform you generally about our services (unless you have opted out of receiving promotional messages), as well as about events and financial analyses of our Company.
To respond to your questions or requests.
Additionally, the legal basis for processing your personal data may be your consent (Article 6(1)(a) GDPR). If you have given your consent for specific purposes (e.g., receiving promotional messages, acceptance/installation of cookies, etc.), those purposes derive from the relevant content of your consent. In cases where you are required to provide data for this purpose, we will explicitly inform you. If such data is not provided, we will not be able to fulfill your request as expressed in your consent.
You may withdraw your consent at any time without affecting the lawfulness of processing conducted prior to its withdrawal.
Retention Period of Personal Data
We will retain your data for as long as your shareholder relationship with the Company exists, and after its termination for as long as required by the applicable legislation or until the statute of limitations for any related claims expires. In any case, this period shall not exceed twenty (20) years.
Specifically, résumés (CVs) you may submit in connection with a job opening at the Company, which fall under paragraph 6 of Article 27 of Law 4624/2019, are retained in the Company’s records for six (6) months from the date of submission, after which they are deleted.
In particular, we delete personal data immediately when there is no longer a legal basis for its processing, or when it is no longer necessary for the preparation or execution of a contract entered into with you, and no other legal basis applies—for instance, in the case of your objection to the processing—unless further processing is permitted under relevant legal provisions, required for legitimate legal reasons, or in any case, after twenty (20) years.
If you visit the Company’s premises, CCTV footage is retained for 15 days. In cases where the retention of personal data is necessary for the establishment, exercise, or defense of the Company’s legal claims before judicial or other authorities as provided by law, the aforementioned retention period is extended until the data is no longer needed for those purposes.
We make every effort over time to minimize the personal data we use and to anonymize it, so that it can no longer be associated with or used to identify you. In the case of anonymized data, we may use it without further notice.
Who Are the Recipients of Your Personal Data
In fulfilling our obligations, your personal data may be disclosed to:
Supervisory authorities, administrative bodies, judicial or other public authorities to whom we are either required to provide information or who are legally authorized to request it.
Service providers (processors acting on our behalf) involved in the operation of the Company.
Authorized legal advisors.
We will also disclose data when deemed necessary for protection against fraud, to defend our rights, or to protect our investors.
Finally, access to your data is granted only to the Company’s strictly necessary personnel, who are bound by confidentiality and have been appropriately trained.
The Company guarantees that it will not transmit or disclose your data to any third party (other than the recipients mentioned herein) for any purpose or use without your prior written consent, unless such disclosure is required by applicable law or mandated by public / prosecutorial / judicial authorities.
Transfer of Personal Data Outside the EU/EEA
The Company does not transfer data outside the EU/EEA.
Automated Decision-Making
The Company does not use automated decision-making processes.
Personal Data Security
At Andromeda, we recognize the importance of protecting personal data, and we continuously monitor and improve our safeguards against unauthorized use, accidental loss, disclosure, or destruction. Every employee of the Company who has access to such information uses it solely for the purposes described above.
Your personal data is not used for any purpose other than those described in this Policy. Furthermore, in cases where an organization, company, or external partner provides services to us or on our behalf that involve the processing of personal data, we ensure that appropriate safeguards (technical and organizational measures) are in place and that the data is processed in accordance with the defined terms. These organizations or professionals are not permitted to process your data for their own purposes and are contractually bound (via a Data Processing Agreement) to maintain the confidentiality and protection of the data in accordance with national data protection laws and the EU General Data Protection Regulation (GDPR).
Your Rights
You may contact us to learn what data we hold about you and how exactly we process it. Additionally, you may request a copy of your personal data at any time by completing and submitting the relevant form, signed and with certified authenticity of your signature (Article 15 GDPR, subject to Article 33 of Law 4624/2019).
If you believe your data is incomplete or inaccurate, please contact us so that we can make the appropriate corrections (Article 16 GDPR).
If you believe your data is not being processed for a specific and lawful purpose, you may request its deletion after consulting with us (Article 17 GDPR, subject to Article 34 of Law 4624/2019).
You may request that we suspend the processing of your personal data or object to it on grounds related to your particular situation. If you submit such a request, we will no longer process your personal data, unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims (Article 21 GDPR, subject to Article 35 of Law 4624/2019).
You may opt out of all promotional activities or choose to be excluded only from specific types of communications (e.g., email, phone, etc.).
If you no longer wish to receive promotional emails, you may unsubscribe from our mailing list.
You may request to receive a copy of your personal data in a structured, commonly used, and machine-readable format in order to transfer it to another organization. You also have the right to request that your personal data be transferred directly by us to another organization you designate (right to data portability, Article 20 GDPR).
You may withdraw (Article 7 GDPR) your previously given consent for the processing of your personal data at any time, in cases where the processing is based solely on your consent and no other legal basis applies. In such cases, we will cease processing your data, without affecting the lawfulness of processing carried out prior to the withdrawal.
You may request the restriction of processing of your personal data for specific purposes only, including where there is a dispute regarding the accuracy of the data or in cases of unlawful processing (Article 18 GDPR).
You can submit any of the above requests by completing and sending the relevant form to:
ALPHA TRUST-ANDROMEDA S.A. Portfolio Investment Company
Head Office: 1 Aristeidou St., Kifissia, P.C. 14561
Tel.: +30 210 62 89 100
Email: [email protected]
The Company is committed to responding to your requests within one month from submission. If, however, we are unable to fulfill your request within this timeframe, we will inform you accordingly and provide the reason.
Andromeda understands your concerns regarding your personal data. For any related information, feel free to contact us at:
Email: [email protected]
Right to Lodge a Complaint
If you have exercised some or all of your data protection rights and still feel that your concerns regarding how we use your personal data have not been satisfactorily addressed, you have the right to lodge a complaint.
You also have the right to file a complaint with the Hellenic Data Protection Authority (HDPA), located at Kifisias 1-3, Postal Code 115 23, Athens. Information on how to submit complaints can be found on their official website: http://www.dpa.gr.
Changes to This Privacy Policy
We may from time to time change or modify this Policy, and we will accordingly update the revision date indicated at the end of this Policy. We recommend that you review this statement periodically to stay informed about how we process and protect your personal information.
Last revision of the Policy: December 29, 2022.
