PERSONAL DATA PROCESSING POLICY OF THE "GREEN CITY" SERVICE
This Privacy Policy ("Privacy Policy") is published on the website www.thegreencity.gr (the "Website") on the date indicated herein.
Southstar respects your personal data ("you" or the "User") and fully comply with the General Data Protection Regulation (EU 2016/679, "GDPR"), with Law 4624/2019, as well as with all provisions of the Personal Data Protection Law, and take the technical and organizational measures foreseen and available as provided therein.
The purpose of the Privacy Policy is to inform you about the processing of your Personal Data by Southstar.
The terms of this Privacy Policy may be changed at any time, with the Users' latest notification.
1. Definitions
The following terms have the corresponding meanings in the Privacy Policy:
(a) The term "Southstar" means the company named SOUTHSTAR S.A., located at 23 Kallirois Street, Athens.
(b) "Personal Data" means personal data as referred to in Article 4(1) GDPR. Personal Data shall in no case include special categories of data, in accordance with Article 9 GDPR.
(c) "Data Subjects" means natural persons as defined in Article 4(1) GDPR. In any case, the Privacy Policy is addressed to adults, and Southstar does not process Personal Data of minors.
(d) "Data Protection Authority" means the Personal Data Protection Authority, Kifissia 1-3, www.dpa.gr
Otherwise, (a) the definitions of the Terms of Use of the "Green City" Service, as published on the Website, and (b) the definitions of article 4 of the GDPR apply.
2. Controller and Processor - Ways of communication
Southstar is a "controller" in accordance with Article 4(7) GDPR for all the processing of Personal Data in this Privacy Policy.
Southstar is a "processor" in accordance with Article 4(8) GDPR for all the Personal Data processing of this Privacy Policy.
Southstar's contact details, in case you wish to exercise your rights under the Data Protection Law in relation to this Privacy Policy or for any comments, remarks or questions, are as follows:
Address: 23 KALIRROIS 23 ATHENS, GREECE, ZIP CODE 11743
Phone: 2106424100
e-mail: info@southstar.gr
Southstar, as the processor, complies with the provisions of the Data Protection Law that apply to it. In any case, it undertakes to forward any request, comment or observation you may make to ESDNA, as controller.
3. Purposes and legal bases of processing
Southstar processes Users’ Personal Data for the following purposes:
a) for the creation and management of a User Account in the Application;
b) for the identification of the User when using the Service, including through a card, QR code or other unique identifier;
c) for recording the User’s participation in the “THE GREEN CITY” programme, including the weighing of recyclable materials, the accumulation of points, the redemption of points, and the use of offers, privileges, bonuses, coupons or other benefits;
d) for informing the User about the operation of the Application, collection points, routes, service availability, technical or operational changes, as well as any other information necessary or useful for the provision and use of the Service;
e) for sending informational, commercial, promotional or other related material concerning the Application, the Service, the rewards programme, the accumulation or redemption of points, offers, privileges, promotional discounts, bonuses, coupons, competitions, special campaigns or other benefits;
f) for informing the User about offers, promotional activities, informational materials, commercial communications, privileges or benefits offered by Southstar, the “THE GREEN CITY” Service, Partner Businesses, commercial partners, suppliers, sponsors or third-party businesses/entities, irrespective of whether such third parties participate on an ongoing basis in the Platform as Partner Businesses;
g) for Southstar’s compliance with obligations arising under applicable law, as well as for the establishment, exercise or defence of its rights and legal claims.
The legal basis for the processing for the above purposes is the User’s consent. The User may withdraw their consent at any time or opt out of receiving such communications in an easy and direct manner.
4. Duration of processing
Southstar retains and processes Users’ Personal Data only for as long as necessary to fulfil the purposes for which such data were collected and are processed, in accordance with this Personal Data Processing Policy, the Terms of Use of the Service and applicable law in force from time to time.
In particular, Personal Data processed for the creation, management and operation of the User’s Account, the identification of the User, the use of the Application, participation in the Service, the recording of weighings, the accumulation and redemption of points, the use of offers, privileges, bonuses, coupons or other benefits, as well as for the sending of necessary operational or technical communications, shall be retained for as long as the User’s Account remains active or for as long as required for the provision and proper operation of the Service.
In the event of the expiry, suspension or discontinuation of the Service, the deletion or deactivation of a User Account, or the withdrawal of the User’s consent, Southstar shall, as appropriate, delete or anonymise the relevant Personal Data or restrict their processing, unless their continued retention is necessary for compliance with a legal obligation, the settlement of outstanding contractual or financial matters, the security of the Application, or the establishment, exercise or defence of the rights and claims of Southstar or third parties.
Personal Data processed for the purpose of sending informational, commercial, promotional or other related material, including communications regarding offers, privileges, promotional discounts, bonuses, coupons, competitions, special campaigns or other benefits offered by Southstar, the “THE GREEN CITY” Service, Partner Businesses, commercial partners, suppliers, sponsors or third-party businesses/entities, shall be retained and used for such purpose for as long as the User maintains the relevant preference or consent active and, in any event, until such consent is withdrawn, the User exercises their right to object, or the User unsubscribes from receiving the relevant communications.
In the event of withdrawal of consent, objection or unsubscribing from informational, commercial or promotional communications, Southstar shall cease using the relevant User contact details for such purpose. The withdrawal of consent or unsubscribing shall not affect the lawfulness of processing carried out prior thereto and shall not affect the ability to send necessary operational, technical or informational communications relating to the operation of the Application, Account security, the management of points or the provision of the Service.
Southstar may retain limited records documenting the User’s consent, withdrawal of consent, objection or unsubscription, including, indicatively, the date and time of the relevant action, the means through which it was carried out and its subject matter, solely for the purposes of compliance with applicable law and demonstrating that the relevant User request or preference has been recorded and complied with.
Exclusively for the purposes of compliance with legal obligations, transaction record-keeping, auditing, security, request management, and the establishment, exercise or defence of rights and legal claims, Southstar may retain the necessary Personal Data for as long as required under applicable law or until the expiry of the relevant limitation period, subject to a maximum retention period of twenty (20) years, unless a different retention period is provided for by a specific provision of law or by a final decision of a competent authority or court.
Upon expiry of the aforementioned retention periods, Personal Data shall be securely deleted or anonymised, unless their further retention is required or permitted under applicable law.
5. Recipients
Southstar does not generally disclose or transfer Personal Data to third parties.
However, Southstar may outsource to third parties, sub-processors, the processing of your Personal Data in order to better operate the Application and provide the Service. The sub-processors may not further process your Personal Data nor are they allowed to transfer your Personal Data to third parties.
Southstar may also transfer Users' Personal Data in cases expressly provided for in applicable legislation, such as, but not limited to, where the disclosure of personal data must be made to a competent public authority in order to comply with a legal obligation.
For the purposes of sending informational, commercial, promotional or other related material, Southstar may use third-party technical service providers, including, indicatively, providers of email, SMS, Viber and push notification services, hosting services, technical support services, campaign management services or communication automation tools. Such providers shall act, as applicable, as processors or sub-processors on behalf of Southstar and shall process Personal Data solely in accordance with Southstar’s instructions and for the purposes set out in this Policy.
Southstar does not disclose or transfer Users’ contact details to Partner Businesses, commercial partners, suppliers, sponsors or third-party businesses/entities for their own independent marketing purposes, unless the User has provided specific consent or another lawful basis for such disclosure or transfer exists under applicable law.
Southstar may itself, through the Application or through its technical service providers, send informational, commercial or promotional material concerning offers, privileges, promotional discounts, bonuses, coupons, competitions, campaigns or other benefits offered by third-party businesses/entities, without requiring, for this purpose, the disclosure or transfer of the User’s contact details to such businesses or entities.
6. Transfers outside the EU
Southstar does not transfer Personal Data outside the EU. Especially in the case of internet social media (Facebook, Twitter, YouTube, Flickr) Southstar applies the provisions of the Data Protection Law and the decisions of the competent national and European institutions, as applicable.
7. Safety measures
Southstar implements appropriate technical, material and organizational security measures in order to protect Users' Personal Data against accidental or unlawful destruction or accidental loss, alteration, unlawful disclosure or access (including remote access) and against all other forms of unlawful processing (including unnecessary collection or further processing). These measures shall ensure a level of security appropriate to the risk, taking into account the evolution of technology, the cost of implementation and the nature, scope, context and purposes of the processing.
8. Your rights
Any natural person, in particular Users, may submit a request to Southstar for access, rectification or erasure of their Personal Data or for restriction of processing or for the exercise of one of the data subject's rights of opposition or portability.
In particular, each User may at any time withdraw the consent of Article 3 of this Privacy Policy. The revocation is valid for the future.
Also, any User may make a modification to the means and manner or content of Southstar's communication with him/her either through the Application or through the Website.
Each request shall be submitted exclusively and only by one of the above mentioned communication methods of Article 2 of this Privacy Policy.
The satisfaction of any request regarding the processing of your Personal Data will be done in accordance with the applicable legislation.
With specific regard to the sending of informational, commercial or promotional communications, each User has the right to withdraw their consent at any time or opt out of receiving such communications, without affecting the lawfulness of processing carried out prior to the withdrawal of consent.
Withdrawal of consent or unsubscribing may be carried out through the relevant unsubscribe link included in each promotional communication, through the User’s Account settings in the Application, or by contacting Southstar using the contact details specified in this Policy.
Following the withdrawal of consent or unsubscribing, Southstar shall no longer use the User’s contact details for the purpose of sending commercial or promotional communications, unless the User subsequently provides consent again or another lawful basis for such processing exists under applicable law.
The withdrawal of consent to receive commercial or promotional communications shall not affect the User’s ability to receive necessary operational or technical communications relating to the use of the Application, the security of their Account, the management of their points, or the provision of the Service.
9. cookies
- Southstar uses cookies, in accordance with standard internet practices, to facilitate and improve Users' access to and browsing of the Site, to obtain certain information about the Site, and to serve personalized advertisements.
- Cookies, pixel tags and similar technologies (collectively called "cookies") are files containing small amounts of information that are downloaded to any Internet-enabled device - such as your computer, smartphone or tablet - when you visit a website. The cookies are then sent back to the website from which they originated on each subsequent visit or to another website that recognizes that cookie. Cookies do many different and useful things, such as remembering your preferences, generally improving your online experience and helping us to provide you with the best products and services. Some cookies are strictly necessary for the proper functioning of the Internet and do not require user consent, such as those that ensure that the content of a page loads quickly and efficiently by spreading the workload across multiple computers or on computers that provide security. Other cookies are still reasonably necessary or important, but are not strictly necessary and therefore require the user's consent.
- The Website uses the following types of Cookies, as listed in the table below:
Α. Necessary Cookies
These Cookies are necessary for the proper functioning of the Website and cannot be disabled. You can set your browser to block or warn you about these Cookies, but some parts of the Website will not work afterwards. These cookies do not store Personal Data. The Necessary Cookies that we may use on our Website are as follows:
|
Cookie name |
Description |
Domain |
Default state |
|
XSRF-TOKEN |
Protection for forms sent by the user. |
https://thegreencity.gr |
Always Active |
|
referral-registration |
It is used for user identification to take advantage when recommending a user. |
https://thegreencity.gr |
Always Active |
|
lslb_backend |
Necessary for connecting the loadbalancer to the correct backend. |
https://thegreencity.gr |
Always Active |
|
thegreencity_session |
Necessary for users to connect |
https://thegreencity.gr |
Always Active |
|
the_green_city |
Saves the cookie options |
https://thegreencity.gr |
Always Active |
|
MicrosoftApplicationsTelemetryDeviceId |
Microsoft sets this cookie to install a unique device ID that is used to track how users behave and interact with the Microsoft application on the device. |
https://thegreencity.gr |
Always Active |
|
forgot_password_sms_cookie |
Restricting malicious use of the Forgot my password form |
https://thegreencity.gr |
Always Active |
|
desktop_location |
Stores the current physical location of the user with his/her approval. |
https://thegreencity.gr |
Always Active |
|
popupad |
Used to show informative messages to users (photos or video). |
https://thegreencity.gr |
Always Active |
|
z_AppKit-Visited: |
Use for styling |
https://thegreencity.gr |
Always Active |
|
z_Appkit-Visited-Scroll-Position |
Use to go to the previous position on the page |
https://thegreencity.gr |
Always Active |
B. Performance Cookies (Analytics)
Performance Cookies collect information about the use of a specific website and allow us to improve the way it works. The Performance Cookies that may be used on the Website are the following:
|
Cookie name |
Description |
Domain |
Default state |
|
__ga |
Google Analytics: It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. |
https://thegreencity.gr |
|
|
__gid |
Google Analytics: stores and updates a unique value for each page visited. |
https://thegreencity.gr |
|
|
_gat_gtag_ |
Google Analytics Used to limit the percentage of requests. It compiles information about how visitors use the site. |
https://thegreencity.gr |
10. Data Protection Authority
The competent authority for any comments you may have on this Privacy Policy is the Data Protection Authority.
