POLICY APRIVACY AND DATA PROTECTION

 

Α. GENERAL SECTION INTRODUCTION

 

RECOM REPOWER S.A. attaches great importance to the harmonization of its practices with the legislation in force. In this context, it maintains and processes your personal data with confidentiality and respect for your privacy, constantly taking the necessary technical and organizational measures to further protect them, modifying its security and processing policy, in accordance with the General Data Protection Regulation of the European Union (GDPR).

This Privacy Policy (hereinafter "Policy") concerns the conditions of collection, storage, retention, processing and use of your personal data by RECOM REPOWER SA (hereinafter "RECOM REPOWER SA").

 

TERMS / CONCEPTS

The basic definitions of the terms and concepts to be used in this document, as referred to in Article 4 of the General Data Protection Regulation 2016/679/EU, are as follows:

Personal Data: Any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one whose identity can be established, directly or indirectly, in particular by reference to an identifier such as a full name, an identification number and/or passport number, tax data, location data, an online identifier or one or more factors that are relevant to the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

Special Categories of Personal Data (sensitive): Personal data which are by nature particularly sensitive in relation to fundamental rights and freedoms are considered sensitive and therefore require special protection, as the context in which they are processed could pose significant risks to fundamental rights and freedoms. Such personal data include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of positive identification of a person, data concerning health or data concerning the sex life of a natural person or sexual orientation.

It is clarified that all personal data of minors under the age of 16 are by definition sensitive and are treated as such.

Processing: any operation or set of operations which is performed, whether or not by automated means, on personal data or on sets of personal data (whether or not sensitive), such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processing Manager: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processor: the natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Every organisation regardless of its type, legal form and size holds and processes personal data and is called a controller.

Any natural or legal person in the public or private sector who processes data on behalf of a controller is called a processor.

(For example, an accounting firm to which the organisation outsources the payroll of its employees).

Recipient: the natural or legal person, public authority, agency or other body to whom the personal data are disclosed, whether or not a third party. However, public authorities which may receive personal data in the context of a specific investigation in accordance with Union or Member State law shall not be considered as recipients; the processing of such data by those public authorities shall be carried out in accordance with the applicable data protection rules, depending on the purposes of the processing.

 

Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects of an individual, in particular to analyse or predict aspects relating to the job performance, financial situation, health, personal preferences, interests, reliability, behaviour, location or movements of that individual.

 

Authority: The Data Protection Authority (DPA).

RECOM REPOWER SA is designated as a controller and strictly complies with the data protection principles set out in Article 5 of the General Data Protection Regulation.

 

Β. SPECIAL PART

 

  1. WHAT IS THE PURPOSE OF THE BUSINESS?

The main purpose of RECOM REPOWER AE is, among other things, the production of electricity from photovoltaic systems.

 

  1. WHAT IS PERSONAL DATA?

The term "personal data" or "personal data" or "data", as used in this Policy, refers to information of natural persons (such as full name, patronymic, maiden name, maiden name, postal address, postal code, contact telephone number (landline/mobile), e-mail address, ), hereinafter "Personal Data or Data".

 

  1. WHAT IS THE PROCESSING OF PERSONAL DATA?

Processing of Personal Data is any operation or series of operations carried out with or without the use of automated means, either in electronic form (soft copy) or in hard copy, on personal data, such as the collection, recording, organisation, classification, structuring, storage, adaptation, alteration, modification, retrieval, search for information, use, transmission to third parties, dissemination, association, combination, restriction, erasure and destruction of Personal Data of natural persons.

 

  1. WHAT DATA DO WE COLLECT FROM YOU?

RECOM REPOWER SA collects all the necessary data of its counterparties (its customers) for the preparation and execution of the contract for the provision of its services or for the realization of the communication between us with your explicit consent, and in particular:

A) In the context of an upcoming or existing business relationship with RECOM REPOWER SA, the Company may process the following categories of personal data of its business partners:

(a) Identity and contact details, such as name, full name, VAT number, tax office, address, telephone number, mobile phone number, fax number, e-mail address provided to us by the contractor or its representative for the purpose of identification and communication with us.

(b) Specifically for the energy sector, details of the photovoltaic equipment installation lease, title deeds, copies of contracts, extracts of land registry maps, copies of land registry sheets, a copy of a land registry share, accounts or previous supplier's accounts, electricity and gas consumption data obtained from customers and/or relevant managers, bank account numbers that you provide to us, details of transactions and payment execution made to the

(c) Any creditworthiness and integrity data (information regarding court cases or other legal proceedings against business partners) collected from publicly available sources, databases and credit rating agencies in the case of financing.

B) When visiting and browsing the website https://re-power.com/

When you browse https://re-power.com/ we collect anonymous information such as your IP address, your geographic location (via GPS) and basic web log information such as your browser type and/or the operating system of your mobile device and the pages you browsed/browsed on the website, browser language, date and time of the service offer to a User, etc. We may identify the pages that led you to our software, although we do not associate this information with your personal information.

C) Information from communications

You acknowledge that RECOM REPOWER SA may keep a record of written letters, e-mails or other messages and generally any written communications you have exchanged with RECOM REPOWER SA for any reason whatsoever and specifically in relation to your cooperation with RECOM REPOWER SA.

Furthermore, you agree that it records and keeps it on file for security reasons and for the purpose of ensuring compliance with the Terms of Use of the Application and for quality reasons of your communication as a User of the Website.

D) Transaction information via the website https://re-power.com/

During your visit and navigation on the website of RECOM REPOWER SA, apart from the above, we do NOT collect your Data, but only those collected by the cookies that you have allowed through your consent to be used and specifically, the only cookies used by the page belong to the categories:

(j) Necessary Cookies; and

(ii) Functionality Cookies, both of which are necessary for the proper functioning of the website.

(iii) Advertising Cookies

v) Cookies AAnalysis

 

The information they collect is anonymous and they do not track browsing activity on other websites.

 

  1. FOR WHAT PURPOSE WE PROCESS YOUR DATA

We collect your Data solely for the purposes of:

(a) the service provided by RECOM REPOWER SA for the purpose of either the preparation and execution of the contract between us or for the realization of the communication between us, with your express consent.

(b) sending informative messages by e-mail, SMS or other electronic means about general offers.

(c) sending you special offers that are exclusively applicable to you.

(d) RECOM REPOWER SA 's compliance with the obligations imposed by the applicable legislation e.g. issuance of tax documents etc.

We may use your Personal Data to create anonymous information files and/or to provide third parties with benchmarking and aggregate statistics about our Services. Benchmarking and aggregate statistics are anonymous and do not contain personally identifiable information, nor are they transferred or sold to third parties in any way or form that identifies or makes you identifiable.

We use your browsing data to operate and improve the website, to diagnose problems with our server and to manage the software, to gather demographic and statistical data, for better advertising and layout on the website, to facilitate your identification during a specific session, etc. Your IP address does not contain any personal information about you.

We use User/Customer reviews in order to inform Customers about the quality of your work and the services you provide.

RECOM REPOWER SA does not use the data for purposes other than those related to the proper provision of our services and security, always with a view to providing high quality services and the compliance of our company with the applicable legislation.

 

  1. CONNECTIONS TO THIRD PARTY SITES

The website https://re-power.com/ may provide links to other websites or applications (e.g. social media), maintained by third parties. Links to any such third party website or application are provided for your convenience only.

RECOM REPOWER SA bears no responsibility for the content of any linked website or application nor is it responsible for any data they may collect.

RECOM REPOWER SA does not endorse or make any representations about these linked websites or any information, software or other products, services or materials found there, or any results that may arise from their use. If you decide to access any third party website linked to this website, you do so entirely at your own risk.

 

  1. WHAT IS THE LAWFUL BASIS FOR THE PROCESSING OF DATA BY THE RECOM REPOWER AE

The processing of data is done for the execution of any contract between us for the provision of our services, for informing you about RECOM REPOWER SA activities towards you, the security of transactions and our customers, as well as for the communication of RECOM REPOWER SA with you, only with your explicit consent, written or electronic.

 

  1. THE DATA ARE USED FOR OTHER PURPOSES E.G. FOR PURPOSES OF PROMOTING PRODUCTS AND/OR SERVICES?

RECOM REPOWER SA does not use the Data for purposes other than those mentioned above, which are related to the proper provision of our services, with a view to providing high quality services and the compliance of our company with the applicable legislation.

 

  1. WHO ARE THE DATA RECIPIENTS

We collect and process your personal data only with your explicit consent and to the extent that this is strictly necessary. Recipients of the Data are the absolutely necessary staff of RECOM REPOWER SA (regardless of whether they are linked to it by a dependent fixed-term or indefinite employment contract, semi-employment, project contract or other form of employment relationship) as well as its subsidiaries and the staff of its subsidiaries, its external collaborators, contractors, contractors' assistants and contractors, who are aware of and bound by this Protection Policy and the Privacy Policy and, in addition, are bound by confidentiality obligations.

RECOM REPOWER SA, is the recipient of the transmission of personal data of visitors / users / customers / subscribers for storage and further processing.

In addition, RECOM REPOWER SA may provide, with your consent, access to your contact details (mobile phone or e-mail) to external Partners under contracts in order to create personalized offers of products and services depending on the scope of these Partners). Such communication will only concern the above mentioned contact details (name, mobile phone and e-mail) and not the whole of your personal data and exclusively for the purposes of promotion and promotion of services and products with special personalized offers addressed to RECOM REPOWER SA subscribers.

Notwithstanding the above, we will NEVER sell, rent, distribute, or disclose in any way, your personal data unless required by law.

 

  1. HOW DO WE ENSURE THAT THE PROCESSORS RESPECT YOUR PERSONAL DATA?

The Processors have agreed and contractually committed with RECOM REPOWER SA:
- to maintain confidentiality,

  • not to disclose to third parties Data without the express permission of RECOM REPOWER SA,
  • take all appropriate security measures,
  • comply with the legal framework for the protection of personal data and in particular with the GDPR Regulation.
  • RECOM REPOWER SA takes all appropriate technical and organizational security measures to ensure that the personal data processed are accurate and, when necessary, updated immediately.
  • RECOM REPOWER SA takes all necessary measures to ensure that data that are inaccurate or incomplete are deleted or corrected immediately. The personal data processed are appropriate, proportionate and relevant to the needs of the service offered to the customer, the fulfillment of the contractual obligations on both sides and are collected only for specified, explicit and legitimate purposes, as indicated above and in the relevant contracts.
  • The processing of personal data by RECOM REPOWER SA is carried out in a manner that ensures its confidentiality and follows rules and other procedures to protect personal data from any unauthorized access, misuse, alteration, unauthorized disclosure, disclosure, loss or accidental/unlawful destruction and any other form of unlawful processing. RECOM REPOWER SA implements technical and organizational security policies and procedures in order to protect the personal data it collects from possible breach, loss, misuse, alteration or destruction.
  • Internal audits of the personal data processing procedures are regularly carried out by RECOM REPOWER SA in order to review the effectiveness of the measures applied for the protection of personal data.
  • Specially authorised persons have access to the data processing systems through which personal data are processed or used only in accordance with the instructions of RECOM REPOWER SA.The data processing systems cannot be used by unauthorised persons, the persons authorised to use the data processing systems have access only to the data for which they have been authorised, the personal data cannot, during the processing, be used for any purpose other than the processing of personal data.
  • Access to personal data is limited to those who are authorized in the context of their duties to RECOM REPOWER SA, provided that there is a need to know them. The persons who have access to the data are obliged to respect the confidentiality of these data.

 

  1. HOW LONG WILL YOUR DATA BE KEPT?

As a general rule, all personal data of the data subjects are deleted/destroyed upon termination of our contractual relationship, unless the express consent of the data subjects has been obtained for a certain or indefinite period of time.

The retention period of the Data is also determined by the retention obligation imposed by the current legislation governing the contractual and tax obligations of RECOM REPOWER SA.

Exceptionally, it is possible to extend the period of data retention for the purpose of proving before the courts the fulfilment of contractual obligations by the company or in case required by a rule of law or compliance with the instructions of Public or Independent Authorities.

 

  1. IS YOUR DATA SAFE?

RECOM REPOWER SA is committed to safeguarding your Personal Data.
We have taken appropriate organizational and technical measures to ensure the security and protection of the Data from any form of accidental or unlawful processing. The security measures are reviewed and modified whenever necessary to meet the requirements and specifications set by the applicable legislation.

Indicatively and not restrictively, the following rules describe how and where the data is kept. Data kept in colour files shall be kept in a place where unauthorised persons cannot see them. The same applies to records which are kept electronically but which for some reason have been printed out.

Important points are the following:

  • The files and the colour data shall be kept in a lockable filing cabinet.
  • Employees are confident that printouts are not left where unauthorized individuals could have access, such as in or near the printer.
    - Printed data that is not in use is destroyed. Where data is stored electronically, it shall be protected against unauthorised access to it, accidental destruction and attempts at interception. In particular:
  • Data is protected by strong passwords, which are changed frequently and not disclosed to non-designated employees.
  • In case the data is stored on portable media (such as CDs, etc.), it is stored securely when not in use.
  • All servers and computers containing data are protected by approved software and firewall software.
  • The processing of your Data is permitted only to persons authorised by us, our employees and partners exclusively for the purposes mentioned above.
  • RECOM REPOWER SA carries out regular audits and inspections to verify data security and the implementation of the Policy.

 

  1. WHAT ARE YOUR RIGHTS?

You have the right to access your personal data.

This means that you have the right to be informed by us if we process your Data. If we process your Data, you can request to be informed about the purpose of the processing, the type of your Data we hold, who we give it to, how long we store it, whether automated decision-making is taking place, and your other rights, such as rectification, erasure, restriction of processing and lodging a complaint with the Data Protection Authority.

You have the right to correct inaccurate personal data.

If you find that there is an error in your Data, you can submit a request to us to correct it (e.g. correction of your name or update of a change of address).

You have the right to erasure/right to be forgotten.

You can ask us to delete your data if it is no longer necessary for the processing purposes mentioned above.

You have the right to portability of your Data.

You may request to receive the Data you have provided in a readable form or request us to transfer it to another controller.

You have the right to restrict processing.

You can ask us to restrict the processing of your Data for as long as your objections to the processing are pending.

You have the right to object to the processing of your Data.

You may object to the processing of your Data or withdraw your consent and we will stop processing your Data, unless there are other compelling and legitimate reasons that override your right.

 

  1. HOW CAN YOU EXERCISE YOUR RIGHTS?

In order to exercise your rights you can send us a request, describing the right you wish to exercise, either to our Company's postal address which you will find on our website https://re-power.com/ with the indication "Exercise of the right of access/correction/deletion/restriction/objection", or to the e-mail address dpo@re-power.com with the title "Exercise of the right of access/correction/deletion/restriction/objection", with a description of your request and we will take care to examine it and reply to you as soon as possible.

 

  1. WHEN DO WE RESPOND TO YOUR REQUESTS?

We will respond to your requests free of charge without delay, and in any case within (1) one (1) month of receiving your request. However, if your request is complex or there are a large number of requests, we will let you know within the month if we need to obtain an extension of another (2) two months, within which we will respond to you.

If your requests are manifestly unfounded or excessive, in particular because of their repetitive nature, RECOM REPOWER SA may impose a reasonable fee, taking into account the administrative costs of providing the information or performing the requested action, or refuse to comply with the request.

 

  1. WHERE CAN YOU CONTACT FOR THE DEVELOPMENT OF YOUR REQUESTS?

For more information you can call +30 2107001640 or email dpo@re-power.com using the title: "Request Evolution".

 

  1. DO WE USE AUTOMATED DECISION-MAKING/INCLUDING PROFILING WHEN PROCESSING YOUR DATA?

NO, we do not make decisions, or carry out profiling, based on automated processing of your Data.

 

  1. WHAT IS THE APPLICABLE LAW FOR THE PROCESSING OF YOUR DATA BY THE RECOM REPOWER AE;

We process your Data in accordance with the General Data Protection Regulation 2016/679/EU, and in general the applicable national and European legislative and regulatory framework for the protection of personal data.

 

  1. WHERE CAN YOU GO IF WE VIOLATE THE CURRENT LAW ON THE PROTECTION OF PERSONAL DATA?

You have the right to lodge a complaint with the Authority for the Protection of Personal Data - PERSONAL DATA PROTECTION (1-3 Kifissias Street, Athens/www.dpa.gr), if you believe that the processing of your Personal Data violates the applicable national and regulatory framework for the protection of personal data.

 

  1. HOW WILL YOU BE INFORMED OF ANY CHANGES TO THIS POLICY?

We will update this Policy whenever necessary to comply with the applicable national and European legislative and regulatory framework for the protection of personal data. If there are significant changes to the Policy or the way we use your Personal Data, we will post them prominently on our site 

We encourage you to periodically read this Policy to know how your Data is protected RECOM REPOWER SA is responsible for processing the personal data of individuals or sole proprietorships that it receives.


If you wish to contact us on any matter relating to the processing of your Data and the exercise of your rights, you can contact us at the following e-mail address : dpo@re-power.com

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