Welcome to the website of SARISA S.A. (hereinafter the “Website”).

This Website has been created by “SARISA SUB-CONCESSION OF KAVALA PORT PHILIPPOS II S.A” (the “Company”), a member of GEK TERNA Group, with registered offices at 85 Mesogeion Avenue, Athens 11526, Greece, for the purpose of providing information and services to visitors/users.

The Company acts as Data Controller for personal data collected through use of the Website and, where applicable, in the context of transactional, contractual, professional or other relationships with natural persons, in accordance with Regulation (EU) 2016/679 (GDPR) and applicable data protection legislation.

In this Policy, we provide information regarding the processing of personal data through the Website and general information on key categories of processing carried out by the Company.

Which data we process 

The personal data that we collect and further process during your use of the Website include the following:

  • Technical information collected during your visit to the Website, such as your IP address and other information related to your browsing activity on the Website. For detailed information regarding cookies and their management, please refer to the Cookies

 

  • Information you provide to us through the Website, including, but not limited to, identification and contact details, as well as any information contained in requests or messages that you send to us.

Furthermore, the Company processes only the personal data that are strictly necessary, depending on the nature of its relationship with each natural person, including the following:

  • Identification data, such as full name, Tax Identification Number (TIN), Identity Card Number or passport number, professional capacity/occupation, and date of birth.
  • Contact details, such as residential or business address, telephone number, and email address.
  • Financial and tax data, such as bank account details (IBAN), invoices, payment receipts, and insurance/tax-related obligations.
  • Data related to a contractual or business relationship, such as contract details and other information necessary for the establishment and management of the relevant relationship.
  • Professional or employment-related data, such as curriculum vitae (CV) information, employment record/employee registration number, payroll data, and performance evaluations.

Why We Process Your Personal Data and the Legal Basis for Processing

The Company processes your personal data in accordance with the following purposes and legal bases:

  • Performance of a Contract

When processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract.

  • Legitimate Interest

To safeguard and pursue the Company’s legitimate interests, the Company processes the personal data concerning you referred to above in order to ensure the uninterrupted, proper and secure operation of the Website, improve its functionality and user experience, maintain data backups, prevent fraud, protect and defend any legal claims, and generally ensure business continuity.

Also, based on our legitimate interest, we manage any general communication we receive from you in order to ensure our prompt and effective response to any request or inquiry that you submit through the Website’s contact form or through our other official communication channels.

  • Consent

Furthermore, where you provide your consent, subject to the specific conditions set out by applicable legislation, for example for the use of technologies such as cookies, information about you is automatically collected in accordance with the Cookie Policy available on this Website, for the purposes of analytics, personalization and/or advertising. You may change your cookie preferences at any time through the Website’s Cookie Policy and, more generally, withdraw any consent you have provided by contacting us at dpo@gekterna.com.

  • Legal Obligation

The Company will process your personal data where this is necessary for compliance with legal obligations arising under national or European Union law, such as disclosure obligations, the submission of information to supervisory authorities, and compliance with tax, employment, or social security obligations.

In addition, the Company is required to process your requests concerning the protection of your personal data and, more generally, to comply with any personal data requests received from competent police, judicial, or other supervisory authorities.

Who Are the Recipients of Your Data

The Company may, to the extent necessary for the fulfillment of the above processing purposes, disclose personal data to the following categories of partners, while always implementing strict confidentiality safeguards (e.g. cooperation agreements/data protection agreements) and security measures:

  • External partners/third-party service providers, such as companies providing Website support and management services, accounting or law firms, technical consultants, subcontractors, and other external partners assisting in the execution of projects or the provision of services.
  • Other companies within the GEK TERNA Group with which we cooperate for the fulfillment of the above purposes.
  • Competent administrative, judicial, supervisory, or other public authorities, as well as other persons, where disclosure is required or permitted by applicable law or pursuant to a relevant decision of a competent authority.

The Company has taken all necessary measures to ensure that its personnel and partners are specifically authorized for these purposes and are fully bound by confidentiality obligations and the requirements set out by applicable legislation regarding the collection and further processing of your personal data.

Transfer of Data to Third Countries

Please note that the processing of your personal data is carried out within the European Union. However, should the Company need to transfer data outside the European Union, any such transfer will take place only to countries that ensure an adequate level of protection for data subjects pursuant to a decision of the European Commission and/or in accordance with the appropriate safeguards provided for under EU Regulation 2016/679 (GDPR), as applicable.

Security of Your Data

The Company has adopted all appropriate organizational and technical measures, in accordance with technological standards and applicable laws and regulations, to ensure that the processing of personal data, whether carried out by the Company itself or by third parties on its behalf, is lawful, appropriate, and subject to an adequate level of security, so as to prevent any unauthorized or accidental access, processing, deletion, alteration, or other use thereof.

Retention Period of Your Data

The personal data processed by the Company are retained only for the period necessary to fulfill the purpose for which they were collected.

Upon fulfillment of the relevant purpose, the data are deleted or anonymized, unless their further retention is required by applicable law or is necessary for the establishment, exercise, or defense of legal claims.

Specifically:

  • Where processing is required pursuant to obligations arising from the applicable legal framework, your personal data will be retained for the period prescribed by the relevant legal provisions.
  • Where processing is carried out on the basis of a contract, your personal data will be retained for as long as necessary for the performance of the contract and, following its termination, for as long as required under applicable law or for the establishment, exercise, or defense of legal claims.
  • Personal data collected on the basis of your consent will be retained until you withdraw your consent, unless there is another lawful basis for their further retention.

Your Rights

In any case, we would like to inform you that, in accordance with the applicable legislation, you have and may exercise, following verification of your identity, the following rights:

  • the right to access your personal data, as well as information relating to their processing,
  • the right to rectify inaccurate data and complete any incomplete personal data,
  • the right to erasure (“right to be forgotten”),
  • the right to restriction of the processing of your data in the cases expressly provided for by law,
  • the right to data portability, allowing you to receive your personal data in a structured, commonly used, and machine-readable format, either for yourself or for transmission to another data controller,
  • the right to object to processing activities based on our legitimate interests as described above,
  • the right to withdraw any consent you have provided, promptly and free of charge, in the manner described above.

 

Contact Details

For any questions, clarifications, or requests regarding the protection of your personal data, you may contact the Data Protection Officer (DPO) directly at the following email address: dpo@gekterna.com.

Right to Lodge a Complaint

If you exercise any of your rights and your request is not satisfactorily addressed, you have the right to lodge a complaint with the Hellenic Data Protection Authority (HDPA) through its online portal (https://eservices.dpa.gr/). For further information, you may consult the website of the Hellenic Data Protection Authority (www.dpa.gr).

What Happens with Third-Party Websites?

The Website provides access to third-party websites through appropriate links. These links have been included solely for the convenience of Website users. The websites to which these links direct users are subject to their own terms of use and Privacy Notices.

The inclusion of such links does not constitute an endorsement or acceptance by the Website administrator of the content of the respective websites. The Website administrator bears no responsibility for their content, their privacy practices, or the accuracy of the materials available on them.

The Company has no control over websites owned by third parties or over their content, access to which may be provided through this Website or made available on it. Accordingly, the Company does not endorse, sponsor, advise on, or otherwise accept any responsibility for such websites or their content.

If the User decides to access any third-party website through the links provided on the Website, the User acknowledges and accepts that they do so at their own risk.

Amendmentsto this Privacy Policy

This Privacy Policy reflects the Company’s practices regarding the processing of personal data as implemented at the time of its publication. The Company may amend or update this Policy if there are material changes to its processing activities, the applicable legal framework, or its business operations and procedures.