Privacy Policy

Resolute Cepal Greece S.A. (“RCG”/ “we”) collects and processes personal data as a Data Controller, for the purposes described in this Privacy Policy in accordance with the General Data Protection Regulation ("GDPR") and the applicable Greek legislation, including Law 4624/2019 on the protection of personal data, while taking the appropriate technical and organizational measures to protect personal data.

RCG’s data obligations are regulated by the Hellenic Data Protection Authority ('HDPA') (www.dpa.gr) with regards to the treatment of all data received and processed. The HDPA does not require the Company’s formal registration.

If we receive your personal information then we are the Controller of that data, which may be collected:

through our website,
when you visit our offices, or
when you become our client.

RCG respects your privacy and is committed to protecting your personal data, as well as in general keeping all information collected confidential.

We will not lend or sell your information to third parties.

This Privacy Policy explains how we collect and use your personal data and tells you about your privacy rights and how the law protects you.

Contact details

Resolute Cepal Greece S.A.
8 Xenofontos Street
P.C. 10557, Athens, Greece
https://resolute-cepal.com

As RCG is not a public authority and does not have core activities consisting of large scale processing of special categories of data or requiring large-scale, systematic monitoring of individuals, we are not legally obligated to appoint a Data Protection Officer, however, we do have a Data Governance Officer, responsible for handling all data protection and privacy-related issues. The contact details are as follows:

Telephone: +30 210 325 4147

E-mail: dgo@res-cep.com

This is primarily information about our clients, visitors to our website and any other third party linked to our Company. There will also be some personal data in client information we will collect from time to time. All client information is confidential. It will remain so.

Our policy is to treat all personal data to the same high standard as follows:

What information do we collect about you and why?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We will only use your personal data when the law allows us to. We may collect, use, store and transfer different kinds of personal data about you on the basis that it is in our legitimate interests to do so in order to carry out our business (and your interests and fundamental rights do not override those interests), or to perform a contract with you, or to comply with legal or regulatory obligations, for example in order to comply with KYC/AML checks. We will collect personal information including identity data, contact data, financial data and technical data.

How long do we keep this information?

All collected information related to you will be stored in our secure servers in European Union. We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Who do we share your information with?

We will share your personal data and give access to authorized personnel from RCG, on a strictly need to know basis and only as far legally justifiable.

Our data is also managed by external providers such as internet companies and software companies. We share data only as far as legally permitted to do so and only as strictly necessary. Within RCG your information is processed and accessed only by specific individuals who provide IT and system administration services and also undertake leadership reporting, as well as the partners and other senior members of RCG. External third parties may include:

Our IT providers and service providers in order to provide IT and system administration services;
Our appointed professional advisers including auditors, accountants, lawyers, bankers, insurers who provide consultancy, banking, legal, insurance and accounting services, to the extent that they may require access to the information to provide advice;
Tax and regulatory authorities based in Greece who require reporting of processing activities in certain circumstances;
If required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
Relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law.

We wish to inform you that we require from all our employees and third parties to respect the security of all personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

RCG does not transfer personal data to any third countries outside the European Economic Area and international organizations. However, in exceptional cases, RCG may transfer personal data outside the EEA provided such transfer is required by the applicable regulatory or legislative framework or RCG deems it as necessary for the performance of its contractual obligations, such as via processors who may use. In this case we will ensure that there is an appropriate level of protection corresponding to the level of protection of personal data in the EEA and that the transfer in question is lawful on condition that there is an adequacy decision of the European Commission or the required guarantees of Articles 44-50 of the GDPR are provided, such as the European Commission's Binding Corporate Rules or Standard Contractual Clauses.

RCG does not apply any automated decision-making process. No automated processing of certain data for the purposes of evaluating certain aspects (limited profiling) is done without human intervention.

Data subjects are entitled to oppose at any time to personal data processing for marketing purposes, including profiling, by contacting with the Company in writing at dgo@res-cep.com.

In the future we may choose to sell, transfer, or merge parts of our business or our assets. We may seek to acquire other businesses or merge with them. In such case, we may share your information with such new owners (third parties). Should such a change happen to our business, then we will ensure the new owners use your personal data in the same way as set out in this privacy policy.

Your rights

In relation to the collection and processing of data, you have the following rights:

Right of Access: You can request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a free copy of the personal data we hold about you and to check that we are lawfully processing it.
Right to Rectification: You can request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to Erasure: You can request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object: You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to Restriction of Processing: You can request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to Data Portability: You can request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to Withdraw Consent: You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right not to subject to automated individual decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You may exercise the abovementioned rights by sending your request at the following email: dgo@res-cep.com or by post at the following address: Attention to Data Governance Officer, Resolute Cepal Greece S.A., 8 Xenofontos Street, Athens, P.C. 10557, Greece.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we reserve the right to charge a reasonable fee if your request is clearly repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within 30 days from their receipt except for exceptional cases, where the above-mentioned period may be extended for two (2) more months, if necessary, considering the complexity of the request and/or the number of requests. In this case, RCG will inform you about any extension within the month of the delivery of the request, as well as about the reasons for such delay.

You have the right to make a complaint about the way in which we handle your personal data at any time to the Hellenic Data Protection Authority at contact@dpa.gr (1-3 Kifissias Avenue, Ampelokipi, www.dpa.gr, +30 2106475600).

We would, however, appreciate the chance to deal with your concerns before you approach the HDPA, so please contact us in the first instance.

Data security

We ensure all our third-party providers of services or data processing have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. You should be informed about how these third parties process your personal data by their relevant privacy policies.

Changes to this Privacy Policy and your duty to inform us of changes to your information

This Policy was updated in March 2024. We may update this Privacy Policy from time to time. When we do so we will notify you of any significant changes.

It is important that the personal data we hold about you is accurate and current. We would be grateful if you would keep us informed if your personal data changes during your relationship with us.