Subject

This Website Trackers Policy (hereinafter the “Policy“) aims to provide information regarding the use of trackers (such as cookies) used on the website www.ktpae.gr (hereinafter the “Website“), the information collected through them and the way they are used by the single-member société anonyme under the name “INFORMATION SOCIETY S.A.” (hereinafter “IS S.A.” or “we” or “us“). IS S.A. manages the tracker data of its Website with respect for the privacy of its visitors (hereinafter “you”, “your”) and transparency regarding its operation. You may find detailed information about the processing of your personal data by IS S.A. in the Privacy Policy of IS S.A.

Scope

This Policy applies to the official Website of IS S.A. (www.ktpae.gr) and concerns all visitors and users browsing it.

Definitions

According to the General Data Protection Regulation (GDPR), and generally accepted international practices, for the purposes of this Policy, the key terms used are defined 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 determined, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Tracker”: Trackers are an umbrella term that includes any software, code or technology used to monitor, record and analyze activity on the internet. Their purpose is usually to create profiles for targeted advertising or to analyze statistical data (analytics). Cookies are only one type of tracker.

“Third Parties”: Any natural or legal person, public authority, service or other body (excluding Employees and Management of IS S.A.) that contracts with IS S.A. through a project agreement, provision of independent services or other legal relationship. Third Parties include, indicatively and not exhaustively: external partners, contractors, consultants, suppliers, technical support and maintenance providers, auditors, as well as any other person to whom IS S.A. provides temporary or permanent access to Corporate Equipment for the execution of a specific purpose.

“Applicable Legislation”: Applicable Legislation includes (a) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), (b) Greek Law 4624/2019 and (c) the decisions, guidelines, opinions and recommendations of the European Data Protection Board (EDPB) and the Hellenic Data Protection Authority (HDPA), in particular the recommendations no. Γ/ΕΞ/1525 on compliance with electronic communications legislation.

“Cookies”: Cookies are self-installing text files with short content that are stored on the user’s computer or other electronic devices (e.g. mobile phones, tablets, etc.) when visiting a website. In this way, the website remembers the user’s/visitor’s actions and preferences (e.g. language, font size and other display preferences) for a certain period of time.

Roles – Responsibilities

IS S.A.

IS S.A. is responsible for the lawful operation of its Website, ensuring that non-essential Trackers are installed only after the user’s consent.

Users / Website Visitors

They are responsible for managing their personal preferences. They have the ability to modify their browser settings to receive notifications, reject the use of Trackers or withdraw their consent at any time.

Policy

A. Strictly Necessary Cookies:

These Cookies are essential for the proper functioning of the Website, allowing you to browse and use its features, such as access to secure areas. These cookies are necessary for the operation of the Website and without them it would not be technically possible to provide its services. Therefore, these Cookies are enabled by default for as long as you browse the Website, without requiring consent.

B. Functionality Cookies:

These Cookies allow the Website to remember choices you make (e.g. language) and provide enhanced features. They are installed only after you provide your consent. A table of functionality cookies follows.

C. Analytics Cookies (third-party) and other technologies:

These Cookies collect information about the user/visitor of the Website and enable improvement of its operation. This data helps monitor Website performance, measure visits, track how users access the Website, etc. They are installed only after you provide your consent. A table of analytics cookies (third-party) follows.

D. Performance Cookies:

These Cookies collect information regarding the use of the Website, e.g. which pages you visit most often and whether you receive error messages. These Cookies do not collect information that identifies you, as the data is aggregated and remains anonymous. They are used only for statistical purposes to improve Website functionality. They are installed only after you provide your consent. A table of performance cookies follows.

E. Security Cookies:

These Cookies are used for security purposes (prevention of cyberattacks and any other malicious activity). They are installed only after you provide your consent. A table of security cookies follows.

Processing of Personal Data

A. Categories of Data Subjects

Through the Website’s trackers, Personal Data of visitors/users is collected and further processed.

B. Categories of Personal Data

Through the Website’s trackers, the following categories of Personal Data are collected and further processed:

• IP address
• Metadata
• Consent status

C. Legal basis for processing

Your Personal Data is processed based on:

• The legitimate interest of IS S.A., when processing is carried out through “Strictly Necessary Cookies”. In particular, the legitimate interest lies in ensuring proper technical operation, security and availability of the Website. This processing is necessary for the provision of services requested by the visitor/user.
• Your consent, where provided, when processing is carried out through other categories of Cookies.

D. Transfers

As a rule, Personal Data collected through the Website is stored and processed within the European Union (EU) and the European Economic Area (EEA). However, certain third-party service providers (such as web analytics and social media providers) may be established in or process data in third countries outside the EU/EEA (e.g. USA). In such cases, IS S.A. ensures that such transfers are carried out in full compliance with Applicable Legislation, adopting appropriate safeguards such as adequacy decisions by the European Commission or Standard Contractual Clauses (SCCs).

E. Rights

Under the conditions provided by applicable law, you have the following rights:

• Access
• Rectification
• Erasure (“right to be forgotten”)
• Restriction of processing
• Objection
• Data portability
• Withdrawal of consent
• Lodging a complaint with the HDPA

Cookie Management

You may always modify your browser settings to reject or accept the use of Cookies. In this case, if you do not allow the use of Cookies for certain services, you may not have further access to them.

You may also withdraw your consent for the use of cookies by deleting them from your browser’s memory.

You can learn more depending on your browser using the following links:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Safari
• Opera
• Adobe (flash cookies)

For more information about cookies and how to block or restrict them, you may visit: https://www.webtoffee.com/

You can modify your cookie preferences through the following link: Preferences, located at the bottom of your screen.

For more information about the processing of your Personal Data, please visit the Privacy Policy of IS S.A.

Last Revision: January 2022