Privacy Policy of COSMOS LAC S.A.

I. INTRODUCTION

1. General
   1. At COSMOS LAC S.A., we place great importance on the protection of your personal data and privacy. To ensure the lawful management of your data and to provide you with appropriate information regarding the ways and purposes for which we process it, we, the company under the name “KOSMOS LAC SPRAY PAINTS, VARNISHES, AND CHEMICAL PRODUCTS INDUSTRY S.A.”, trading as “COSMOS LAC S.A.”, headquartered in Kallithea, Attica, at 242 Syngrou Avenue, P.C. 17672, VAT number 094446114, General Commercial Registry number 121707002000, contact phone number +30 2262072011, and email support@cosmoslac.com (hereinafter referred to as the “Company,” “we,” or “us”), have adopted this Privacy Policy (hereinafter referred to as the “Policy”). This Policy is addressed to the users (“Users,” “you,” or “your”) of our website www.cosmoslac.com (hereinafter referred to as the “Website”) and its services.
   2. Below, you will find information regarding the terms under which we process the data collected and processed by the Company about you, including:

1. Information about us, the Data Controller, and our contact details for matters concerning your personal data.
2. The types of data we collect, store, share, and use.
3. The purposes and legal basis for processing.
4. The security measures we take to protect and store your data, as well as our data retention policy.
5. The recipients of your personal data.
6. Your rights and the ways to exercise them.

2. Data Controller & Contact Details
   1. We, the company COSMOS LAC A.E., are the Data Controller of your personal data.   
   2. Contact Information: Email: support@cosmoslac.com
   3. The Data Protection Officer (DPO) for our company is [name to be provided], and their contact information is support@cosmoslac.com.
   4. Inquiries & Requests: You can contact us using the above contact details to submit any comments, inquiries, requests, or complaints regarding this Policy and the collection and processing of your personal data. For more information on how we handle issues related to your personal data, please refer to Section III.9.
   5. This Policy includes the Cookies Policy and, therefore, both policies should be read as a unified document. By visiting the Website or using its services, including providing any personal data to us, you accept this Policy, which governs the collection, storage, use, and sharing of your personal and non-personal data and information. If you do not agree with the practices described in this Policy, please refrain from interacting with the Website.

II. COLLECTION AND PROCESSING OF PERSONAL DATA

3. General  
   1. We process your personal data lawfully and transparently. We collect only data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. The data collection is carried out for specified, clear, and lawful purposes – the data is not further processed for purposes that are incompatible with those for which it was collected.
   2. We do not share your data with third parties unless it is absolutely necessary for the performance of our services, you have previously provided your consent, or processing by third parties serves our legitimate interest (e.g., providing other services requested by you), or whenever required by law (for example, in the execution of a court order).
   3. We take every precaution to ensure that the data we collect is accurate and, where necessary, kept up to date. We do not knowingly collect or process personal data of individuals under the age of 18. If you are under 18 years old, please do not use the Website, request our services, or provide us with personal data.
   4. The management and protection of your personal data by us are governed by the terms of this Policy and the relevant provisions of European legislation regarding the protection of natural persons against the processing of personal data. Any future changes to the aforementioned regulatory framework will be incorporated into this Policy.

4. What Data We Collect About You Through the Website
   1. Through the Website, we collect various types of personal data, either directly from you or from third parties, such as (indicatively):
      1. Identity Data: (Name, Surname)
      2. Contact Data: (Phone, Email)
      3. Technical Data: (IP address, browser type and version, operating system, and platform, etc.)
      4. Cookie Data: (See Cookie Policy).
   2. We collect personal data directly from you:
      1. When you request our services (e.g., request information about our company, products, or wish to contact us, etc.).
      2. When you communicate with us through the Website.
      3. When you subscribe to the Website’s Newsletter service.
   3. We collect personal data about you from third parties when you voluntarily share your data on our social media pages or through them.
   4. We collect personal data about you through automated means:
      1. Via cookies that you accept (see Cookie Policy).
5. HOW and WHY we use your personal data collected through the Website
   1. The personal data you provide to us, either mandatory or optional through the Website, or that we collect from third parties via the Website, is processed for the lawful purposes outlined below. Specifically, we collect and process your data for the following purposes:

 a. Provision of Information and Services:

• To provide users with access to information, articles, updates, and other content available on the Website.

2. Interaction and Communication with Users:

– To facilitate user interaction, such as comments, feedback, and questions.

– To respond to user inquiries or requests submitted through contact forms or email.

3. Website Analysis and Performance:

– To analyze the use and performance of the Website to improve its content, design, and functionality.

4. Compliance and Legal Obligations:

– To comply with legal obligations, including data protection regulations.

– To ensure the security and integrity of the Website.

5. Marketing and Promotional Activities:

– To send newsletters, updates, and promotional materials (with the user’s consent).

6. Statistical and Business Analysis:

For other purposes, which will be communicated to you on a case-by-case basis or to identify you at the time your data is collected.

5.2  The legal basis for using your information is one of the following:

1. Compliance with a legal obligation to which we are subject,
2. Execution of a contract to which you are a party,
3. Our legitimate interest, which is fairly balanced against your interests in protecting your data,
4. Your consent, when none of the above applies (which we will request before processing your data).

Learn more:

5.3 When consent is the legal basis for processing your data, you can withdraw it at any time, and we will cease processing your data for the specific purpose. Please contact us using the contact details provided in Section 2 to withdraw your consent at any time.

5.4 When legitimate interest is the basis for processing, you have the right to object to such processing (opt-out) by contacting us. However, please note that the Company reserves the right to demonstrate compelling legitimate grounds for processing, which will be reasonably balanced against your rights and privacy protection.

5.5 To opt out of receiving commercial communications, such as our newsletter, you can click the “unsubscribe” button at the bottom of the email you received. Please do not use the “forward to junk or spam” option.

5.6 When we process your data for statistical purposes, we ensure that the collection and processing of your data is conducted in a manner that does not allow the identification of any specific data subject and does not infringe on your rights and freedoms, particularly your privacy.

6. With WHOM do we share your information and for what purposes?

Service Providers and Subcontractors: We may transfer the personal data you submit through our Website to other service providers, such as subcontractors we use to perform certain services (e.g., the hosting service provider, the development team for our Website, etc.)

• Redirecting to Other Websites: Upon your request and with your prior notification, you may be redirected to other websites, either managed by us or third parties, which collect your personal data. Once you are redirected to the other website, we do not share any data provided to us with third parties.

• Subsidiaries and Affiliates: We may also transfer the personal data you submit to us to our subsidiaries and/or affiliated companies, subject to appropriate contractual, technical, and organizational safeguards.

• Business Transfers: We reserve the right to disclose your personal data to third parties in case we decide to transfer all or part of our business. Furthermore, in the event of a merger, acquisition, or other business changes, the new owners, etc., have the right to use your personal data in the same manner we do under this Policy.

• Judicial, Police, and Administrative Authorities: Your data may be shared with competent judicial, police, and other administrative authorities upon their request and in accordance with applicable laws. Additionally, in the case of a legal requirement, service order, or official preliminary investigation, our Company has the right to provide all relevant information to the competent authority.

Data Transfers: Our Company generally retains and processes your personal data within the European Economic Area (“EEA”). We do not regularly transfer data outside the EEA. When your data is to be transferred to third countries outside the EEA or to international organizations for which there is no adequacy decision by the European Commission, all appropriate safeguards required by the applicable data protection legislation will be implemented for transfers to third countries.

III. PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA

7. SECURITY OF YOUR PERSONAL DATA

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, use, alteration, or destruction. Encryption and Security Technologies:Where applicable, we use encryption and other technologies that contribute to the security of the data you provide to us. Service Provider Compliance: We also require our service providers to comply with privacy and data protection requirements.

Specifically, the management of your personal data is carried out exclusively by specially authorized personnel of the Company under our control. Authorized Personnel and Third Parties: For processing activities, the Company selects individuals or third parties with appropriate professional qualifications, providing sufficient guarantees regarding technical expertise and personal integrity to maintain confidentiality. Security Measures and Confidentiality: Through its contractual commitments and partners, the Company takes all necessary security measures to protect and ensure the confidentiality and integrity of personal data. External Factors and Force Majeure: In any case, the security of your personal data is subject to factors beyond the Company’s control, such as technical issues in the network not managed by the Company or force majeure events. Anonymization for Statistical Reports: When generating reports for statistical analysis, we anonymize the relevant data on which the research is based before creating the reports.

8. HOW LONG will your information be retained?

We will retain your data for as long as necessary to fulfill the purposes for which it was collected. After that, it will be deleted. Data retention periods may vary depending on the purposes for which the data was collected. Please note that, in certain cases, you have the right to request the deletion of your data. However, in some instances, we are legally obligated to retain data, for example, for tax and accounting purposes.

To determine the retention period of your personal data, we take into account the nature of the data, its quantity, the purpose, security regulations, etc. You have the right to request the deletion of your data. To exercise your rights, please refer to Section 9 of this Policy.

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9. Your Rights and Options

•   How to Exercise Your Rights:
• True and Accurate Data: To enable us to respond to and/or accurately fulfill your request, you must always provide specific, accurate, and truthful data and/or facts. Otherwise, the Company bears no responsibility for any errors that are beyond its control. Furthermore, we reserve the right to reject requests that are unfounded, excessive, abusive, submitted in bad faith, or are unlawful under the law. We may also request clarifications to better understand your concerns and expectations in order to address your request more effectively.
• Identity Verification: We reserve the right to request proof of your identity in order to fulfill your rights.
• Cost: You do not need to pay a fee to exercise your rights regarding personal data, unless otherwise provided by law or in cases where the request is unfounded or excessive. In such cases, you may be charged a reasonable fee. We will inform you of any potential charges before processing your request.
• Timeframes: The Company aims to respond to all valid requests no later than one (1) month from the date of receipt, unless the request is particularly complex or the data subject has submitted multiple requests, in which case we aim to respond within three (3) months. If we require more than one month to fulfill the request for the reasons mentioned above, we will inform you accordingly.

10. Modifications

This Policy was last updated on 03/12/2024. We will regularly update this Policy to clarify our practices and to describe new or different policies regarding the management of your personal data, such as when we add new services, products, features, or functionalities to the Website.

You acknowledge and agree that any use of the services after any modifications constitutes confirmation of your acceptance of this Policy. Please read this Policy carefully and revisit it periodically to obtain the most up-to-date information regarding the personal data protection policies we implement.

If you wish to receive any clarifications or information regarding the changes, or if you have any concerns or questions about them (the changes), you may contact us using the contact details mentioned above. Please note that any information/clarification provided to you regarding the changes to this Policy in the manner described above does not constitute a replacement or modification of this Policy.

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