Information on the Processing of Personal Data
Introduction
The HELLENIC PUBLIC PROPERTIES COMPANY is a public limited company that aims to utilize, with all appropriate means, the real estate assets it owns, the management of the assets and the operation of tourist business units, which have been assigned to it by the state, by legal entities under public law, by legal entities under private law belonging to the broader public sector as well as from public limited companies, the share capital of which belongs directly or indirectly to the Greek state (hereinafter “HPPC SA” or “Company“).
We would like to assure you that HPPC SA, during the management of the business unit “Parnassos Ski Center” (PSC), sets as a primary goal the protection of personal data of its customers and visitors, as well as on all individuals, such as suppliers, partners and staff. For this reason we have taken the appropriate organizational and technical measures to protect the personal data we collect and process to ensure that the processing of personal data is always carried out in accordance with the obligations set within the legal framework, both by the Company and its business unit, as well as by third parties who process personal data on its behalf.
Processor – Data Protection Officer (DPO)
HPPC SA is based in Athens (Voulis 7, PC 10562), with Tax Identification Number (AFM) 094537454, tel: +30 210-3339416, website: http://www.etasa.gr, e-mail: info@etasa.gr and fax : 210-3339507 during the management of the PSC, located in Parnassos, Boeotia (tel: +30 22340 22700, website: https://parnassos-ski.gr), informs that for the purposes of conducting its business activities, processes personal data, in accordance with applicable national legislation and European Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “the Regulation“), as in force.
For any issue regarding the processing of personal data, contact directly the Data Protection Officer (DPO) Ms. Marilena Bellou email: dpo@etasa.gr.
What personal data do we process?
The personal data you provide to us such as name, contact telephone, e-mail address (email), police ID or passport, details for issuing invoices in case of an individual or any legal form of sole proprietorship, supporting documents for the purchase of special (discount) ticket categories and photo for the issuance of Skidata magnetic cards – tickets, are required for reasons of protecting the contractual rights of our Company through the control of entry and stay in the PSC, as well as for the safety of persons, according to the current legislation on ski resorts and we process them only when we have a legitimate reason to do so.
HPPC SA does not collect or process specific personal data. For the issuance of discount tickets due to disability, only the presentation of the relevant supporting document is required.
Ποιοι είναι οι νόμιμοι λόγοι επεξεργασίας των προσωπικών σας δεδομένων;
What are the legal reasons for processing your personal data?
Legal reasons for the processing of your personal data are:
(a) the actions we take to provide you with the services you expect and wish to receive from us, in particular: ski services and related mountain activities (eg snowmobiles, skibus, mountain guides), rental, sale of ski equipment, ski schools, leisure and catering services (central chalet, shelter), sale of souvenirs, advertising of partner companies on the official site and at PSC facilities.
(b) the consent you provide to us, under certain legal conditions, such as in the case of taking and posting of your photos on the PSC website, for the purpose of presenting and promoting our services. We assure you that on this legal basis we process your personal data solely for the purpose for which you provide your consent.
(c) the processing of your personal data for the purpose of medical diagnosis, provision of health or social care or treatment, which is provided to you free of charge by a doctor located at the First Aid Station within the PSC area or, in critical cases, based on the doctor’s evaluation, your transfer to the nearest health centre or hospital, in case you are injured while engaging in any of our activities.
d) the processing of personal data that is carried out in the context of compliance with obligations imposed by law, such as compliance with the applicable legal framework, as determined by the Ministry of Tourism (Hellenic Tourism Organization), council authorities for the operation of ski centres, as well as the compliance with special environmental and health provisions, as outlined by the Ministry of Environment and the Ministry of Health, respectively.
(e) the safeguarding and protection of legitimate interests, primarily yours and of our business. Thus, in the context of providing immediate information to customers-visitors of our website, to be informed at any time, on weather conditions, the condition of ski slopes and possibly the traffic that they will encounter, we carry out a constant transmission of images through webcams from appropriate points of the PSC. In this case, we seek to take the image from as far away as possible, so that the faces are not identifiable, in order to minimize the possibility of causing our visitors annoyance.
Also, in order to be able to protect the security of people, goods and in general of our facilities we use closed circuit television (CCTV) with security cameras. HPPC SA for the operation of cameras and recording and processing systems has taken all the necessary organizational and technical measures, in accordance with the General Regulation of the EU. 2016/679 and the current Directions of the HDPA, regarding positions and viewing angles, exclusively capturing of images and in no case audio, the markings, the time it is kept and access to the recorded products, having prepared a relevant Impact Assessment Study.
How and why do we use your personal data?
- To offer quality services to our customers and visitors, to best serve their needs, as well as for the proper execution of contractual relationships with our partners.
From the contractual relationship between us and from the existing pre-contractual actions, we extract and process the information required for the smooth development of the cooperation between us, such as the personal data that, in your capacity as customers-visitors, you submit to the electronic platform of our website for online ticket purchase or for the collection of statistical data (regarding the number and profile of our customers).It is explicitly stated that the use of the PSC facilities by customers, for any form of skiing (ski, snowboard, etc.) is a contractual relationship between HPPC and the customer, for as long as he is in and uses the PSC facilities. The collection and processing of the customer’s personal data, through the issuance of magnetic cards – Skidata tickets, as well as for the issuance of web tickets, is an essential condition for the execution of the contract, for reasons of personal safety, in accordance with the applicable legislation on the operation of ski resorts and protection of HPPC SA’s legal interests.
- For the provision of first aid and medical services in the event of an accident.The doctor who is in the First Aid Station of the PSC, in case of an injury or sudden illness to a visitor, provides a free medical diagnosis and first aid health care. In this context, it processes specific data of our visitor patients, in particular their health data, in order to provide immediate first aid and care.
- For the presentation and promotion of services offered at our ski centre.If you have consented to this, our website will occasionally host photographic material from the premises of PSC, in order to present through our website the activities we have at our ski centre.
- For our compliance with legal obligationsWe are obliged to comply with the legal provisions provided for by the Ministry of Tourism (in particular by the Hellenic Tourism Organization) regarding the operation of ski resorts, the health provisions of the Ministry of Health and environmental provisions of the Ministry of Environment, and with any other public and local government authority, which define the total framework of our legal and orderly operations.
- For the protection of our legal interests and the protection of persons and propertyWe process the personal data of our customers for the optimization of our online (via the site) services as well as for the better operation of our website and, therefore, we may collect data of our website’s visitors (eg browsing history). In addition, the use of CCTV and security cameras, as referred to above, ensures the protection of persons (ie our customers, suppliers and staff), as well as the security of our business’ goods.
Where is your data communicated?
HPPC SA, regarding the operation of the PSC, may forward your personal data to the following categories of recipients:
- Public Authorities, law enforcement agenciesWhen this is necessary, e.g. in the case of a regular financial or extraordinary tax audit and in accordance with the prescribed procedures, as well as in the case of e.g. providing information to police and/or judicial authority, in the event of any preliminary examination or interrogation or legal dispute with our client (eg injury) and in order to safeguard the public interest or our business interests and the reputation of our Company.
- Partners of our Company (suppliers, agencies, advertising companies, etc.)HPPC SA maintains partners to whom it entrusts the processing of personal data on its behalf (eg suppliers of information systems and technological equipment in general, partners on tax services, etc.).
In these cases, our Company remains responsible for the processing of your personal data and defines the individual components of the processing, and signs a special contract with the service providers (Data Processing Agreement) to whom it assigns the execution of processing activities, in order to ensure that the processing takes place. in accordance with the applicable legal framework and so that every natural person can freely, and in an unhindered manner, exercise the rights conferred on him by the legal framework.
Furthermore, our Company may forward to cooperating third companies in order to inform the public about our services, the promotion of our services and the presentation of our offers, under the condition that consent has been provided by each natural person, as stated above, and that the above applies with the written processing assignment.
Storage Period
The data storage period is decided based on the following specific criteria, depending on each case:
When processing is required by the provisions of the applicable legal framework and the protection of public interest, your personal data will be stored for as long as the relevant provisions require.
When the processing is carried out based on the execution of a contract, and/or the taking of measures for the purpose of drawing up a contract, your personal data are stored for as long as defined by the applicable contract, as well as for as long as necessary for the establishment, exercise, support or rebuttal of the legal claims arising from the contract and up to their legal limitation. The above personal data may be kept even for as long as it is determined by other tax or more specific legal provisions.
Notwithstanding the above general provision, especially for the issuance of magnetic cards – Skidata tickets, as well as for the issuance of web tickets, the personal data we collect are stored in accordance with the business purposes and the legal interests and legal obligations of the Company, taking into account the smooth operation of the PSC.
For the purposes of promoting our products and services, and in so far as the availability of your personal data is based on your consent, your personal data is kept until your consent is revoked. This can be done by you at any time. Withdrawal of consent shall not affect the lawfulness of the proceedings based on the consent given during the period prior to its withdrawal.
What are your rights in relation to your personal data?
Any natural person whose data is processed by HPPC SA in regard to the PSC, enjoys the following rights:
Right of access:
You have the right to be aware of and verify the legality of the processing. Thus, you have the right to access the data and receive additional information about their processing.
Right of correction:
You have the right to study, correct, update or modify your personal data, upon written request with the Data Protection Officer (DPO) at the contact details listed below.
Right to delete:
You have the right to submit a written request for the deletion of your personal data when we process it based on your consent or in the context of the protection of our legal interests. In all other cases (such as when there is a contract, obligation to process personal data imposed by law, public interest), this right is subject to certain restrictions or does not exist, as the case may be.
Right to restrict processing:
You have the right to request the restriction of the processing of your personal data in the following cases: (a) when you dispute the accuracy of the personal data and until it is verified; (b) when you oppose the deletion of personal data and instead of deletion, request the restriction of their use; (c) when personal data is not needed for processing purposes, but is necessary for the establishment, exercise, support of legal claims; (d) when you object to the processing and until it is verified that there are legitimate reasons that concern us and prevail over the reasons why you oppose the processing.
Right to object to processing:
You have the right to object at any time to the processing of your personal data in cases where, as described above, it is necessary for the purposes of legitimate interests we seek as processors.
Right to portability:
You have the right to receive your personal data free of charge in a form that allows you to access, use and process it using commonly used processing methods. You also have the right to request that, if technically possible, we transfer the data directly to another processor. This right exists for the data you have provided to us and their processing is carried out by automated means based on your consent or in execution of a relevant contract.
Right to withdraw consent:
Where processing is based on your consent, you have the right to revoke it freely, without it affecting the legality of the processing based on your consent before revoking it.
To exercise any of the above rights you can contact the Data Protection Officer (DPO) Ms. Marilena Bellou, postal address: Voulis no. 7, 105 62 Athens, email dpo@etasa.gr.
Right of complaint to the HDPA
You have the right to file a complaint to the Hellenic Data Protection Authority (www.dpa.gr): Call Center: +302106475600, Fax: +30210 6475628, E-mail: complaints@dpa.gr
Personal Data Security
HPPC SA implements appropriate and modern technical and organizational measures, aimed at the secure processing of personal data and the prevention of accidental loss or destruction and unauthorized and/or illegal access to them, their use, modification or disclosure. In any case, the operation of the internet and information systems in general and the fact that it is open to anyone does not guarantee that unauthorized third parties will never be able to violate the applicable technical and organizational measures by gaining access and possibly using personal data for unauthorized and/or unlawful purposes.
Links to other sites.
Our website may contain links to foreign websites. HPPC SA and Parnassos Ski Center are not responsible for the privacy practices or the content of other websites that do not belong to our Company. Therefore, we suggest that you read carefully the privacy statements posted on the website of the respective foreign website.