Privacy Policy

1. Introduction

At DELTA TRADE (the “Company”, “we”, “us”, or “our”), we take the protection of your personal data seriously and are committed to being transparent about how we collect, use, and protect it.

This Privacy Policy explains how we process the personal data you provide through our Website. Any personal data voluntarily submitted through the Website is used solely for the proper operation of our services and to ensure the lawfulness of related transactions.

Your personal data will not be used by third parties except in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679), Greek Law 4624/2019, and the ePrivacy rules as applicable.

2. Data Controller
The data controller responsible for the processing of your personal data is:

Company Name: VASILIOS ATHANASIADIS & SIA E.E
Registered Address: YPSILANTOU 102-104
Tax Registration Number (VAT): 997633902
Email: [email protected]

3. Legal Bases for Processing Your Personal Data
We process your personal data for the following purposes:
a) Provision and sale of our services
b) Communication with you regarding our services
Processing for the purposes described in points (a) and (b) is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

Legal basis: Article 6(1)(b) GDPR
c) Enabling communication with the public
d) Carrying out the Company’s promotional activities and other communications
e) Sending advertising and informational material, as well as offers tailored to your preferences and interests
Processing for the purposes described in points (c), (d), and (e) is necessary for the purposes of our legitimate interests, namely promoting our products and services and informing you about related activities or events.

Legal basis: Article 6(1)(f) GDPR

Where required by applicable law, electronic marketing communications are sent only on the basis of your prior explicit consent.
f) Research, statistical analysis, and evaluation, in order to improve our products, services, and technologies
Processing for this purpose is necessary for our legitimate interest in continuously improving the quality of our services and the overall customer experience.

Legal basis: Article 6(1)(f) GDPR
g) Managing and responding to requests submitted to our Company
Processing for this purpose is necessary for the performance of our contractual relationship with you.

Legal basis: Article 6(1)(b) GDPR

In addition, processing may be necessary for compliance with our legal and regulatory obligations, for the establishment, exercise, or defense of legal claims, and for improving the quality of our products and services.

Legal basis: Article 6(1)(c) and Article 6(1)(f) GDPR

Where handling your request requires the processing of special categories of personal data (for example, health data), such processing will only take place with your explicit consent or where necessary for the establishment, exercise, or defense of legal claims.

Legal basis: Article 9(2)(a) and Article 9(2)(f) GDPR
h) Compliance with the Company’s tax and accounting obligations

4. Collection and Use of Personal Data
We collect and use personal data only for lawful and legitimate purposes related to our business activities and legitimate interests. We do not sell, transfer, assign, exchange, or otherwise disclose your personal data to third parties outside the Company, except as described in this Privacy Policy or where required by law.

We take reasonable steps to ensure that the personal data we process is accurate, complete, and up to date.

If users voluntarily provide personal data through the Website, such as their name, address, telephone number, or email address, the Company may collect and process this data for the purposes described in this Privacy Policy.

The recipient of non-sensitive personal data is the Company only. Any communication with the Website administrator may be made by email at: [email protected]

Subject to your consent where required, we may collect personal data in the following cases:
a) Newsletter subscription
When you subscribe to the Company’s newsletter, we collect:

• Email address

b) Contact form submission
When you complete the contact form on the Website, we may collect:

• Full name / company name
• Business activity
• Email address
• Telephone number
• Free-text message / reason for contact

The above data is collected and used for the purposes described in this Privacy Policy. Where processing is based on your consent, you have the right to withdraw that consent at any time.

5. Data Retention
We retain the personal data you provide only for as long as necessary to fulfill the purpose for which it was collected, and always in accordance with applicable legal requirements.

You may withdraw your consent at any time with effect for the future. Where your personal data is used for direct marketing purposes, it will be retained until you withdraw your consent or object to such processing.

6. Where We Store Your Data
The personal data we collect from you is stored within the European Economic Area (EEA).

7. Your Rights
If you have provided personal data to the Company, you have the following rights under applicable data protection law:

Right of access
You have the right to request a copy of the personal data we hold about you, as well as information about how we process it.

Right to rectification
You have the right to request that inaccurate personal data be corrected and incomplete personal data be completed.

Right to erasure
You have the right to request the deletion of your personal data at any time, particularly where:

• your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• processing is based on your consent and you withdraw that consent;
• your personal data has been processed unlawfully.

This right does not apply where processing is necessary:

• for the establishment, exercise, or defense of legal claims; or
• for compliance with a legal obligation requiring processing by the Company.

In all cases, we will inform you whether your request can be fulfilled and, if not, the reasons for refusal.

Right to object
You have the right to object to the processing of your personal data where such processing is based on our legitimate interests. In that case, we will stop processing your personal data unless we demonstrate compelling legitimate grounds for the processing which override your rights and freedoms, or unless the processing is necessary for the establishment, exercise, or defense of legal claims

Right to object to direct marketing
You have the right to object at any time to the processing of your personal data for direct marketing purposes.

You may do so by:

• following the unsubscribe instructions included in each promotional email; or
• contacting us by email at: [email protected]

Right to data portability
Where we process your personal data by automated means on the basis of your consent or a contract, you have the right to request that your personal data be transferred to you or to another data controller. You also have the right to receive your personal data in a structured, commonly used, and machine-readable format. Where technically feasible, you may request that we transmit your data directly to another controller.

This right applies only to personal data that you have provided to us.

Right to restriction of processing
You have the right to request restriction of the processing of your personal data in the circumstances provided by law.

Right to lodge a complaint
If you believe that the processing of your personal data is unlawful, you have the right to lodge a complaint with the competent supervisory authority, namely the Hellenic Data Protection Authority.

Address: 1-3 Kifisias Avenue, 115 23 Athens, Greece
Telephone: +30 210 6475600

Complaints may be submitted using the form available on the authority’s website.

To exercise any of the rights described above, you may contact us by email at: [email protected]. We will take all reasonable steps to respond to your request within thirty (30) days of receipt and will inform you either of the action taken or the reasons preventing us from fulfilling your request.

8. Newsletters
If you subscribe to receive newsletters or promotional communications and provide your consent where required, your email address will be stored in MailChimp/Brevo, which are marketing service providers used by the Company.

You may withdraw your consent at any time or object to the use of your data for direct marketing purposes by emailing us at: [email protected]

Each newsletter also contains an unsubscribe link that allows you to remove your email address from our mailing list. Your email address will remain in our database until you request its deletion, either by using the unsubscribe link in our emails or by contacting us from the email account you registered.
Your personal data will be used for newsletters and promotional communications only until you withdraw your consent or unsubscribe.

9. Disclosure of Personal Data
The Company undertakes not to sell, rent, transfer, publish, or otherwise disclose users’ personal data to third parties, except in the following cases:

• where you have given your explicit consent;
• where disclosure is necessary for the performance of services requested by you;
• where disclosure is required in order to comply with legal obligations or requests from competent authorities;
• where disclosure is made to selected and trusted third-party service providers, such as email service providers (for example, Mailchimp) or website analytics providers (for example, Google Analytics), who process data on our behalf and are contractually bound to maintain confidentiality and implement appropriate technical and organizational safeguards in accordance with applicable data protection law.

Third parties working with the Company may process personal data only to the extent strictly necessary to support the Company’s services.

10. Automatically Collected Information
When you visit our Website, we may automatically collect certain information relating to your use of the Website, including browsing behavior, pages visited, time spent on the Website, number of pages viewed, and the websites from which you arrived at our Website.

This information may be stored through third-party services such as Google Analytics for the purpose of improving our advertising activities and other business operations. This data does not directly identify users and may be retained for up to two (2) years.

When you visit the Website, your browser may send information to our servers, including:

• your IP address;
• the date and time of your visit;
• the referring URL;
• the pages visited on our Website;
• information about your device and browser, such as browser type and version, and operating system.

11. Social Media
Our Website may allow you to register or log in through plug-ins connected to your existing social media accounts, such as Facebook, Twitter/X, LinkedIn, Google, or similar platforms.

If you choose to interact with a social media platform through our Website, certain information about your activity on the Website may become available to that platform. If you are already logged into a social media account while visiting our Website, that platform may associate your visit with your social media profile.

If you do not want this data transfer to occur, you should log out of the relevant social media platform before using the relevant feature on our Website.

You may request a full list of data processors acting on our behalf by sending a written request to the contact details provided at the beginning of this Privacy Policy.

12. How We Protect Your Data
We implement appropriate technical and organizational security measures to protect your personal data against loss, misuse, unauthorized access, disclosure, alteration, or destruction, as required by applicable law.

These measures include, among others:

• role and responsibility management;
• procedures for handling physical records;
• monitoring and audit mechanisms;
• encryption, pseudonymization, and anonymization techniques;
• firewalls and malware protection;
• remote access controls;
• physical access restrictions;
• secure protocols for data transfer.

Access to personal data is restricted to authorized personnel who need access in order to perform their duties and provide our services.

13. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy at any time. Any changes will be posted on our Website together with the updated revision date. We encourage you to review this page regularly to stay informed of any updates.

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