PRIVACY POLICY

The Company, EPIROTIC BOTTLING INDUSTRY S.A., which is based in Hadji Pelleren Str. 2, PC 45221, Ioannina, Greece, tel. 2651061951 ensures the confidentiality of your personal data and adopts the General Regulation for the Protection of Personal Data 679/2016 of the European Union and the current Greek legislation in all procedures and stages of communication with you.

Purpose of this Policy

This Personal Data Protection Policy concerns the Epirotic Bottling Industry S.A. and the personal data of individuals processed by the Company. This policy provides to any individual, customer or visitor of the VIKOS S.A. or visitor of the websites of our Company www.vikoswater.gr & www.water.gr with concise and transparent information regarding the practices followed for the management and protection of personal data.

It concerns any transaction or series of transactions performed with or without the use of automated means, in personal data or in personal data sets, such as the collection, registration, organization, structure, storage, adaptation or modification, retrieval, search for information, use, disclosure by transmission, dissemination or any other form of disposal, association or combination, restriction, deletion or destruction.

The Policy is updated from time to time and may be amended whenever necessary, without prior notice, always within the applicable legal framework and in accordance with any changes in the current legislation on personal data protection. We therefore suggest that you check our websites www.vikoswater.gr & www.water.gr, in which, any posted revised version of this policy, prevails over the printed version.

Definitions

The term "personal data" hereinafter referred to as "Personal Data or Data", is any information concerning a specific natural person or person whose identity can be verified (e.g., name, identity number, address, etc.). Data related to health (physical or mental condition, receiving medical services, etc.) are included in the general term personal data; however, they constitute a special category of data.

For the purposes of this Privacy Policy, the definitions of the EU General Data Protection Regulation (GDPR) (2016/679) apply.

Legal Basis

Personal Data are obtained with following methods:

(a) When you apply for a job. The provision of your personal data in the context of submitting a CV to find a job in our Company takes place automatically and voluntarily as otherwise, it would not be possible to assess the possibility of your recruitment. The legal basis for the processing is in accordance with Article 6, (1) (b) of the GDPR “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”.

For more information, please check our CV Policy.

(b) Personal data are provided to us when you fill in forms and consent forms for the use and processing of your data in the context of promoting the Company and participating in promotional activities. The submission of your data is of your choice and their processing with your consent in accordance with article 6 (1) (a) of the Regulation 2016/679 “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”.

More details about the technologies used on our websites are set out in our Cookies Policy.

(d) You provide your personal data to us when you complete forms in the context of the implementation of Management Systems (ISO) within the Company. The data is processed in accordance with article 6 (1) (f) of the Regulation 2016/679 “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.

(e) You provide your personal data to us in the context of your participation in the voluntary actions organized by the Company (indicatively and not limited to: blood donation). The submission of your data is at your choice and their processing is in accordance with article 9 (2) (a) of the Regulation 2016/679 “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject”.

(f) You provide your personal data to us in the context of the transaction between us for the performance of our contractual obligations and in the context of the Company's compliance with its legal obligations. The processing of the personal data we receive is carried out in accordance with articles 6 (1) (b) and 6 (1) (c) of the Regulation 2016/679 “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract” & “processing is necessary for compliance with a legal obligation to which the controller is subject”.

(g) You provide your personal data to us when you fill in online forms or send an e-mail, in order to be informed about the products and actions of our Company as they are presented on our websites www.vikoswater.gr & www.water.gr. The submission of your data is at your choice and the processing of such data is carried out with your consent for the sole purpose of informing you in accordance with article 6 (1) (a) “the data subject has given consent to the processing of his or her personal data for one or more specific purposes” and in accordance with article 6 (1) (b) of the Regulation 2016/679 “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”.

Categories of Personal Data - Purposes of Processing

Personal data which are collected and further processed include:

-identification data such as your name, postal address, general contact details (including email address and telephone number). The purpose of the collection and processing is in accordance with article 6 (1) (b) of the Regulation 2016/679 “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”.

-identification data such as CV, education status, work experience, etc. The collection, processing and maintenance of the above data is for the sole purpose of the selection and evaluation of prospective employees by the Company for the possibility of finding a job and in accordance with article 6 (1) (b) of the Regulation 2016/679 “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”. Your data are kept only for this purpose and are processed by the competent departments of the Company and its authorized personnel, the Accounting Department, Human Resources (HR) Department, IT Manager, etc.

-health data such as the blood group you belong to. The purpose of the collection and processing is your participation in voluntary activities of the Company as the legal basis for the processing is your consent in accordance with article 9 (2) (a) of the Regulation 2016/679 “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject”.

-identification data, financial data, tax and contact details, such as VAT, Tax Office, address, etc. The collection, processing and retention of your data belonging to the above mentioned categories, is in accordance with article 6 (1) (c) of the Regulation 2016/679, “processing is necessary for compliance with a legal obligation to which the controller is subject”.

-identification data such as your geographic location and full name. The receipt and processing of the above data is carried out in accordance with article 6 (1) (f) of the Regulation 2016/679 “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.

The Company will not process your personal data without your consent, where is required. However, the Company reserves the right, in exceptional cases, to process your personal data to the extent permitted or required by law, and/ or by court decisions or prosecutorial orders.

The Company will search in the files of default of obligations, mortgages & mortgage notes and company data from the Official Gazette and the General Register of Companies of TEIRESIA S.A., 2 Alamanas Street, 15125, Maroussi, tel. 210-3676700 (Controller) through the checking system, any data concerning the Customer, in order to assess or reassess the assumed transaction risk in the context of the relevant transaction or, in the case of a fixed or indefinite term contract, for as long as it is in force, at the option of the Company. You can find the detailed information of TIRESIA S.A. regarding the data, the sources of their extraction and the rights of the Customer in the following link, as well as on the website of TIRESIA S.A. (www.tiresias.gr).

Recipients of your data

We may disclose your personal information (in whole or in part, as each time it appears) indicatively to:

a) all authorized persons of our Company, e.g. legal advisers, business consultants, external accountants, marketing management consultants, external accountants, insurance companies, security technician, occupational physician, etc.,

b) specific persons of our Company, necessary for the selection process of candidate employees, e.g., Human Resources (HR) Department, Administration, IT Manager etc.,

c) external partners (logistics companies, transport companies, etc.), necessary for the execution of the contract between us,

d) third party companies (e.g. credit rating agencies) in order to defend our Company's legitimate interest in security of transactions, financial freedom and freedom of information,

(e) subsidiaries or affiliates of the Company for the performance of our contractual obligations and the Company's compliance with its legal obligations,

(f) providers supporting systems for the processing of personal data,

(g) judicial or supervisory or control authorities, within the scope of their jurisdiction,

(h) third parties who have a legal interest in establishing, exercising or upholding legal claims.

In cases where your consent to the disclosure of your data to third parties is required (where it is not mentioned by law), it will be explicitly requested by you and you have the right to revoke it at any time. In these cases, the Company assures you that it is in constant contact and takes all necessary security measures, so that the transfer of personal data is carried out in the safest possible way.

The Company undertakes the obligation to not trade your personal data by making it available for sale or rental by transferring or disclosing it to third parties or using it in any other way and for other purposes that might jeopardize your privacy and your rights and freedoms, unless required by law, court decision/ order, administrative act or if it is a contractual obligation necessary for the smooth operation of the Company's website and the performance of its functions.

Your personal data may be transferred to partners or third parties, complying with the terms of this policy and committed to maintaining confidentiality and who act on behalf of the Company for further processing in order to provide services (e.g. data management, technical support etc.). These third parties have contractually agreed with the Company, that the personal data will be used only for the above purposes and will not transmit personal information to third parties, as well as will not disclose any personal data to third parties unless law requires it.

Data Retention

The retention period can vary significantly depending on the type of data and how it is used. Determining the retention time of data is based on criteria such as legal retention periods, pending or potential disputes, intellectual property or rights, contractual requirements, business instructions or archiving needs.

The Company is committed to keep your CV for three (3) years, after the job position is filled.

Your sensitive data are destroyed two (2) months after your participation in the Company's voluntary activities (e.g. blood donation).

The tax data are kept in accordance with the current tax legislation.

Data collected via video surveillance system are kept for up to 15 days after which it is automatically deleted. In the event that during this period we find an incident, we isolate part of the video and keep it for another (1) month, in order to investigate the incident and initiate legal proceedings to defend our legal interests, while if the incident concerns thirdly we will keep the video for up to three (3) more months.

In order to fulfill the purpose of processing that concerns the execution of the contract and to inform you about our services, a reasonable retention time of your data is the time of the operation of the Company and according to the current legal framework governing its operation, the legal framework governing the tax obligations of the Company as well as the Personal Data Protection Legislation.

CCTV – Data Processing

We use a surveillance system for protecting persons and property. The processing is necessary for the purposes of legal interests as a Controller and in accordance with article 6 (1) (f) of the Regulation 2016/679, “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.

Our legal interest consists in the need to protect our property and the goods located in it from illegal acts, such as theft. The same applies to the safety of life, physical integrity, health as well as the property of our staff, our customers and third parties legally located in the supervised area. We only collect image data and limit the collection to areas where assessed with an increased possibility of committing illegal acts e.g. theft, such as at the entrance, without focusing on places where the privacy of the persons being photographed may be severely restricted, including their right to respect for personal data.

The kept material is accessible only by our authorized personnel who are in charge of the security of our facilities. This material shall not be transmitted to third parties, except in the following cases: (a) to the competent judicial, prosecutorial and police authorities when it contains information necessary for the investigation of a criminal offense involving persons or property of the controller; b) to the competent judicial, prosecutorial and police authorities when requesting data, lawfully, in the performance of their duties and (c) to the victim or perpetrator of a crime, in the case of data may constitute evidence of the act.

Data subject’s rights

With regard to your personal data, you may exercise the following rights: right of access, right of information, right of rectification, right of erasure, right of restriction of processing, right of data portability, and right of objection.

In order to exercise any of the above rights, please use the "Request Form" and send it either by letter to the Company's headquarters (Hadji Pelleren Str. 2, PC 45221, Ioannina, Greece, tel. 2651061951), or via e-mail (in the Email account: [email protected]) always stating your complete details and the reason for your communication.

In case of exercise of one of the above rights, the Company will take every possible measure to satisfy your request within one (1) month of receiving it, informing you in writing of the satisfaction of your request or the reasons that prevent the satisfaction of one or more of them, as well as for the reasons of any delay beyond the above period of one (1) month and in any case not later than three months. The Company will also inform you of your further rights in case of improper response. This information is in principle provided free of charge by the Company, subject to the request for notification and information not to be exercised repeatedly, in excess and/ or to be manifestly unjustified.

If you consider that the Company in any way violates the current legislation on personal data, you reserve the right to file a complaint to the Personal Data Protection Supervisory Authority: http://www.dpa.gr, 1-3 Kifissias, PC 11523, Athens, tel. 210 6475600, e-mail: [email protected].

In this case, we would highly appreciate your previous communication with the Company either by letter at its headquarters (Hadji Pelleren Str. 2, PC 45221, Ioannina, Greece, tel. 2651061951), or via e-mail (to the E-mail account: [email protected]) Always stating your complete details and your reason for contact.