Privacy Policy

1. Introduction

"PRIME BIOSCIENCES I.K.E." with the trade name "PRIME BIOSCIENCES" (hereinafter "the Company" or "we") recognizes how important the protection of the personal data of the visitors and users of its website www.ingenic.gr (hereinafter "the Website") is. The purpose of this Privacy Policy (hereinafter "the Policy") is to inform the visitors and users of our Website, among other things, about the personal data that the Company collects, the purpose for which it processes them, and the rights you have regarding them.

We would like to assure you that any information and data you provide to us or that are collected by us in any way within the operation of our Website will be used by our Company in compliance with the applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (hereinafter "GDPR") and Law 4624/2019 "Personal Data Protection Authority, implementing measures for Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of natural persons regarding the processing of personal data and incorporation into national legislation of Directive (EU) 2016/680 of the European Parliament and the Council of April 27, 2016, and other provisions".

2. Key Concepts

"Personal Data" or "Personal Information": 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, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural, or social identity of that natural person.

"Processing of Personal Data": any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

"Data Controller": the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Processor of Personal Data": the natural or legal person, public authority, service, or other body which processes personal data on behalf of the data controller.

 

3. Data Controller

The data controller for all personal data processing activities carried out through the Website is our company “PRIME BIOSCIENCES”, based at 18 Lemesou Street, Agios Dimitrios, Attica, 17341, Greece, tel. (+30) 211 1828 611.

 

4. Type of Personal Data We Collect From You

When using the Website, the Company may collect information related to you that allows for your identification, either directly or indirectly in conjunction with additional information. This information, referred to as "personal data," may be collected by the Company either when you voluntarily provide it to us (e.g., when you register for the newsletter service) or simply by analyzing your behavior on our Website (e.g., through cookies).

 

Data You Provide Voluntarily

If you wish to subscribe to our Company's newsletter list through our Website, you will be asked to provide your email address. If you choose to contact us using the "Contact Form" available on our Website, you will be asked to provide your contact details (name, surname, email, and optionally your company name). Similarly, if you use the "Interest/Order Form" on our Website, you will be asked to provide your contact details (name, surname, email, phone, address, and optionally company and position). It is not mandatory to provide the Company with the aforementioned personal data. However, if you do not provide them, the Company will not be able to respond to your requests or offer the services you requested.

 

Browsing Data

The operation of our Website, as is typical with every website on the internet, involves the use of computer systems and software processes that collect information about the users of the Website as part of their usual functioning. Although the Company does not collect this information to associate it with a specific user, it is possible, due to its nature and in connection with additional data held by third parties, that it may allow for user identification, either directly or indirectly, using other information that has been collected.

This information may include parameters related to your operating system, including your Internet Protocol (IP) address, your location (country), domain names of your computer, Uniform Resource Identifier (URI) addresses for resources you request through the Website, the time when such requests were made, information about your activity on our Website (e.g., the pages you visit, the products you view), details about the device (e.g., computer, tablet, or smartphone) you use to access our Website, and so on, through cookies and other technologies that allow for such tracking. For more information, please visit the Cookies Policy.

This data will be used by the Company only for anonymous, statistical purposes related to the use of the Website, without being associated with any user identifiers, to ensure its proper functioning and to identify any errors or/or breaches of the Website. This data may also be used to investigate liabilities in case of cybercrimes committed against the Website.

 

5. Purposes and Legal Bases for the Processing of Personal Data

The Company intends to use your personal data, collected through its Website, for the following purposes:

I. To respond to your inquiry, to provide you with information or services you request. To process transactions and registrations you request, and to communicate with you when necessary, including sending emails. To complete purchase orders and deliver products you ordered via the Website and to provide any other services you may request. For the above purposes (hereinafter jointly "Provision of Services"), your consent is not required for the processing of your personal data, as this processing is deemed necessary for the provision of the services you requested and, therefore, for the performance of the contract to which you are a party or for taking steps at your request prior to entering into a contract (GDPR Article 6, para. 1 b). You are not obliged to provide your personal data to the Company for these purposes. However, if you do not provide them, the Company will not be able to respond to your requests or/or offer the services you requested.

II. For marketing, promotion, and advertising purposes, regarding the products and services of the Company and to send you offers, promotional actions, electronic newsletters, and other information about our products and services. The processing for these purposes (hereinafter jointly “Marketing”) is based on your consent (GDPR Article 6, para. 1 a). You are not obliged to provide your consent to the Company for the use of your personal data for this purpose, and no consequences will arise if you choose not to provide it, other than the fact that you will not receive promotional communications from the Company. Any consent given may be withdrawn in the future. Please note that withdrawing consent does not affect the legality of the processing based on the given consent.

III. For future marketing, promotion, and advertising purposes, by sending you direct electronic promotional communications regarding products and services offered by the Company, which are identical or similar to those you may have previously requested from the Company (hereinafter “Soft Spam”). The processing for these purposes is based on the legitimate interest of the Company (GDPR Article 6, para. 1 f) to send you direct electronic promotional communication regarding products and services that are identical or similar to those you have previously requested. You can opt out of these communications, and there will be no consequences if you do so, by indicating your objection via the unsubscribe link provided at the bottom of each such future communication.

IV. To analyze the usage of the Website, measure its traffic, gather information about users' preferences, and display advertisements related to users and their interests, through the use of statistical/ performance analysis cookies and targeting/advertising cookies. The processing for this purpose (hereinafter "Advertising/Analysis") is based on your consent (GDPR Article 6, para. 1 a), which is obtained through the cookie banner or/and a specific field that you must actively fill in. You are never obligated to provide your consent to the Company to use your personal data for this purpose, and there will be no consequences if you choose not to provide it. Any consent given may be withdrawn in the future by modifying the settings of your device, based on instructions provided in the Company's Cookie Policy.

V. For compliance with laws that require the Company to collect and/or further process certain categories of personal data. When you provide any personal data to the Company, the Company must process it in accordance with applicable law, which may include retaining and disclosing your personal data to official authorities, in compliance with tax, customs, or other legal obligations. No consent is required for the processing of data for this purpose (hereinafter "Compliance"), as such processing is necessary to comply with a legal obligation of the Company (GDPR Article 6, para. 1 c).

VI. To protect and defend the security of the Company's systems and property, including preventing and detecting any misuse of the Website or any fraudulent activities that take place via the Website, as well as to defend the legitimate interests of the Company before competent Courts and Authorities. The processing for this purpose (hereinafter "Security/Legitimate Interests") is necessary for the pursuit of the legitimate interests of the Company (GDPR Article 6, para. 1 f).

6. Recipients of Personal Data

The Company does not sell, trade, or rent data to third parties, whether natural or legal persons. Access to your personal data may be granted, on a case-by-case basis, and only to the extent necessary:

  • Properly appointed partners/service providers to our Company (e.g., internet service providers, IT system support, website content management, customer service, transport companies, legal advisors, accountants).
  • Affiliated businesses with our Company for internal administrative purposes.
  • Authorized individuals who are allowed by the Company to process the strictly necessary personal data for performing activities related to providing services via the Website (e.g., technical maintenance of network equipment and electronic communications networks), who are bound by confidentiality obligations or subject to appropriate legal confidentiality obligations (e.g., employees of the Company).
  • Credit institutions (for example, for processing payments).
  • Public authorities, bodies, services, including tax authorities, when required in compliance with applicable law.
  • In the event that the Company undergoes a business change, reorganization, merger, sale, etc., your data may be transferred. In this case, the Company will make every effort to inform you and give you the opportunity to exercise your rights.

7. Minors

In compliance with laws protecting children's privacy online, the Company does not knowingly collect personal data from individuals who are under the age of 18. If the Company becomes aware that it has unintentionally collected personal data from a minor, it will delete this data.

8. Security of Personal Data

All personal data collected and processed through the Website will be stored and processed in a manner that minimizes the risk of destruction, loss (including accidental loss), unauthorized access, use, or misuse incompatible with the original purpose of collection. This is achieved with the appropriate technical and organizational security measures implemented by the Company.

9. Retention of Personal Data

In general, the Company retains your personal data only for as long as necessary, based on the purpose for which it was collected. The criteria that govern the determination of the retention period include the following: (a) as long as our relationship lasts, (b) if the processing is based on your consent, from the moment you grant it until the moment you withdraw it, unless further retention is required to protect the interests of the Company – it is clarified that the withdrawal of consent does not affect the legality of processing based on that consent, (c) as long as required to ensure compliance with a legal obligation that applies to the Company, (d) as deemed appropriate in view of our legal position (e.g., defense of rights before Courts, inspections by Regulatory Authorities, etc.).

Specifically:

  • Personal Data processed for the Provision of Services (according to clause 5.I. above) will be retained by the Company for a period deemed strictly necessary to fulfill this purpose. However, the information will be retained for a longer period if needed to address any claims related to the services or to protect the Company's interests regarding potential liability related to the Provision of Services.
  • Personal Data processed for Marketing purposes as well as for Advertising/Analysis purposes (according to clauses 5.II. and 5.IV. above) will be retained by the Company from the moment you grant your consent until the moment it is revoked. In case of withdrawal of consent, the personal data will cease to be used for these purposes, but may be retained by the Company as it may be necessary to protect the Company's interests regarding potential liability related to this type of processing.
  • Personal Data processed for Soft Spam purposes (according to clause 5.III. above) will be retained by the Company from the moment you provide them until the moment you object to such processing.
  • Personal Data processed for Compliance purposes (according to clause 5.V. above) will be retained by the Company for the period required by the specific legal obligations for which such personal data was processed.
  • Personal Data processed for Security/Legitimate Interests purposes (according to clause 5.IV. above) will be retained by the Company strictly for as long as required to achieve the purposes for which they were collected.

After the expiration of this period, all data will be deleted or anonymized, except for data that, according to applicable law, must be retained for a longer period.

10. What are your rights?

As the data subject, you have the following rights, which you can exercise at any time, subject to certain exceptions provided by the GDPR or applicable law:

  • You can request confirmation of whether your personal data is being processed by the Company and, if so, access it and receive a copy of it.
  • You can request the correction of inaccurate data, the update of your data, and/or the completion of incomplete data.
  • You can request the deletion of your data if it is no longer necessary or if you believe it has been processed unlawfully.
  • You can request the restriction of the processing of your data when you feel that your personal data is inaccurate or the processing is unnecessary or unlawful.
  • You can withdraw your consent to the processing of your data when consent is the legal basis for the processing.
  • You can request, under certain conditions, the portability of your data, meaning to receive a copy of your data in a structured, commonly used, and machine-readable format, as well as request its transfer to another data controller.
  • You can object to the processing of your personal data.
  • You can file a complaint with the Personal Data Protection Authority. For the Authority's jurisdiction and how to submit a complaint, you can visit its website www.dpa.gr → My rights → Submit a complaint, where you will find detailed information.

11. Modifications to the Privacy Policy

The Company reserves the right to modify this Policy from time to time. Any revisions will be posted on our Website, with a clear indication of the date of the last update. Please check this Policy regularly to stay informed about any modifications or updates.

12. Contact

If you have any requests or questions, you can contact us:

We will make every effort to respond to your request as quickly as possible.

 

Last Updated: 04/2020