PERSONAL DATA PROTECTION STATEMENT

Preamble
This website (the “Website”) is provided by DELTA S.A. Industrial and Commercial Company of Food Products (“DELTA”). For DELTA, respecting and protecting your personal data is a key commitment. In this context, it presumes that you are sufficiently aware as regards the treatment of your personal data. The personal data that visitors to our website provide are used exclusively for the purpose for which they were provided, as outlined at each point that such information is collected.
This Personal Data Protection Statement outlines the personal data we collect about you, how we use and protect them, and the choices you have about how we use such data. Its purpose is to inform you about the company’s policy regarding the personal data you provide us with, to allow you to know the purpose of their processing by us, the category of recipients thereof, and the procedures you can follow to exercise your legal rights.

Definitions

Personal Data: any information relating to an identified or identifiable natural person whose identity can be directly or indirectly identified.
Special categories of Personal Data (“Sensitive Personal Data”): personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Data Subject: the identified or identifiable natural person to whom the personal data and/or sensitive personal data pertain.
Processing: 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, organisation, 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: For the purposes of this policy, Controllers means the Group Companies that individually or jointly determine the purposes and manner of processing Personal Data.
Processor: the natural or legal person, public authority, agency or any other body which processes Personal Data on behalf of the Controller.
Consent: any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Personal Data Breach: a security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

How is your personal data collected?
• When you contact us through our website, by entering your data in the DELTA contact forms, by email or by telephone.
• When submitting your CVs or uploading them through www.delta.gr/jobs/
• If your personal data is lawfully transmitted to us either by other Group companies or by business partners.
• Via social networks, if you have granted access to your data to one or more social networks, such as Facebook
• During your visit to our facilities.

Why do we collect/process your personal data?
The personal data you provide to us will be processed for the following purposes:
• For our communication with you and for the overall management of our relationship. For example, we may contact you by phone or email or by other means in order to provide you with information or to request additional information about a request. We may need to contact you by email or phone for administrative reasons, such as for arranging appointments with candidates for staff recruitment.
• The company collects and processes your personal data to the extent necessary during the interview and the prospective recruitment process in order to evaluate your application for prospective employment.
• For the purpose of the submission and approval of corporate expenses corresponding to products provided to DELTA by natural persons, in order to proceed to their direct payment.
• To safeguard our legitimate interests. To be able to protect the safety of individuals, materials and facilities, we also use CCTV and security cameras during your visits to DELTA’s facilities; for the same reason, we also record the data of visitors, contractors entering our facilities to perform works etc. and issue access cards to DELTA’s facilities.
• To comply with an obligation imposed by law.
DELTA makes every effort to minimise the risk to your rights and freedoms by not collecting personal data beyond those necessary for the fulfilment of the aforementioned purposes. Your data are not subject to further processing in any manner that is incompatible with the purpose.

What personal data do we collect about you?
The data we collect depends on the general context of your interaction with DELTA, as well as on the functions you use. Some of this data is provided directly by you, for example when you contact us.
Contact Data. DELTA collects contact data such as name, address, postal code, telephone numbers, email addresses when you contact us directly either through the online contact form or by phone or Facebook or when you send us your CV. The above data is also requested from natural persons with whom DELTA cooperates.
Invoicing details. DELTA collects the invoicing details of natural persons who provide it with products or services, such as their address of residence/registered office, TIN and the name of their tax office, in order to certify the remuneration due to them and to ensure our compliance with tax laws.
Your CV. Depending on the post for which you are applying, DELTA collects the information you have submitted and processes personal data including the following: your educational background, employment history, previous employers, areas of expertise, professional and other work permits and certifications, the educational institutions from which you have graduated, your preferences as to the type of work, the verification of information regarding your recommendations and previous employers, any other information you choose to submit through the CV submission process, other data that may be provided to us during any phone calls or through your application or in any other communication with you. For the purpose of checking your application history, we may also receive information about you from other sources, where permitted by applicable law, such as from your previous employers, subcontractors providing technical services, as well as from publicly available sources, such as information posted on publicly available and publicly accessible websites, social media profiles, information from public search engine results, where such information is proportionate and appropriate for assessing your suitability for the position you are applying for.
Video. If you visit DELTA’s facilities, your image may be captured by our CCTV and security cameras, which are aimed at detecting and preventing malicious acts.
We also collect the information you provide to us and the content of the messages you send to us, such as questions and information you provide through DELTA’s online contact form. We do not use email and chat content to send you targeted adverts.

Legal basis for processing your personal data
• The conclusion and execution of a written or otherwise agreed contract.
• The consent you provide under the specific conditions set by the legal framework.
• Our compliance with national and/or European legislation.
• The safeguarding and protection of both our and your legitimate interests.
• Their obvious disclosure by the data subject.

Recipients
Where we disclose your personal data, we do so on the basis that the third parties involved agree to comply with the provisions of the GDPR. Any companies to which DELTA may disclose your personal data in the framework of a service contract will process your personal data in their capacity as processors solely for that purpose and on behalf of DELTA.
Within DELTA, your personal data will be disclosed only to the persons responsible for serving you and for handling our relations. For example, to make a recruitment decision when searching for candidates your personal data will be disclosed to HR staff, system operators (such as IT) and, of course, to the heads of the relevant departments.
In any case, unauthorised access to your personal data, including by DELTA’s personnel, is prohibited.

Personal data retention period
Your personal data shall be retained only for the time necessary to fulfil the purpose for which they are collected and processed. The retention period of your data is determined on the basis of the following specific criteria, as appropriate:
When processing is required by a labour or other provision of the applicable legal framework, your personal data will be stored for the period required by the relevant provisions.
The CVs of prospective employees are stored for any future use for a period of 6 months.

If you accept an offer for employment at DELTA, your personal data will be kept on the basis of the Employee Personal Data Processing Information form, which is disclosed to all employees

Minors’ Personal Data
DELTA does not knowingly process personal data of minors under the age of 16 without having obtained the prior consent of their parent or legal guardian. We undertake to provide the parent/guardian with: a) information about the specific categories of personal data collected from the minor and b) the possibility for them to object to the further collection, use or storage of such data. If found that personal data of a minor under the age of 16 has been collected without the verifiable consent of their parent or legal guardian, DELTA will take appropriate measures with a view to immediately deleting such data from its databases.

How do we safeguard the protection of your personal data?
DELTA takes all necessary technical and organisational measures to ensure the secure processing of your personal data and to prevent any accidental loss or destruction and any unauthorised and/or illegal access, use, alteration or disclosure of your data. Although the way the Internet works and the fact that it is freely accessible to anyone do not allow us to guarantee that unauthorised third parties will never be able to circumvent the applied technical and organisational measures, we are trying to avoid unfortunate circumstances.

Disclosure of personal data to a third Party located outside the European Economic Area (EEA) – The personal data the Company collects from you are transmitted and/or processed and/or disclosed to a third Party located outside the European Economic Area (EEA), according Art.44 -50  of EU General Data Protection Regulation and the Commission Implementing Decision (EU 2021/914) of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.»

Links to other websites
Our website may contain links to other websites. This Personal Data Protection Statement applies only to DELTA. Therefore, whenever you follow a link from this website to another, even to another Vivartia Group website, we recommend that you read the Personal Data Protection Statement of the respective website carefully. If you choose to connect to any third-party website through special links (links, hyperlinks, banners) that may be contained in the website, the company and the other Group members bear no responsibility for the terms on handling and protection of personal data applied by these third parties.

Your rights
Any natural person whose personal data is processed by the company may exercise the following rights, in accordance with the terms and specific provisions of Regulation (EU) 2016/679 and law 4624/2009
Right to Access. You may request and obtain from DELTA information about your personal data that we process, as well as information regarding the way in which they are processed, such as its purposes, recipients and retention period (article 15 of the Regulation). As part of this right, you may request that we provide you free of charge with a copy of your personal data that we process. If the requests are repeated and manifestly unfounded, DELTA reserves the right to set a reasonable amount for this service.
Right to Rectification. You may request the rectification of any inaccurate or incomplete information; the company will take these actions immediately without undue delay (article 16 of the Regulation). Our company also undertakes to immediately inform any recipients to whom your data have been transmitted (article 19 of the Regulation).
Right to Objection. You may object to the processing of your personal data where there is a legitimate interest in this, in accordance with the terms and provisions of article 21 of the Regulation, including your right to object to the automated processing of your data and to the processing thereof for marketing purposes.
Right to Erasure (“right to be forgotten”). You may request the erasure of your personal data if there is no longer a legal obligation to keep such or you object to their processing, having a legitimate interest in this (article 17 of the Regulation). In certain situations (e.g. where there is a contract in place or data processing obligations imposed by law, or where this serves the public interest), this right may be subject to specific restrictions or may even be unenforceable, as the case may be. Upon your request, our company will delete these without undue delay, under the conditions set out in the relevant applicable Greek and European legislation on Personal Data Protection. The company also undertakes to immediately inform any recipients to whom your data have been transmitted (article 19 of the Regulation).
Right to Withdraw Consent. Where we process your personal data based on your consent, you may at any time withdraw your consent or change the degree of consent you have provided, without this affecting the lawfulness of the processing for the period prior to the withdrawal.
Right to Portability. You have the right to receive your personal data in a structured, commonly used and machine-readable format, as well as to request that these data be transmitted to other controllers (article 20 of the Regulation).
Right to Restrict Processing. You have the right to request that we stop processing your personal data: (a) if you contest the accuracy of your personal data, until such accuracy is verified; (b) if you do not wish to have your personal data erased and request a restriction of use instead; (c) if your personal data is no longer needed for the relevant processing purposes, but it is required for the establishment, exercise or defence of legal claims; and (d) if you object to processing, until it is verified that there are legitimate grounds for processing, overriding the reasons for which you object to the processing (article 18 of the Regulation).
Right to lodge a complaint. You can contact the competent Greek independent authority, which is the Hellenic Personal Data Protection Authority, if you believe that your data is being unlawfully processed (http://www.dpa.gr/). Call Centre: +30 210 6475600, Fax: +30 210 6475628, Email: contact@dpa.gr.
If you exercise any of the above rights, DELTA will respond within one month, unless your request is particularly complex or there are numerous similar requests. In any case, DELTA undertakes to inform you in detail of any incidents of violation, where these may pose a high risk to your rights and freedoms, as well as of the measures to be taken to address them.

Social Network Plug-ins
Our website provides plug-ins of various social networks.
If you are already logged in to a social network when you visit our website, the social network operator may be able to link the information about your visit to our website to your social network profile data. Therefore, please visit the operators of the social network you use for information about these features.
The relevant services are provided by the respective companies (“operators”). These operators are:
Facebook operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA
YouTube provided by Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA

Contact with Controller & Protection Officer
The Controller is DELTA S.A. Industrial and Commercial Company of Food Products. You can contact DELTA for any queries or questions regarding your personal data and their processing, as well as to exercise the above rights, either by emailing us at ked@delta.gr or by sending a written request to: DELTA FOODS S.A. 230 km Athens – Lamia National Road, 14565, Ag. Stefanos, Attica.
Mr. Vagenas Konstantinos has been appointed Data Protection Officer (DPO). You can contact the DPO about any matter relating to your personal data by emailing dpo@vivartia.com

Update & Changes
This Personal Data Protection Statement was last updated on 14/7/2021.
DELTA reserves the right to amend and update this document at any time and for any reason. Please check our website periodically to find out about the currently applicable Personal Data Protection Statement, especially before you provide any new personal data.
Any change to this Statement will be posted here immediately.

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