Privacy Policy
ARTICLE 11 OF LAW 2472/1997, REGULATORY ACT 1/1999 OF THE HELLENIC DATA PROTECTION AUTHORITY
This Privacy Policy (hereinafter the "Privacy Policy" or the "Policy") sets out the terms and conditions observed by BriQ Properties R.E.I.C. (hereinafter the "Company") for the protection of personal data. The purpose of this Policy is to inform you about the categories of personal data we collect and process, as well as the methods and purposes for which we collect, store, use, and disclose such personal data, as applicable.
We would like to assure you that the Company takes all appropriate technical and organizational measures to protect the personal data it processes and to ensure that their processing is always carried out in accordance with the legal framework, both by the Company itself and by any third parties processing personal data on its behalf.
We also assure you that BriQ Properties R.E.I.C. does not collect data concerning minors.
The Company reserves the right to amend, update, revise or otherwise modify this Policy periodically, whenever it deems necessary, without prior notice, in accordance with the law. Therefore, we kindly ask you to review this Policy periodically in order to stay informed about any updated versions.
What is the GDPR?
The General Data Protection Regulation (hereinafter the "Regulation" or "GDPR") is the new regulatory framework of the European Union (EU) in the field of data protection. The Regulation establishes the conditions for the processing of personal data in order to protect the rights and freedoms of natural persons, especially the right to the protection of personal data.
Data Controller
The data controller is defined as the person who determines the purposes and means of the processing of personal data.
BriQ Properties R.E.I.C., headquartered at 3 Mitropoleos Street, Athens, P.C. 10557, with TIN 997521479, email: [email protected], tel.: +30 211 9994833, website: www.briqproperties.gr, as legally represented (hereinafter the "Company"), informs that, as data controller and for the purposes of carrying out its business activities, it processes personal data of the individuals referred to in this Policy in accordance with the applicable national legislation and European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as applicable.
For any matter relating to the processing of personal data, you may contact the Company.
What does the term "personal data" mean?
Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.
What does the term "processing" mean?
Processing means 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.
What categories of personal data do we collect and process?
To serve its business purposes, the Company collects and processes data of the following categories of natural persons: shareholders and employees of the Company, property owners and/or tenants, participants in property sale and purchase tenders by submitting offers, suppliers, partners and other contracting parties (e.g., brokers, sellers, guarantors, etc.), attorneys-in-fact, legal representatives and employees of partners, members of the Board of Directors, proxies of the above individuals, visitors/users of the Company’s website, visitors of its premises, etc.
Specifically, the personal data collected and processed by the Company include the following:
− Data of employees / BoD members / shareholders:
The Company collects and processes personal data of employees and job applicants, BoD members, and shareholders, which may include, as the case may be: full name, father’s name, mother’s name, date of birth, gender, nationality, postal address, email address, phone number, ID card number, Social Security Number (AMKA), social insurance institution, Tax Identification Number (TIN) and Tax Office, financial data, IBAN, bank account number, criminal record (for BoD members), education and academic background, such as diplomas, work experience, hiring date, job position, work schedule, information on benefits from the Company, performance evaluation data, marital status, suitability for employment, etc.
− Data of property owners and/or tenants and/or participants in property sale and purchase tenders:
The Company collects and processes personal data of property owners and/or tenants and/or participants in property sale and purchase tenders, specifically: full name, address, phone number, TIN and Tax Office, property ownership data, etc.
− Data of suppliers, partners and other contracting parties:
The Company collects and processes personal data of suppliers, partners and other contracting parties, specifically: full name, postal address, email address, phone number, TIN and Tax Office, IBAN, bank account number, etc.
− Data of visitors to the Company’s premises:
The Company collects and processes personal data of visitors to its premises, specifically image data, full name and ID number, entry and exit times, etc.
− Data of website users:
The Company collects and processes personal data of website users, specifically technical and other information regarding user activity on the Company’s website and information originating from the use of the internet and/or automatically through the browser used on desktop, laptop, tablet or mobile device, such as IP address, domain of internet service provider, browser type and version, operating system, or other information about websites visited and search queries.
How and why do we use your personal data?
• Fulfillment of corporate purpose The Company collects and processes personal data and information of shareholders (members of the BoD, institutional investors and/or the investing public), property owners and/or tenants, and participants in real estate sale and purchase tenders through submission of offers, in order to fulfill its corporate purpose, namely the acquisition and management of real estate assets and the general implementation of investments in real estate, as well as in rights, shares, or holdings in real estate, the listing of its shares on a regulated market, the publication of a semi-annual investment report of its available funds, the receipt of loans, credits, and guarantees, the distribution of profits, etc.
• Regulatory compliance The Company collects and processes personal data and information of shareholders (members of the BoD, institutional investors and/or the investing public), property owners and/or tenants, and participants in real estate sale and purchase tenders through submission of offers, for the purpose of regulatory compliance with the requirements of the Hellenic Capital Market Commission, which is responsible for the supervision and enforcement of Law 2778/1999 and the regulatory decisions governing the operation of REICs issued pursuant thereto. REICs and their subsidiaries are required to make available to the Capital Market Commission and its authorized officers all data necessary for the conduct of such oversight. These officers may: (a) access any document in any form and obtain copies thereof, and (b) request information from any person and, where necessary, summon and receive testimonies in accordance with paragraphs 9 to 13 of Article 22 of Law 3340/2005.
• Employment relationship management The Company collects and processes personal data and information of employees which are necessary for recruitment procedures, payroll processing, and overall employment relationship management and administration.
• Safeguarding legitimate interests and protection of individuals and assets The Company uses closed-circuit television (CCTV) and security cameras to ensure the safety of individuals, materials, and facilities, including vessels.
• Distribution of Company News / Investor Information When visiting our websites www.briqproperties.gr and www.briqproperties.com, you have the option to complete a contact form to get in touch with us, or a communication form to receive Company updates and investor-related financial information. Additional information may be requested upon completion of these forms; however, only the minimum required information for the aforementioned processing purposes will be marked as mandatory fields.
What are the lawful bases for processing your personal data?
The Company processes personal data only when there is a lawful basis for doing so, specifically when:
(a) Processing is necessary for the performance of a contract to which the data subject is a party,
(b) Processing is necessary for the fulfillment of the Company’s corporate purpose and the overall operation of its business activities,
(c) Processing is necessary for compliance with a legal obligation, such as regulatory compliance required by applicable legislation for real estate investment companies, for tax purposes, etc.,
(d) Processing is necessary for the protection and safeguarding of the Company’s legitimate interests. For instance, we use CCTV and security systems to protect the safety of individuals, facilities, and materials, as well as specialized security software to detect and prevent malicious acts. Specifically, when visiting our physical premises or browsing our websites, we use information such as IP address, location data, and device details to detect or prevent fraud or misuse of our website,
(e) Processing is based on your consent under the specific conditions set out by the legal framework, in order to receive updates on the activities, products, services, etc., of BriQ Properties R.E.I.C.
Protection of Minors
The website is addressed to an adult audience (e.g., investors and individuals seeking information about the Company). The Company neither collects nor intends to collect any information from or regarding children.
Do third parties have access to your data?
BriQ Properties R.E.I.C. does not allow third parties to access personal data it collects and processes as Data Controller. Exceptionally, and only where absolutely necessary, third parties such as staff members, affiliated companies, banks, insurance companies, service providers, the Capital Market Commission, the Athens Stock Exchange, courts, administrative or judicial authorities, other public bodies, lawyers, experts, technical advisors, witnesses, etc., may access your personal data.
Such access is granted exclusively for the purposes and to the extent required to provide the respective service, and always on the condition that these parties accept and comply with the terms of this Policy and applicable law. In such cases, the Company remains responsible for the processing of your personal data and determines the specific terms of such processing. The Company signs a specific contract with each third party engaged in processing activities to ensure that the processing is carried out in accordance with the legal framework.
How long does the Company retain your data?
The retention period of personal data is determined based on the following specific criteria, depending on the case:
(a) Where processing is required as an obligation under the applicable legal framework, your personal data will be stored for as long as such provisions mandate.
(b) Where processing is based on a contract, your personal data will be stored for as long as necessary for the execution of the contract and for the establishment, exercise, or defense of legal claims based on the contract.
(c) Where processing is necessary for the purposes of the legitimate interests of the controller or a third party, the personal data will be stored for as long as is necessary to satisfy those legitimate interests.
(d) Where processing is based on your explicit consent for information and communication purposes, your personal data will be retained until you withdraw your consent. You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of the processing carried out based on consent before its withdrawal.
To withdraw your consent, you may contact the Company at 3 Mitropoleos Street, Athens, P.C. 10557, TIN 997521479, email: [email protected], tel.: +30 211 9994833. You may also use the unsubscribe options by clicking the relevant link in our electronic communications.
What are your rights regarding your personal data?
Every natural person whose data is being processed by BriQ Properties S.A.R.E.I.C. enjoys the following rights:
Right of access: You have the right to be informed and to verify the lawfulness of the processing. Therefore, you have the right to access the data and receive additional information regarding their processing.
Right to rectification: You have the right to review, correct, update and/or modify your personal data.
Right to erasure: You have the right to request the deletion of your personal data when the processing is based on your consent or in order to protect our legitimate interests. In all other cases (such as when there is a contract, a legal obligation to process personal data, public interest), this right is subject to specific limitations or may not exist depending on the case.
Right to restriction of 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 request the restriction of their use instead, (c) when the personal data are not needed for processing purposes but are necessary for the establishment, exercise, or defense of legal claims, and (d) when you object to the processing and until it is verified that legitimate grounds exist that override your objections.
Right to object to processing: You have the right to object at any time to the processing of your personal data in cases where processing is necessary for the purposes of the legitimate interests pursued by us as data controller, as well as for processing carried out for direct marketing purposes and the creation of consumer profiles.
Right to data portability: You have the right to receive, free of charge, your personal data in a format that allows you to access, use, and process them using commonly accepted processing methods. You also have the right to request, where technically feasible, that the data be transmitted directly to another data controller. This right applies to data you have provided and which are processed by automated means based on your consent or in the performance of a relevant contract.
Right to withdraw consent: Finally, BriQ Properties S.A.R.E.I.C. informs you that where processing is based on your consent, you have the right to freely withdraw it, without affecting the lawfulness of the processing based on your consent before its withdrawal. To withdraw your consent, you can use the unsubscribe options provided in our electronic communications or contact us at [email protected].
To exercise any of the above rights, you may contact the Company at: 3 Mitropoleos Street, Athens, P.C. 10557, TIN 997521479, by email: [email protected] with the subject "Personal Data", or by phone at: +30 211 9994833.
Right to lodge a complaint with the Hellenic Data Protection Authority: You have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr): Telephone Center: +30 210 6475600, Fax: +30 210 6475628, Email: [email protected].
Stakeholders of the Company may submit reports or complaints regarding suspected incidents of illegal conduct that have been committed or are likely to be committed in the Company’s operations, or serious misconduct and breaches of rules, policies and procedures, or any act that is or could be harmful to the Company’s mission or reputation. Email: [email protected]
Security of Personal Data
BriQ Properties S.A.R.E.I.C. implements appropriate technical and organizational measures aimed at the secure processing of personal data and the prevention of accidental loss or destruction, as well as unauthorized and/or unlawful access, use, modification, or disclosure of such data. In any case, the nature of the Internet and the fact that it is accessible by anyone does not allow for guarantees that unauthorized third parties will never be able to bypass these measures and gain access to or use personal data for unauthorized and/or improper purposes.
Cookie Policy Notification
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Links to other websites
Our website may provide links to other websites not owned by the Company, and other websites may link to the Company’s website. The Company makes every effort to ensure that its website links only to third-party websites that share similar standards for privacy and security. In any case, the Company bears no responsibility for the content or privacy practices of websites not owned by it, does not guarantee continued and secure accessibility, does not endorse or adopt the content or services of third-party websites, and is not responsible for the protection and privacy of any information you provide to other websites once you leave this website. For this reason, we recommend that you carefully read the privacy statements of those external websites.