Information on the Processing of Personal Data
The Public Properties Company SA (ETAD SA) is a société anonyme whose purpose is the exploitation, by any appropriate means, of the immovable assets owned by it together with the management of the assets assigned to it by the State, by legal persons governed by public law, by legal persons governed by private law belonging to the wider public sector and by other societe anonymes whose share capital belongs directly or indirectly to the Greek State (hereinafter referred to as “ETAD SA” or “Company”).
ETAD SA was formed by the absorption of Sociétés Anonymes, “Tourist Properties SA”, “Olympiaka Akinita SA”, “Public Real Estate Company SA” and “Paraktio Attiko Metopo SA”.
In this context, ETAD SA is active in:
• Administration / Management of Public Property (Tourist, Olympic, Urban, Rural and Other Real Estate Properties)
• Management of Lease Contracts or/and properties’ concession
• Operation of tourist business units as branches (ski, marinas, coasts, thermal springs)
• Exploitation of Property, with private investment, through lease tenders
• Development of Real estate Property through co-funded programs
• Short-term lease of facilities and outdoor areas throughout Greece for the holding of various kinds of events (exhibitions, concerts, conferences, receptions, etc.)
• Participations (equity participation in corporate schemes for the development and exploitation of tourist property)
For “ETAD SA” the main priority is the management and exploitation of its portfolio’s real estate properties, through modern financial tools, in accordance with the objectives and priorities of the Country’s development, contributing to the development of the economy, tourism and local communities. The intention of the Company is to attract private investment and to promote public-private partnerships, with a view to protecting the environment and working with local communities. The total stake (100%) of the Company’s share capital is hold by HELLENIC COMPANY OF HOLDINGS AND PROPERTY (EESYP SA), after the adoption of Law 4389/2016.
The “ETAD SA” operates in the public interest, in accordance with the rules of the private economy.
Notification of personal data’ protection
We would like to assure you that for Public Properties Company SA (ETAD SA), which operates in the management, exploitation and utilization of private property of the State, the protection of the natural persons’ personal data is of paramount importance. In particular, in the context of the use of the online platform e-auction (www.publicrealestate.gr) in which public properties are auctioned by natural persons-members of this platform, we are taking all appropriate measures to protect the personal data we process and to ensure that the processing is always carried out in compliance with the obligations as set by the legal framework, both by the Company itself and by those third parties that process personal data on behalf of the Company.
Controller – Data Protection Officer (DPO)
The Public Properties Company SA (ETAD SA), seated in City of Athens, Attica, at 7 Voulis street, email: firstname.lastname@example.org, tel: (+30) 210 3339641/9483, website: https://www.e-publicrealestate.gr/, as duly represented, informs that, for the implementation of its innovative project, i.e. for the exploitation of public property via electronic tender, it created the website www.e-publicrealestate.gr, through which, each registered member of the site is enabled to (either designated as a “User” (natural / legal person) or as a “Real Estate Broker”, acting on behalf of a third party) have access to information on the available for sale or lease property of the State, as well as to participate in electronic tenders related to these properties. Within the framework of the above services, our Company processes the personal data of its registered members (for example, candidate buyers data, which may be either individual natural persons or representatives of legal persons or brokers – authorized by third parties) as well as other persons, such as its staff, in accordance with applicable national law 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 (General Data Protection Regulation, hereinafter referred to as the “Regulation”), as such is in force.
For any matter related to the processing of personal data, please contact directly Data Protection Officer, Mrs Marilena Bellou, email: email@example.com
Which are the legitimate grounds for processing your personal data; and how do we process them?
The personal data you provide us (indicatively and not exhaustively your full name, your contact details, your email address, your telephone number, your VAT number, as well as financial information that may be necessary for your participation in a tender bidding and other additional information that may arise from other supporting documents of your participation in a tender, including, but not limited to, the details of the delegator) are being processed only when we have a legitimate ground to do so.
Legitimate grounds for processing your personal data constitute:
(a) the actions required at pre-contractual stage and are carried out voluntarily by prospective buyers / tenants, such as the details you provide us (name, address, telephone, e-mail, VAT number, etc.), in order to participate in an electronic property tender, with a view to proclaiming you as a contractor, and the completion of the transfer of the auctioned property by a notarial deed, while the same legal basis (the performance of the contract) is also used for the management of any objections that you submit to us in order to cancel / repeat the stage of the tender.
(b) the compliance with an obligation imposed by law, such as the transfer of the buyer’s data to a public notary in order for the transfer operation to be completed,
(c) the safeguarding and protection both of your, as well as our, legal interests. Thus, in order to improve the operation of the online auction platform www.e-publicrealestate.gr , we may process the login information (for example, access details of a registered member) or check users’ activity on the site, or even evaluate suggestions and comments that our members or ordinary visitors may submit to improve our online services.
(d) the consent you provide us with under the specific conditions as set in the legal framework, such as indicatively the management of our communication with the public and its information about our business activity. We assure you that on this legal basis we process your personal data solely for the purpose for which you give us your consent.
(e) processing necessary for the performance of a task carried out in the public interest, which is in this case the exploitation and the optimum utilization of public property, which is provided in Article 201 of Law 4389/2016.
How and why do we use your personal data?
- To take the necessary measures in the pre-contract stage of the tender, for the proper performance of the contract and the compliance with our contractual commitments.
From our contractual relationship, which arises from the pre-contractual stage of obtaining the necessary data and documents for your proper participation in an electronic tender through the online platform, until the final award of the property to a bidder and the execution of the contract upon the completion of the transfer of the property, we obtain and process the information required for the smooth development of our cooperation, such as the submission of your personal data requested in the online application to participate in a tender, the deposit of any additional supporting documents required (eg legalization documents in the case the natural person acts on behalf of a legal person or is a real estate broker acting on behalf of a third party), the guarantee of participation in the competition in a banking institution, etc.
- To communicate and manage our relationship with you
We may communicate with you via e-mail or phone for administrative purposes, e.g. in order to confirm information required for the performance of a contract or the update of existing information or the collection of missing documents for a tender. In general, it is likely that we get in contact with you as regards the management of your complaints and requests.
- To send newsletters and explore investment interest:
We provide real estate investment advisory services to our registered members, depending on the criteria you are notifying us, as well as updates on upcoming property tenders that you may be interested in.
- To comply with legal obligation
In an electronic contest, we have to comply with the terms of the tender and therefore we have to process the information required in each declaration in the manner and for the purpose indicated. In addition, for the completion of the sale of the property after the award of tender to the successful tenderer, we have to transfer the buyer’s personal data to any competent public authority (notary, land registry, etc.).
- To safeguard our legal interests and to protect individuals and goods
We may process the data of our members (eg username, password of the registered member) as well as data provided by our site’s simple visitors (eg browsing history) in order to upgrade the online platform www.e-publicrealestate.gr and optimize our online services.
- To create a member account
To create a member account on the e-auction website, you have to provide us with your name, your residence address, your telephone number, your email address, your VAT number, as well as with your personal passwords.
Do we share your personal data?
The Public Properties Company SA (ETAD SA) informs you that it shares your personal data with the following categories of recipients:
- Public authorities, Law enforcement institutions
The personal data of tenders-buyers are disclosed and transferred to a notary, the competent tax authorities and the land registries, with a view to completing the transfer of the property belonging to the public property, in accordance with the lawful procedures. Moreover, the company may disclose personal data of applicants to judicial authorities if a legal dispute may arise.
- Cooperating companies (Hellenic Republic Asset Development Fund, banks)
The Public Properties Company SA (ETAD SA) may disclose to the above Hellenic Republic Asset Development Fund (hereinafter “Fund”) the information of real estate tenders, provided that these properties are managed by our Company, in the framework of our cooperation with the Fund. It may also disclose the details of the candidate applicants of an electronic tender to specific banking institutions in the context of a letter of guarantee is being returned or reimbursed or for the submission of the award price which constitutes the sale price of the property. In these cases, our company remains responsible for your data processing, and defines the specifics of the processing. Our company concludes data processing agreements with the third parties, in order to ensure the compliance of the process with the current legal framework, and the unhindered exercise of the rights of every natural person.
Furthermore, the Public Properties Company SA (ETAD SA) may transfer data of a candidate applicant to third natural persons or legal persons who are candidates for the same tender at the special request or objections of the latters, if this is permitted by the content of the notice, in order to provide information in the context of the transparency of the tendering procedure.
Data Storage Period
The data storage period is decided on the basis of the following specific criteria, as the case may be:
When processing is imposed as an obligation under provisions of the applicable legal framework, your personal data shall be stored for as long as required by the relevant provisions.
When processing is conducted on a contractual basis or/and in order to take steps at your request prior to entering into a contract, your personal data are stored for as long as necessary for the performance of the contract and for the foundation, exercise, support or defence of legal claims under the contract and until their legal limitation. The above personal data may be retained for as long as it is determined by other tax or more specific legal provisions.
In the context of our communication with you and to the extent that the supply of your personal data is based on your consent, your personal data will be retained until your consent is withdrawn. This could be done by you at any time. The withdrawal of your consent does not affect the legality of processing, which is based on consent given in the period before the withdrawal.
What are your rights in respect to your personal data?
Every natural person whose data are being processed by The Public Properties Company SA (ETAD SA) enjoys the following rights:
Right of Access:
You have the right to be aware and verify the legitimacy of the processing. So, you have the right to access the data and get additional information about their processing.
Right to Rectification:
You have the right to study, correct, update or modify your personal data.
Right to Erasure:
You have the right to request the deletion of your personal data when we process it based on your consent or in order to protect our legitimate interests. In all other cases (such as, by way of indication, where there is a contract, obligation to process personal data required by law, public interest), such right shall be subject to specific restrictions or shall not exist, as the case may be.
Right to Restriction of Processing:
You have the right to request the limitation of the processing of your personal data in the following cases: (a) when the accuracy of the personal data is questioned and until such data is verified, (b) when you object to the deletion of personal data and request the limitation of their use rather than their deletion, (c) when such personal data are not needed for processing purposes, they are, however, indispensable for the foundation, exercise, support of legal claims, and (d) when you oppose to the processing and until it is verified that there are legitimate grounds that concern us and supersede the reasons for which you are opposed to the processing.
Right to object:
You are entitled to oppose the processing of your personal data, at all times, in case where, as described above, this is necessary for the purposes of legitimate interests pursued by us as controllers, as well as in the processing for direct marketing purposes and consumer profile training.
Right to data portability:
You have the right to receive your personal data free of charge in a format that allows you to access, use, and edit them with commonly used editing methods. Moreover, you have the right to ask us, if technically feasible, to pass the data directly to another controller. Such right to do so exists for the data you have provided to us and their process is carried out by automated means based on your consent or performance of a relevant contract.
Right to withdraw your consent:
Last, the Public Properties Company SA (ETAD SA) informs you that, where processing is based on your consent, you have the right to revoke it without affecting the legality of consent-based processing in the period prior to said revocation.
To exercise any of the above rights, you can contact the Data Protection Officer (DPO) Mrs. Marilena Bellou, postal address: 7, Voulis str., 105 62 Athens, email: firstname.lastname@example.org
Right to lodge a complaint to the Personal Data Protection Authority
You have the right to file a complaint with the Personal Data Protection Authority (www.dpa.gr): Switchboard: +30 210 6475600, Fax: +30 210 6475628, E-mail: email@example.com
Security of Personal Data
The Public Properties Company SA (ETAD SA) shall implement appropriate technical and organizational measures aimed at the safe processing of personal data and the prevention of accidental loss or destruction and the unauthorized and/or unlawful access to, use, modification or disclosure thereof. In any case, the way in which internet operates and the fact that it is free to anyone cannot guarantee that unauthorized third parties will never be able to violate the applicable technical and organizational measures gaining access and, possibly, using personal data for unauthorized and/or unfair purposes.
Connections with other sites
Our online platform www.e-publicrealestate.gr may contain links to foreign websites. The Public Properties Company SA (ETAD SA) is not responsible for the privacy practices or the content of other sites, which do not belong to the Public Properties Company SA (ETAD SA). Therefore, we suggest that you read carefully the privacy statements of these foreign sites.