Tuesday, October 17, 2017

DATA PROTECTION POLICY

1) The present website (http://www.sboing.net) is a property of the company SBOING™ (hereinafter, COMPANY), which offers through it its services in respect and pursuant to the law for personal and sensitive data protection. The COMPANY is a new GPS technology based navigation operator, which leverages upon patented technological innovation that is used to compute routes based on the actual speeds recorded in the streets, as opposed to estimating the speed using only the speed limit, a method used by almost all of today’s commercial GPS-navigators. Thus, the COMPANY’S products/services enable accuracy in the assessment of time needed to cover routes in consideration of daily actual traffic. The customers or licensees of the COMPANY and the users/visitors of this website’s pages should read carefully the terms and conditions of use and the following data protection (privacy) policy before they proceed to visit/use the COMPANY’S website and leverage on the COMPANY’S products/services. Visiting/using this website implies the unreserved and unconditional acceptance of the aforesaid and described hereto data protection (privacy) policy and terms and conditions of use.

2) The COMPANY recognizes the importance of protecting the personal data and information collected from customers or licensees and/or visitors/users of the COMPANY’s website in the operation of this website, and takes steps to maintain the security, integrity and privacy of any information and data in accordance with this privacy policy. Any customer or licensee’s uploads and/or the collected traces to the SBOING™ website is performed anonymously and encrypted, ensuring the customer or licensee’s privacy.

3) Upon visiting the COMPANY’S website and using its services, it is possible that the COMPANY’S website applications might capture or store information, such as information that is automatically logged about visitors/users and which is used to produce statistics about the use of this website and improve the quality of this website’s services. The following types of information are automatically collected and stored about any visit:

  1. the Internet domain and Internet Protocol (IP) address from which visitors/users and/or customers access this website;
  2. the type of Internet browser and the operating system of the computer of the visitors/users and/or customers or licensees which they use to access this website;
  3. the date and time that visitors/users and/or customers or licensees visit this website;
  4. the pages that visitors/users and/or customers or licensees visit on this website;
  5. if the visitors/users and/or customers or licenses are linked to this website from another website, the address of that website;
  6. if the visitors/users and/or customers or licensees are linked to this website from a search engine, the address of that search engine and the search term that they used.

4) This information is collected by the COMPANY’S web server and is only used for system administration with the aim to provide statistics which the COMPANY uses in order to evaluate use of its website.

5) The COMPANY may also use cookies for collecting user information from the home page of its website. The COMPANY may store some information such as cookies on the visitors/users and/or customers or licensees’ computer when they view the COMPSNY’S website. A cookie is a small file that a website transfers to their computer for record-keeping purposes. This information facilitates use of the COMPANY’S website, reduces the need to re-enter information every time visitors/users and/or customers or licensees visit this website, and allows the COMPANY to provide a personalised experience through its website. Visitors/users and/or customers or licensees can erase or choose to block cookies from their computer or other device to access the COMPANY’s website if they want to; please refer to web-browser settings to do so. Erasing or blocking cookies may limit the range of features of the COMPANY’S website that are available to visitors/users and/or customers or licensees. The COMPANY uses cookies in two ways:

  1. first, temporary, session control cookies are sent from the COMPANY’S server to the customer or licensee’s and/or visitor/user’s computer or other device used to access the COMPANY’S website and are used to validate access privileges. These cookies do not remain on the customer or licensee’s hard drive upon completion of his/her session;
  2. second, at customer or licensee’s choice a cookie is sent from the COMPANY’S server and is stored on his/her computer’s hard drive for automatic login. Cookies are used to enable the COMPANY to identify its customer or licensee without having to ask for his/her username and password, and to measure usage. If the customer or licensee do not wish to accept any of these cookies or wish to be notified when a cookie is sent, they can modify their browser preferences accordingly.

6) Upon visiting the COMPANY’S website and using its services, the COMPANY’S customers and/or visitors/users of its website are requested to sign up and fill in some of their personal data (username, password, last name, first name, full postal address, email, desktop phone number, and cellular phone number etc) in order for respective services of the COMPANY to be activated on their account and, what is more, in order to ensure a communication channel with them to which they expressly consent through the sign up process, so that they may be informed about the COMPANY’S current and future new products and services. Upon completion of the sign up process the data subject receives a confirmation email including the description of login credentials (username and password) for said data subject. It should be clarified that the COMPANY does not provide a publicly accessible directory of its customers or licensees’ and/or visitors/users’ personal data. Therefore, the COMPANY adheres to the provisions of current legislation and protects any personal data furnished to it by its customers or licensees and/or visitors/users. Whatever personal data have been furnished to the COMPANY, it does not allow to be used by any third party unless without prejudice to the provisions of Law 2472/97, 3471/06, and 3783/09 effective as they have been amended henceforth related to the protection of personal data against unlawful processing.

7) The COMPANY acts in compliance with the effective legislation in the locus of its territoriality, i.e. Greece, aiming at the correct application of the best privacy policy as far as data protection and the Internet applications are concerned. In any case that personal data might be collected and processed they are kept in security for as long as customers or licensees and/or visitors/users of the COMPANY’S website remain registered in any of COMPANY’S services. Personal data are deleted, in any way, upon ending of data subject’s relation with the COMPANY. The personal data furnished to the COMPANY are used exclusively by the COMPANY, targeted at the support, promotion and implementation of its GPS-navigation services or on statistical grounds. Contents of the records may also be communicated to the relevant judicial, public order and other administrative authorities following their lawful demand in compliance with the pertinent effective legislation for the protection of privacy and security of communication.

8) Concerning personal data communicated to the COMPANY whenever the data subject is interested in submitting, in any form, their curriculum vitae or any other data seeking employment opportunities or when they are registered as a candidate for recruitment or when they send and/or draft, in any form, their curriculum vitae and/or, in general, communicate information including personal data to the COMPANY, the following considerations apply: a) the COMPANY does not collect knowingly personal data from data subjects who have not reached 18 years of age. The COMPANY uses the collected personal data for the very purpose that justifies the collection, in order to expand its services; b) the COMPANY uses collected personal data concerning candidates, with a view to identify professional and possibly interesting recruitment opportunities for them in the COMPANY; it is also possible that the COMPANY may occasionally communicate with them with respect to such opportunities. The collected personal data for candidates is used exclusively by the COMPANY. The COMPANY does not communicate such information to others such as associated companies and/or to entities belonging to the larger COMPANY’S group of associations and affiliations, unless there is explicit and written consent form the data subject thereupon.

9) In the event the COMPANY’S customers or licensees and/or visitors/users of the COMPANY’S website contacted with the COMPANY via email, through the present website or telephone network, the COMPANY reserves the right to keep a record for this communication and the relevant information handled, and may use the information received in this manner so as to respond to any pertinent request or inquiry submitted by the customers or licensees and/or visitors/users. The COMPANY may send COMPANY’S customers or licensees and/or visitors/users of COMPANY’S website email messages or cellular phone messages concerning a time-to-time update for its services or products and/or offers related to the aforementioned services. Regarding the provision of its services, the COMPANY may collaborate with third parties which, indicatively, but not exhaustively, relate to experts and financial auditors, legal experts, website hosting companies, cellular phone services operators, data analysis, software systems support and other, administrative or not, systems and security services. The COMPANY reserves the right to disclose to these parties anonymized information regarding its customers or licensees and/or visitors/users insofar as this is related to the purpose for which these parties provide their services to the COMPANY. Additionally, the COMPANY software consultants are likely to use such information with a view to modify, evolve, develop, enhance and assess their R&D technology in relation to the COMPANY’S services solely. In compliance with the law and the principle of proportionality, the COMPANY reserves all rights to use or communicate any collected information in any case it considers, bona fide, that is required by the law or in any case it considers that an illegal or malicious activity takes place or is going to take place or in order to secure or protect the COMPANY’S rights, property, security as well as the security of COMPANY’S customers or licensees and/or visitors/users of the present website or in order to respond to a possible force majeure. The COMPANY’S possible communication to proper authorities and in due process of any collected communication is bound by the law and the principle of proportionality.

10) In case that the COMPANY’S customers or licensees and/or visitors/users of COMPANY’S website wish to change or delete their personal data from the COMPANY’S records, they should notify the COMPANY in writing by email through the COMPANY’S website “Contact Sboing” form, stating expressly the desired change or deletion of their personal data and/or account information. It is likely then that the COMPANY may communicate with them in order to confirm their request for change or deletion of their personal data and/or whatever information pertains to them. In any case, it is likely that records of a data subject’s personal data and/or account information may remain on the COMPANY’S files, which are not to be used for commercial purposes, whereas the COMPANY reserves the right to occasionally communicate with the personal data subject depending on the COMPANY’S needs and/or the COPMANY-data subject (ex) relation from time-to-time.

11) The COMPANY takes security measures in order to avert loss, misuse or modification of customers or licences and/or visitors/users’ personal data and/or account information which are under the COMPANY’S sole control. Nevertheless, since no security system or transmission and data migration system through the Internet can provide 100% security and despite the fact that the COMPANY makes every possible effort to protect the personal data of its customers or licensees and/or visitors/users of the present website, the COMPANY in no case whatsoever guarantees the security of its servers and networks, the means through which data is transferred from the data subject’s computer and/or GPS device and/or other computing device to the COMPANY’S servers or networks or any information going to the COMPANY or to any third party via or in interconnection with the present COMPANY’S website.

12) The COMPANY’S customers or licensees and/or visitors/users of the COMPANY’S website have the right to know the identity of the COMPANY’S data controller, the purpose for which their data is being collected and processed, as well as the identity of anyone to whom their data is disclosed in accordance with article 11 of Law 2472/97.

13) The COMPANY’S customers or licensees and/or visitors/users of the COMPANY’S website have the right to know whether their personal data are being processed or have been processed. More specifically, they have the right to request and obtain from the COMPANY, without undue delay and in an intelligible and express manner, information about the nature of their personal data, their origin, the purposes of processing and the recipients, if any, thereof. In order to exercise the right of access data subjects can send a letter (by registered mail or email) to the COMPANY. The letter must be written in a simple manner such as the proposed following text:

Dear Sir/Madam, According to article 12 of Law 2472/1997, I would like to be informed in writing and in an express manner which of my personal data are being held and processed by you.

The COMPANY will answer in writing within fifteen (15) days in accordance with article 12 of Law 2472/97.

14) The COMPANY’S customers or licensees and/or visitors/users of the COMPANY’S website have the right to object to the processing of their personal data by sending a notice to the COMPANY requiring them to correct or to delete their personal data. In order to exercise their right to object customers or licensees and/or visitors/users of the COMPANY’S website may send a letter (by registered mail or email) to the COMPANY. The letter must be written in a simple manner such as the proposed following text:

Dear Sir/Madam, According to article 13, Law 2472/1997, please correct as follows (…) or delete my personal data held in your files.

The COMPANY will answer in writing within fifteen (15) days in accordance with article 13 of Law 2472/97.

15) The COMPANY reserves the right to transfer, without any further consent of its customers or licensees and/or of the visitors/users of its website, the collected information to third parties, within the context and needs of strategic alliances with them or in case of a transfer of the company itself or its associates or subsidiaries, in case of a merge or integration comprising the COMPANY or its associates or its subsidiary companies or in case of a transfer or sale of a part of its capital or its business sectors or its associates or its subsidiary companies.

16) Unless is otherwise stated hereto, the clauses of personal data protection policy of the COMPANY’S present website are effective immediately in their totality, and are accepted by the COMPANY’S customers and/or visitors/users of the COMPANY’S website in their totality and without any expressed or inferred restrain, depreciation, opposition and negation.

 

 
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