GDPR Athenian Privacy Policy

Information on the Processing of Personal Data

Introduction

We would like to reassure you that for Athenian Sea Carriers the protection of personal data is of paramount importance. For such reason we are taking appropriate steps to protect the personal data we process and to ensure that the processing of personal data is always carried out in accordance with the obligations laid down by the legal framework, both by the Company itself and by those third parties that process personal data on behalf of the Company.

Data Controller – Communications Manager

The Company, having its executive offices at Gkyzi 3, Amarousion, Postal Code 15125 in Athens Greece, email: asc_office@atheniangroup.com, tel: +30 210 6834875, website: www.atheniangroup.com, informs that, for the purposes of its business activities, processes the personal data in accordance with applicable national laws 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 relating to the processing of personal data, please contact directly the Communications Manager email: gdpr@atheniangroup.com, Tel: +30 210 6834875 What categories of personal data do we process? We process the personal data you provide us with, i.e. your full name, contact details (email, mobile phone-landline, work address), company, professional capacity, Tax Identification Number when absolutely necessary etc. and only when we have a legitimate reason to do so.

Which are the legitimate grounds for processing your personal data?

The personal data we collect are being processed only when we have a legitimate ground to do so. Legitimate grounds for processing your personal data constitute as follows:

1. The provision of the services assigned to us by you, e.g. Crude Oil and Oil Products transport, therefore, fulfilment of our contractual obligations within this context.
2. The provision of information regarding the business and other activities of our Company, through the distribution of Press Releases, Annual Reports.
3. The compliance with an obligation imposed by law, such as regulatory compliance for tax purposes.
4. Τhe consent you provide us with under the specific conditions set out in the legal framework in order to performance activities of the Company and/or giving to third party cooperating companies, which process personal data in accordance with the applicable framework, from time to time.
5. Regarding health data, our data processing concerns only manifestly public data of the data subject, and when processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.
6. The safeguarding and protection both of your, as well as our, legitimate interests. Thus, we use CCTV and security cameras, in order to be able to protect the safety and security of individuals, materials, facilities, including our vessels.

How and why do we use your personal data?

• To inform you on matters relating to the provision of services, which you wish to receive.
• When you cooperate with us, we use your personal data that is necessary to provide you with safe marine Crude Oil and Oil Products transportation services through the management and operation of Tanker vessels.
• When you cooperate with us in order to provide us goods or services to fulfill our financial obligations of different business activities of the Company.
• When you fill in the form available at our website in order to provide us your CV.
• To communicate with you and manage our relationship with you
• We may communicate with you via e-mail or even contact you by phone for administration reasons, such as the handling of any requests you may submit or for the general handling of any complaints you may have, as well as issues relating to your CV submitted to us.
• To improve our services and to protect our business interests
• Your data that may have been processed in the context of achieving our business purposes, are helping us improve the services we provide to you. Our priority is to improve your browsing in our digital platforms in order to receive the information you request with speed and ease.
• To comply with our legal obligations in a case when, i.e., our Internal Audit Department examines the completeness and reliability of the data and information required for the precise and accurate definition of our financial data, and the release of reliable financial statements.
• To safeguard our legal interests and to protect individuals and goods.

With whom do we share your personal data?

The Company informs you that may share personal data with the following categories of recipients:

• Public authorities, law enforcement institutions
• When, for example, data disclosure is vital for the judicial satisfaction of our legal claims, the relevant data are shared with the competent judicial authorities. In addition, data disclosure may take place towards state authorities, when it is considered essential for the fulfilment of the tax and corporate obligations of our company.
• Third party companies we cooperate with (Agents, etc)

Our Company shares your data with third parties, which have been assigned with the processing of your data on our behalf. In those cases, the Company remains responsible for your data processing, and defines the specifics of the processing. Our Company concludes data processing agreements with such third parties, in order to ensure the compliance of the process with the current legal framework, and the free exercise of the rights of every natural person under the current legal framework.

Retention period

The retention period is decided on the basis of the following specific criteria, as the case may be: When processing is imposed as a requirement 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 done on a contractual basis, your personal data will be stored for as long as necessary for the performance of the contract and for the foundation, exercise, and/or support of legal claims under the contract. For purposes of information and communication of the business activities of the Company, your personal data shall be kept until your consent is withdrawn. This can be done by you at any time. Withdrawal of consent does not affect the legality of consent-based processing in the period prior to such withdrawal. What are your rights in respect to your personal data? Each natural person whose data are being processed by the Company 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 review, correct, update or modify your personal data by contacting the Communications Manager at the above contact details.
• Right to erasure (right to be forgotten): 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, indicatively, where there is a contract, an 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 restriction of 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 restriction of their use rather than their deletion, (c) when such personal data are no longer necessary 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 object to 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 building consumer profile.
• Right to data portability: You have the right to receive your personal data free of charge in a structured, commonly used and machine-readable format that allows you to access, use, and edit them. Moreover, you have the right to request from us, if it is technically feasible, to transmit 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: In cases where processing is based on your consent, you have the right to withdraw it without affecting the legality of consent-based processing in the period prior to said revocation. To exercise any of the above rights you may contact the Data Compliance Officer: email: gdpr@atheniangroup.com, tel: +30 210 6834875
• Right to lodge a complaint to the Personal Data Protection Authority: You have the right to lodge a complaint with the Personal Data Protection Authority (www.dpa.gr): Switchboard: +30 210 6475600, Fax: +30 210 6475628, E-mail: contact@dpa.gr

Security of Personal Data

The Company implements appropriate technical and organisational 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 organisational measures gaining access and, possibly, using personal data for unauthorized and/or unfair purposes.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. We inform you that automated profiling does not take place at our Company for any reason.