Athens May 25, 2018

Privacy policy

1. SECURITY

At TMS Ltd (hereinafter the Company) we are interested in the protection of your personal data and we want to be open and transparent about how they are processed. For this reason, we have created this Privacy Policy in which we explain how we process and protect your personal data. The personal data voluntarily declared by the user anywhere on our Website are intended solely to ensure the operation of the services provided and the legality of the relevant transactions and may not be used by any third party, without complying with the provisions of the General Data Protection Regulation (EC 2016/679 GDPR), ePrivacy directive (2002/58/EC, amended 2009/136/EC) as currently in force on the protection of personal data processing.

CONTROLLER

Responsible for the processing of personal data in accordance with applicable law is TMS Ltd (hereinafter the Company), which is based in ATHENS, at 36 DIM. KAMPOUROGLOU Street, ATHENS

This Policy is an integral part of the Terms of Use. The last update of the Policy is listed at the beginning of this. The Company manages the personal data of its users in accordance with national, Community and international law regarding the protection of the individual from the processing of personal data.

These terms are subject to change so users of the website are kindly requested to check them at regular intervals. Please visit and read this Policy periodically, as we may modify it from time to time.

We use the popular SSL (Secure Socket Layer) method to visit our site in conjunction with the highest level of encryption supported by the browser. This is a 256-bit encryption. If your browser does not support 256-bit encryption, we will use 128-bit v3 technology. The encryption of a page of our website is displayed by the closed representation of the key or lock icon in the bottom status bar of the browser.

The Company also takes appropriate technical and organizational security measures to protect your data from accidental or intentional tampering, partial or total loss, destruction or unauthorized access by third parties. Our security measures are constantly improving in line with technological developments.

The Company makes every reasonable effort to secure the personal data of its users, observing strict security measures. Users, however, are informed that sending confidential information via e-mail services is not the safest way to send it, as it involves the risk of being read this information by unauthorized third parties.

How long your data is stored

The data provided by you is kept and stored by us only for the period of time required for the fulfillment of the purpose for which you have communicated your data to us and in compliance with the applicable legal provisions. In any case, you have the right to revoke your consent at any time with effect for the future.

Where do we store your data?

The data we collect from you is stored within the European Economic Area.

2. USER RIGHTS

2.1 Summary of your rights in accordance with the applicable Personal Data Protection Law.
The users, who have disclosed their personal data to the Company have the following Rights:

2.2 Right of access:
Pursuant to Article 15 GDPR, you have the right to request information about your personal data that we process. In particular, you have the right to request that we provide you with information about the purposes of the processing, the category of personal data, the categories of recipients to whom your data has been disclosed or the planned storage time, whether there is a right to correct, delete or limiting the processing or the opposite of processing them. For this purpose you can send us an e-mail at gdpr@tms.com.gr

2.3 Right of Correction
Pursuant to article 16 of GDPR, you have the right to request the correction of your personal data if it is inaccurate or their completion if it is incomplete, by sending an e-mail to gdpr@tms.com.gr

2.4 Right of deletion:
Pursuant to Article 17 of GDPR, you have the right to request from us the deletion of stored personal data processed by the Company, especially when:

  • Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
  • The processing of your data is based on your consent and you revoke this consent.
  • Your data has been processed illegally.
  • The above right does not exist in particular when:
    • The processing of your data is necessary for the establishment, exercise or support of legal claims.
    • The processing of your data is necessary for the observance of a legal obligation of the Company that imposes the processing.

In any case, we will inform you about the satisfaction or dissatisfaction of your request and in case of dissatisfaction, the reasons for which it is due.

To exercise your above right you can send us an e-mail at gdpr@tms.com.gr

2.4 Right of objection:
Pursuant to article 21 of GDPR you have the right to object to the processing of your personal data based on a legal interest of the Company. In this case, we will stop processing your personal data unless we can prove that we have compelling and legitimate reasons for processing that outweigh your rights and freedoms or to establish, exercise or uphold legal claims.

To exercise your above right you can send us an e-mail at gdpr@tms.com.gr

2.5 Right to object to direct marketing:
You have the right to object to the processing of your personal data for the purpose of direct marketing.
You can express your desire in the following ways:

  • Following the instructions that accompany each e-mail with promotional content
  • By sending an e-mail to gdpr@tms.com.gr

2.6 Right to portability:
Pursuant to article 20 of GDPR in cases where the Company processes your personal data by automated means based on your consent or under contract, you have the right to receive a copy of your data in a structured, commonly used and machine readable format. You can also request the direct transfer of your data to a third party. The above right only applies to personal data that you have provided to us.
To exercise your above right you can send us an e-mail at gdpr@tms.com.gr

2.7 Restriction right:
Pursuant to the article 18 of GDPR you have the right to restrict the processing of your personal data in the following cases:

  • When you question the accuracy of your personal data and until the Company verifies the accuracy of this.
  • When the processing of your data is illegal and you object to their deletion, asking instead to restrict their use.
  • When the Company no longer needs your personal data for the purposes of processing, but this data is necessary for you to establish, exercise or support legal claims.
  • When you object to the processing of your data by the Company based on the legal interest of the latter and until the existence of the illegal reasons of the Company that prevail over your freedoms or rights is verified.

To exercise your above right you can send us an e-mail at gdpr@tms.com.gr

2.8 Right to lodge a complaint with the competent supervisory authority:
As the Subject of the data you provide to us you may at any time exercise the rights provided for in Regulation (EU) 2016/679, including the right to information and access, correction, deletion (right to be forgotten), restriction of processing, portability and the right objection to processing using the appropriate forms. These rights are exercised by e-mail to the Data Processor gdpr@tms.com.gr free of charge unless they are repeated frequently and have administrative costs for us, in which case you will be charged the relevant costs. If you exercise any of these rights, we will take all possible measures to satisfy your request within thirty (30) days of receiving the relevant request, after informing you either of its satisfaction or of the reasons that prevent the satisfaction of it.

You have the right to appeal to the Personal Data Protection Authority for issues related to the processing of your personal data. For the competence of the Authority and the way of submitting a complaint, you can visit its website (www.dpa.gr -> My rights -> Submitting a complaint), where there is detailed information.

3. DATA COLLECTION AND USE

3.1 The Company uses the data it collects for legitimate and lawful purposes related to the fulfillment of its legal interests and does not transfer, sell, assign or exchange them with any third party outside the Company. In addition, it takes all reasonable steps to ensure that the processing of Personal Data is reliable, accurate and complete.

3.2 In the event that the users of the website voluntarily provide their personal data (eg name, address, telephone number or e-mail address), the Company may collect them in a File and processed for the purpose mentioned below.

3.3 The purpose of the processing is the communication with the consent of the personal data providers, to provide information to interested parties about our programs, information about future events, various educational news and circulars or in case the visitor wishes to become a member of our Website in order to be able to use its services, such as sending electronic newsletters (newsletter) or sending information material, which has advertising purposes and promotes the company’s services to interested parties.

3.4 The recipient of personal non-sensitive data is only the Company. Any communication with the webmaster is done by e-mail at gdpr@tms.com.gr

3.5 The Company and if the user gives his consent collects personal data:

(a) When filling in our newletter form the following are collecting

  • E-mail address (Email)

(b) When filling in your details in the relevant contact form from which the following are collected:

  • Name
  • Email
  • Telephone number

3.6 The data are collected and used for the fulfillment of the purposes of the Company as mentioned above and the legal basis for processing in accordance with article 6 par. 6 lit. (a) of the Regulation. In any case, you have the right to revoke your consent to the processing of your data at any time by the procedure described in detail in a previous article.

How long do we store your personal data?
We will retain your personal information for the purpose of direct marketing until you withdraw your consent or object to the use of your personal data for the purpose of direct marketing.

3.7 Electronic newsletters – Newsletters

If the user has completed the relevant field and has consented to the sending of informative and / or promotional material to him for advertising purposes, the e-mail address you submit to us will be forwarded to MailChimp, service provider & marketing via e-mail. You have the right to revoke your consent at any time, by sending an e-mail to gdpr@tms.com.gr and the right to object to the use of your personal data for the purposes of direct marketing or the receipt of our electronic newsletters. In each newsletter you receive you also have the option to unsubscribe with a relevant link at the end of the email. Your email address will remain in the above databases until you explicitly request its removal. You can do this by using the unsubscribe links contained in any of the email newsletters we send you or requesting removal via email. When you request removal by email, send us your email using the email account listed in the mailing list.

If you are under the age of 16, you must obtain the consent of your parents, guardians or custodians before signing up for our email newsletter.

If you have given us your express consent to the use of your personal data for advertising or informational purposes, we will use your data for this purpose until you withdraw your consent.

If your email address remains on our database then you will receive periodic email updates from us.

4. NETWORKING AND DISCLOSURE OF PERSONAL DATA

4.1 The Company undertakes not to sell, rent or in any way publish and / or disclose the personal data of the users of the website to any third party.

4.2 The Company may transfer personal data of its users to third parties legal and / or natural persons only if (not all terms apply at the same time):

  • Has the explicit consent of users to channel personal data.
  • The channeling of personal data to legal entities and/or individuals who cooperate with the Company becomes necessary for the realization of the wishes of the users. The legal entities and individuals that cooperate with the Company have the right to process the personal data that the users of the website submit to it only to the extent that is absolutely necessary for the provision of support to the Company.
  • It is required due to compliance with the relevant provisions of the law and to the competent authorities only.

5. MONITORING INFORMATION

5.1 Information we receive automatically when you visit our Website. We may collect behavioral tracking data from the Website, such as how you use it, which pages a user visits, time spent on the site, number of pages visited, from which websites came to our corporate website. This data may be stored on third-party services such as Google Analytics for the purpose of improving the company’s advertising operations. This data does not identify users and this data is kept for up to two (2) years. When you visit the Website, the web browser sends data to our servers. This information may include the following:

  • your IP address,
  • the date and time of your visit to the Website,
  • the referral URL (ie the website from which the user came),
  • the pages you have visited on our website,
  • information about the device you are using and your web browser (web browser type and version, operating system, etc).

5.2 During the use of the website, data such as the user’s IP address, his browser, his operating system, the date and time of each call to our servers and other similar data are collected and stored in log files of our server. . This information can not identify the user, but they are needed to monitor the smooth operation of our servers, but also to protect the website. Then, if we have obtained your consent to the above, we may provide this information to advertisers and other affiliates, to improve our Services or to provide other ancillary services. None of this information can be linked to the identity or other Personal Data of individual users. We allow third parties to display ads and/or collect certain anonymous information when you visit the Website. These companies may use anonymous, non-personally identifiable information during your visits to the Website or other websites in order to provide advertisements for services that you may be interested in.

5.3 Third Party Applications Google Analytics (Google Inc.)

For advertising purposes, traffic data is provided to third-party services, such as the Google and Facebook platform, for the purpose of displaying advertising messages. This data is kept for a period of up to 2 years. Google Analytics is provided by Google Inc. (“Google”) and uses the data collected to monitor and review the use of this Application, generate reports about its activities and share them with other Google services. Google may use the data collected to create contextual and customized ads for its own ad network. Personal data collected: Cookies and Usage Data. Privacy Policy

5.4 Social media
We place on our website – according to article 6 par. 1 f GDPR – Social Plug-ins from the social networks Facebook, Twitter and Instagram, in order for our website to become better known. This commercial purpose must be regarded as a legitimate interest in accordance with the provisions of the GDPR. Responsibility for this function with privacy policy must be secured by the respective providers. The integration of plug-ins by us is done through the so-called “double click” method for the best possible way to protect our website visitors.

Facebook
On our website, Facebook plugins are used to personalize their use. This is why we use the “LIKE” or “SHARE” button. This is an offer from Facebook.

If you visit a page of our site that contains such a plugin, your Browser creates a direct link to the Facebook servers. The content of the plugins is transferred from Facebook directly to your browser and embedded by it on our website.

By integrating the plugins, Facebook receives the information that your browser has access to the corresponding page of our website, even if you do not have a Facebook account or you are not connected to Facebook. This information (including IP address) is transmitted by your browser directly to a Facebook server in the US and stored there.

If you sign in to Facebook, Facebook may link a visit to our site directly to your Facebook account. If you interact with the plugins, for example by pressing the “LIKE” or “SHARE” button, the corresponding information is transmitted directly to a Facebook server and stored there. The information will also be posted on Facebook and displayed to your Facebook friends.

Facebook may use this information for advertising, market research and personalized Facebook pages. For this purpose, Facebook creates user profiles, related to interests, relationships, etc., to evaluate, for example, the use of our website in relation to the ads that appear on Facebook, to inform other Facebook users about your activities in our website and provide other services related to the use of Facebook.

If you do not want Facebook to link the data collected through our website to your Facebook account, you must log out of Facebook before visiting our website.

For the purpose and scope of the data collection and further processing and use of the data by Facebook, as well as the relevant rights and settings related to the protection of your privacy, refer to the privacy policy (https://www.facebook.com/about/privacy/) of Facebook.

Twitter
Our website incorporates plugins from the Twitter Inc. network. (Twitter). Twitter plugins (tweet button) can be identified by the Twitter logo on our website. An overview of tweet buttons can be found here (https://about.twitter.com/resources/buttons).

When you visit a page on our site that contains such an add-on, a direct link is established between your browser and your Twitter server. Twitter receives the information you have visited on our site with your IP address. If you click the Twitter “tweet” button while logged in to your Twitter account, you can link the contents of our pages to your Twitter profile. This allows Twitter to link your visit to our pages to your user account. We point out that as providers of our websites we do not know the content of the transferred data and their use by Twitter.

If you do not want Twitter to link your visit to our pages, log out of your Twitter account.

More information can be found on Twitter’s privacy policy (https://twitter.com/privacy).

Instagram
Our website uses plugins of the social network Instagram, the company Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, United States of America (“Instagram”).

Plugins are marked with the Instagram logo, for example in the form of an Instagram camera. When you visit a page on our site that contains such an add-on, your browser connects directly to your Instagram servers. The content of the plugins is transmitted from Instagram directly to your Browser and is integrated in our page. Through this integration, Instagram receives the information that your Browser has access to the corresponding page of our website, even if you do not have an Instagram profile or you are not connected to Instagram. This information (including IP address) is sent by the browser directly to an Instagram server in the USA. and stored there.

If you are logged in to Instagram, Instagram can directly link your visit to our site to your Instagram account. If you interact with plugins, for example, by clicking the “Instagram” button, this information is transmitted directly to an Instagram server and stored there. The information will be posted to your Instagram account and displayed there in your contacts.

If you do not want the information collected through our website to be linked directly to your Instagram account, you must log out of Instagram before visiting our website.

For more information, see the privacy policy (https://help.instagram.com/155833707900388) of Instagram.

6. COOKIES

6.1 Cookies are small text files that contain information stored in your computer’s web browser and can be removed at any time. They can help us identify your computer the next time you visit our siteor enable some features on our web pages. Cookies are classified in the following categories:

Strictly necessary cookies
Login cookies
Performance cookies
Targeting/advertising cookies

6.2 For the smooth operation of its websites the Company uses cookies. Cookies are text files that are stored by the user’s browser on his computer. By using cookies, the Company can provide services that would not be possible without them. Users can delete cookies from their browser, but also disable them.

If you do not want cookies, you have the following options:

  • Change your browser settings to delete or prevent cookies from being stored on your computer or mobile device without your explicit consent. The “help” section in your browser will provide you with information on how you can manage your cookie settings.
  • Change the cookie settings in relation to the Website by following the link entitled “Cookies” at the bottom of the Website.

The Cookies we use

  What it does/Utility
Session cookie Session cookie is saved to registered users only after logging in, and is deleted when browser closes
Persistent login cookie Saved only to registered users who have enabled the “Stay Connected” option when logging in. This cookie is deleted only if the user chooses to log out of the website (“Logout” option in the main menu). Note that the session related to this cookie has some restrictions regarding access to specific pages of tms.com.gr. For example, to modify your profile information you need a session cookie, which means that you will be prompted to re-enter your email address and password.
viewed_cookie_policy Used to display the message regarding the acceptance of cookies and the storage of the user’s choice. It lasts 1 year.
has_js It is saved to all site visitors for the duration of the session. It lasts until one leaves our website (to close the browser or the tab) and allows the website to know whether the visitor’s browser supports the Javascript language.
Google Analytics cookies They belong to the category of third party cookies and are stored to all visitors of the website. They collect information about how visitors use our website and their storage time is determined by Google’s usage policy. These cookies collect information in anonymous form, including the number of visitors to the website, the origin of the visitors and the pages visited within our site. We use the information to write reports that help us improve our website. For more information: Google privacy policy For more information: Google privacy policy

More information on deleting or controlling cookies is available at www.aboutcookies.org.

7. MINORS UNDER 16 YEARS OLD

7.1 Through our website we do not knowingly collect personal information from minors under 16 years of age without the prior consent of the parents/guardians/or custodians of minors. If we find that we have collected any personal information from a minor under the age of 16 without verifiable parental consent, we will delete the information from our database as soon as possible. If you believe we may have collected information from a minor under the age of 16, please contact us.

8. UPDATING AND CHANGING THE PERSONAL DATA POLICY

This temporary data privacy policy is effective from May 25, 2018.

As a result of the further development of our website and its offerings or due to changes in legal or official requirements, our privacy policy may change. The current privacy policy can be viewed and printed by you at any time https://tms.com.gr/en/privacypolicy