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Κανονισμός Λειτουργίας - Centre

Operating Rules

Privacy Notice for Employees and Visitors on the processing of personal data through a video surveillance system (CCTV)

Data Controller: 

The Company under the name “ELLINIKO - ETAIREIA ANAPTYXIS AXIOPOIISIS KAI DIACHEIRISIS AKINITON MITROPOLITIKOU POLOU ELLINIKOU – AGIOU KOSMA MONOPROSOPI ANONYMI ETAIREIA” and the distinctive title “HELLINIKON S.M.S.A.”, with registered offices at Maroussi of Attica (37, Kifissias Avenue).

Data Protection Officer: 

The contact details of the Company’ s Data Protection Officer is the following email: TheEllinikon.PersonalData@lamdadev.com. 

Purpose and legal basis of the data processing: 

The Company uses closed-circuit television (CCTV) in order to protect natural persons and goods (security). The processing is necessary for the purposes of the legitimate interests pursued by the Company as a data controller (article 6 para. 1. (f) GDPR).

Legal interests 

Our legitimate interest lies in the need to protect our facilities and specifically the premises of The Ellinikon Experience Park and The Ellinikon Experience Center, including parking area, and the assets located therein from unlawful acts, such as, indicatively, theft. The same applies to safeguarding the life, physical integrity, health, and property of our employees and of third parties lawfully present within the monitored area.

We collect only image data, for example of visitors, employees, and other natural persons who are present and moving within the monitored areas, and we limit recording to locations which we have assessed as presenting an increased likelihood of unlawful acts, such as theft, for example, entry and exit points, parking areas, and the Park’s perimeter fencing, without focusing on areas where the private life of the individuals whose image is captured, including their right to the protection of personal data, may be excessively restricted.

It is noted that the video surveillance system is not used to monitor employees within their workplaces, specifically within the premises of The Ellinikon Experience Park and The Ellinikon Experience Center.

Additionally, it is emphasized that, in any case, the data collected are not used as criteria for evaluating employees’ conduct or performance.

Recipients 

The CCTV material held is accessible only by the competent / authorized personnel of the data controller who is in charge of the security of the premises as detailed above and by the external security company, assigned with the monitoring and management of the CCTV system, to which the assignment of the data processing has been concluded in writing in accordance with the specific conditions set out in Art. 28 of the GDPR.

Furthermore, the CCTV material is transferred, on a case-by-case basis, (a) to the competent Judicial, Prosecutorial and Police Authorities when it contains information necessary to investigate a criminal offense involving persons or goods of the data controller; (b) to the competent Judicial, Prosecutorial and Police Authorities when lawfully requesting data within the performance of their duties, (c) to the victim or perpetrator of a criminal offense, in the case of data which may constitute evidence of the offense and (d) to insurance companies / insurance intermediaries, where this is necessary for the pursuit of claims relating to the payment of insurance compensation (e.g. an accident occurring within the monitored areas).

Data Retention 

We keep the data for fifteen (15) days, subject to more specific provisions of the legislation in force, following which, they are automatically deleted. If during these periods an incident occurs, we isolate part of the video and keep it on a separate file for up to thirty (30) days in order to investigate the incident and initiate legal proceedings to defend our legal interests, while if the incident concerns third parties, we will keep the video for up to three (3) more months.

Data subjects’ rights 

Data subjects have the full range of rights as provided in chapter III of the GDPR, whereas in basic CCTV surveillance systems, the data subjects have in principle the following rights:

  • Right of access: you have the right to know if we process your image and if so, to receive a copy of it
  • Right to restriction of processing: you have the right to request us to restrict processing, for example, you may ask us not to delete data that you deem necessary to establish, exercise or support legal claims.
  • Right to object: you have the right to object to the processing.
  • Right to erasure: you have the right to request that we erase your personal data.
     

You may exercise your rights by sending an email at TheEllinikon.PersonalData@lamdadev.com. To examine a request related to your image, you should tell us when you were within the range of the cameras and give us a picture of you to facilitate us to locate your data and hide the data of third parties pictured. Alternatively, we give you the opportunity to come to our facilities to show you the images in which you appear. Moreover, we would like you to note that exercising the right to object or the right to erasure does not imply the immediate erasure of data or the modification of the processing. In any case, we will answer you in detail as soon as possible, within the deadlines set by the GDPR.

Right to lodge a complaint 

In case you consider that the processing of your data violates Regulation (EU) 2016/679, you have the right to lodge a complaint with the competent Supervisory Authority (www.dpa.gr) through its online portal (https://eservices.dpa.gr/). For more information, please consult the website of the Hellenic Data Protection Authority.