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Privacy Policy

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Introduction

 

Elbridge Capital Management V.C.M. S.A. (hereinafter the “Company”, “we”, “our”) values and respects your privacy and is committed to protecting your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter “GDPR”) as well as by the Greek law no. 4624/2019 “Personal Data Protection Authority, measures for the implementation of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of data” as currently in force.

 

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with us, including through our website, email, and any associated services. 

 

For the purposes of the applicable legislation, Controller shall mean the Company which shall define the purposes and means of processing your personal data, and with this policy, our purpose is to provide you with the most information possible regarding any form of processing of your personal data (e.g. collection, storage, etc.) as well as to inform you of your rights.

By accessing our website or engaging with our services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.

 

We also invite you to read the Terms of Use because they also contain important privacy and security indications adopted by this website.

 

1. Data We Collect and Purpose of Collection

 

We only collect personal data when it is necessary for specific, explicit, and legitimate purposes. Here is a breakdown of the types of data we collect and why we collect them:

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  1. Data You Provide Directly: When you actively provide us with personal data, such as when you:

    • Contact Us: We may collect your name, email address, phone number, and any other information you choose to share to respond to inquiries, resolve issues, or provide client service.

    • Subscribe to Communications: If you subscribe to our newsletter or marketing communications, we collect your name and email address to send you relevant updates and promotional information.

    • Job Applications: When applying for a job or sending us your resume, we may collect personal details such as your name, contact information, education history, and employment history. This data is solely used for recruitment purposes.

  2. Automatically Collected Data: When you visit our website, we may automatically collect certain information about your device, browsing actions, and patterns:

    • Technical Data: This may include your Internet Protocol (IP) address, browser type and version, time zone setting, operating system, and platform.

    • Usage Data: We collect information about how you interact with our website, such as pages visited, time spent on each page, and other actions. This data is collected via cookies, server logs, and similar tracking technologies and helps us enhance your user experience and improve our services.

  3. Third-Party Data Sources: Occasionally, we may obtain personal data from publicly available sources or third-party providers for purposes such as enhancing our customer records or verifying information.

2. Legal Basis for Processing

 

We process your personal data based on one or more of the following legal grounds:

  • Consent: Where you have explicitly consented to the processing of your data, such as subscribing to marketing communications.

  • Contractual Obligation: When processing is necessary for the performance of a contract or to take pre-contractual steps at your funding or other request.

  • Legal Obligation: When we are required by law to process your data, such as retaining transaction records for tax or regulatory purposes.

  • Legitimate Interests: When processing is necessary for our legitimate interests, provided your rights and freedoms are not overridden. This may include improving our website, securing our systems, and conducting business analysis.

3. Data Sharing and Transfers

 

To achieve the purposes outlined in this policy, we may share your data with trusted third parties as follows:

  • Service Providers: We work with service providers who assist us with hosting, data storage, and technical support. Each service provider acts as a data processor on our behalf and adheres to strict confidentiality and security measures as stipulated by GDPR.

  • Professional Advisors: We may share data with legal, accounting, or other professional advisors to obtain advice or manage risk.

  • Legal and Regulatory Authorities: We may disclose your personal data if required to comply with legal obligations, respond to regulatory inquiries, or protect our legitimate interests (such as enforcing our rights or preventing fraud).

 

International Data Transfers: If we transfer personal data outside the European Union and the European Economic Area (EEA), we will ensure that adequate protection is in place, such as relying on countries with adequacy decisions from the European Commission or implementing Standard Contractual Clauses (SCCs).

4. Data Retention Period

 

We will retain your personal data for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law. Specifically:

  • Contact Information: Retained as long as needed to provide customer support or resolve inquiries, then deleted if no further legitimate business need exists.

  • Marketing Data: Retained until you withdraw your consent or unsubscribe.

  • Transaction Records: Retained in compliance with legal and regulatory requirements.

5. Security Measures

 

The Company implements robust security measures, known as Appropriate Technical and Organizational Measures (ATOM), to protect your personal data. These include:

  • Data Encryption: Encryption of sensitive information during transmission and at rest.

  • Access Control: Limiting access to personal data to authorized personnel only.

  • Regular Security Assessments: Periodic security audits and vulnerability assessments to maintain high standards of data protection.

 

Despite these efforts, we cannot guarantee that security measures fully prevent unauthorized access, and we encourage you to use secure devices and networks when interacting with us.

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6. Your GDPR Rights

 

Under the GDPR, you have specific rights regarding your personal data, which you may exercise by contacting us. These rights include:

  • Right to Access: Request a copy of your personal data and information about how we process it.

  • Right to Rectification: Correct inaccurate or incomplete data.

  • Right to Erasure (“Right to Be Forgotten”): Request deletion of your data when there is no longer a need for its retention, subject to legal obligations.

  • Right to Restrict Processing: Request that we restrict the processing of your data under certain circumstances.

  • Right to Data Portability: Receive a copy of your data in a structured, commonly used, and machine-readable format for transfer to another controller.

  • Right to Object: Object to data processing based on legitimate interests or direct marketing.

  • Right to Withdraw Consent: If processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.

 

To exercise your rights, please contact us at compliance@elbridgecapital.com or by postal mail at 6, P. Anagnostopoulou Str. Athens 10673. 

We strive to respond to all legitimate user/visitor requests within one month from the date of submission thereof. Occasionally it may take longer than a month, considering the complexity of your request and the number of requests. In this case, we will notify you and inform you accordingly. However, if your request is manifestly unfounded, excessive or repetitive, we can either impose a reasonable charge, which we will inform you of, or refuse to respond to your request.

 

If you believe that your rights are infringed in any way, you can also submit a complaint to the competent Supervisory Authority:

Hellenic Data Protection Authority

 

Postal Address: 1-3 Kifissias Avenue, P.C. 115 23, Athens

Call Center: +30-210 6475600

Fax: +30-210 6475628

E-mail: contact@dpa.gr

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7. Cookies and Tracking Technologies

 

Our website uses cookies and similar technologies to improve user experience, analyze traffic, and customize content. You may manage your cookie preferences through your browser settings or refer to us for details on the types of cookies used.

 

What Are Cookies?

 

Cookies are small text files stored on your device (computer, tablet, or smartphone) when you visit a website. They allow the website to recognize your device, retain user preferences, and improve functionality for future visits.

 

Types of Cookies We Use

 

We use the following categories of cookies:

  1. Strictly Necessary Cookies:
    These cookies are essential for the website to function properly. They enable core functionalities such as security, authentication, and accessibility. Without these cookies, certain features of the website may not operate as intended.
     

  2. Performance Cookies:
    These cookies collect anonymous data about how visitors use our website, such as the pages visited, and the time spent on the site. The information helps us understand user behavior and improve website performance.
     

  3. Functional Cookies:
    Functional cookies enhance your browsing experience by remembering your preferences and choices, such as language settings or login details. These cookies enable more personalized and convenient interactions with the website.
     

  4. Targeting or Advertising Cookies:
    These cookies track your browsing activity to display relevant advertisements based on your interests. They may also limit the number of times you see an ad and help measure the effectiveness of advertising campaigns.
     

  5. Third-Party Cookies:
    Our website may include cookies from third-party services, such as social media platforms or embedded content like videos. These cookies are governed by the privacy policies of the respective third parties.

 

Why We Use Cookies

 

We use cookies to:

  • Provide a secure and efficient website experience.

  • Analyze visitor behavior to improve website design and content.

  • Save your preferences to personalize your experience.

  • Deliver targeted advertisements and measure their effectiveness.

 

Managing Cookies

 

You can manage or disable cookies through your browser settings. Most browsers allow you to:

  • View cookies stored on your device.

  • Block certain types of cookies.

  • Delete existing cookies.

  • Set preferences for specific websites.

 

Please note: Disabling cookies may impact on the functionality of our website and your ability to use certain features.

 

8. Policy Updates

 

We reserve the right to update or modify this Privacy Policy to reflect changes in data protection laws or business practices. Any modifications will be effective upon posting on our website, and we encourage you to review this policy periodically.

 

9. Contact Us

 

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us at:

  • Data Controller: Elbridge Capital Management V.C.M. S.A.

  • General Commercial Registry Number: 161709401000

  • Contact Email: compliance@elbridgecapital.com

  • Telephone: +30 210 4404800

  • Postal Address: 6, P. Anagnostopoulou Str. Athens 10673 

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