Privacy Policy

Elbridge Capital Management V.C.M. S.A. values and respects your privacy and is committed to protecting your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and with Greek law 4624/2019, as in force.

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

For the purposes of the applicable legislation, the Controller is the Company, which determines the purposes and the means of the processing of your personal data. The purpose of this policy is to give you as much information as possible about every form of processing of your personal data — collection, storage and the rest — and to inform you of your rights.

By accessing this 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, which contain further indications on privacy and security adopted by this website.

1. Data we collect and the purpose of collection

We only collect personal data where it is necessary for specific, explicit and legitimate purposes.

Data you provide directly

• Contacting us: we may collect your name, email address, telephone number and any other information you choose to share, in order to respond to your enquiry, resolve an issue, or provide client service.
• Subscribing to communications: if you subscribe to our newsletter or to marketing communications, we collect your name and email address in order to send you relevant updates.
• Job applications: when you apply for a position or send us your CV, we may collect your name, contact details, education history and employment history. This data is used solely for recruitment purposes.

Data collected automatically

• Technical data: your Internet Protocol (IP) address, browser type and version, time-zone setting, operating system and platform.
• Usage data: technical information recorded in our hosting provider’s server logs when you request a page, such as the page requested, the time of the request and your IP address. We use no analytics tools and we do not track you from page to page or across other websites.

Third-party sources

Occasionally we may obtain personal data from publicly available sources or from third-party providers, for purposes such as completing our records or verifying information.

2. Legal basis for processing

• Consent: where you have explicitly consented to the processing, for example by subscribing to marketing communications.
• Contractual obligation: where processing is necessary for the performance of a contract, or to take pre-contractual steps at your request.
• Legal obligation: where we are required by law to process your data, for example by retaining records for tax or regulatory purposes.
• Legitimate interests: where processing is necessary for our legitimate interests and your rights and freedoms are not overridden — improving this website, securing our systems, and conducting business analysis.

3. Data sharing and transfers

• Service providers: we work with providers who assist us with hosting, data storage and technical support. Each acts as a processor on our behalf and is bound by strict confidentiality and security measures as required by the GDPR.
• Professional advisers: we may share data with legal, accounting or other professional advisers in order to obtain advice or manage risk.
• Legal and regulatory authorities: we may disclose personal data where required in order to comply with legal obligations, to respond to regulatory enquiries, or to protect our legitimate interests.

International transfers. If we transfer personal data outside the European Union and the European Economic Area, we ensure that adequate protection is in place — by relying on countries covered by an adequacy decision of the European Commission, or by implementing Standard Contractual Clauses.

4. Retention period

We retain your personal data for as long as is necessary to fulfil the purposes set out in this policy, unless a longer retention period is required by law.

• Contact information: retained for as long as needed to provide support or resolve an enquiry, then deleted where no further legitimate business need exists.
• Marketing data: retained until you withdraw your consent or unsubscribe.
• Transaction records: retained in accordance with legal and regulatory requirements.

5. Security measures

The Company implements appropriate technical and organisational measures to protect your personal data.

• Encryption of sensitive information in transit and at rest.
• Access control: access to personal data is limited to authorised personnel.
• Regular assessments: periodic security audits and vulnerability assessments.

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

6. Your rights under the GDPR

• Access: request a copy of your personal data and information about how we process it.
• Rectification: have inaccurate or incomplete data corrected.
• Erasure: request deletion of your data where there is no longer a need to retain it, subject to our legal obligations.
• Restriction: request that we restrict the processing of your data in certain circumstances.
• Portability: receive a copy of your data in a structured, commonly used and machine-readable format.
• Objection: object to processing based on legitimate interests or on direct marketing.
• Withdrawal of consent: where processing is based on consent, withdraw it at any time, without affecting the lawfulness of the processing carried out beforehand.

To exercise your rights, please contact us at compliance@elbridgecapital.com or by post at 6 Thetidos Street, Athens 115 28, Greece.

We aim to respond to every legitimate request within one month of its submission. Occasionally it may take longer, depending on the complexity of the request and on the number of requests received; in that case we will notify you and keep you informed. If a request is manifestly unfounded, excessive or repetitive, we may either charge a reasonable fee, of which we will inform you, or decline to act on it.

If you believe your rights have been infringed in any way, you may also lodge a complaint with the competent supervisory authority, the Hellenic Data Protection Authority: 1–3 Kifissias Avenue, 115 23 Athens; telephone (+30) 210 647 5600; contact@dpa.gr.

7. Cookies and tracking technologies

Cookies are small text files stored on your device when you visit a website. They allow the website to recognise your device, to retain your preferences, and to improve functionality on future visits. The clauses below set out the categories that exist and, specifically, which of them this website uses.

Categories of cookies

• Strictly necessary cookies — essential for the website to function, enabling core features such as security, authentication and accessibility.
• Performance cookies — anonymous data about how visitors use the site, such as the pages visited and the time spent on them.
• Functional cookies — remember your preferences and choices, such as your language setting.
• Targeting or advertising cookies — track browsing activity in order to show relevant advertising and to measure its effectiveness.
• Third-party cookies — set by third-party services such as social platforms or embedded content, and governed by those third parties’ own privacy policies.

What this website sets

• None. This website loads no analytics, no advertising and no third-party content, and therefore sets no cookies and reads nothing from your device. Should that change, this clause and a consent notice will be added before anything is set.

Managing cookies

You can manage or disable cookies through your browser settings: most browsers allow you to view the cookies stored on your device, to block certain categories, to delete existing cookies, and to set preferences for individual websites. Please note that disabling cookies may affect the functionality of this website and your ability to use certain features.

8. Policy updates

We reserve the right to update or modify this Privacy Policy in order to reflect changes in data protection law or in our business practices. Any modification takes effect when it is posted on this website, and we encourage you to review this page periodically.

9. Contact us

• Controller: Elbridge Capital Management V.C.M. S.A.
• General Commercial Registry (GEMI) number: 161709401000.
• Email: compliance@elbridgecapital.com.
• Telephone: (+30) 210 440 4800.
• Postal address: 6 Thetidos Street, Athens 115 28, Greece.