Privay Policy – GDPR
The purpose of the present policy lies at the determination and formulation of the general scope and basic principles that the individual enterprise acting under the name of Franco Nikola Cupolo abides by and follows, with a legal seat in Piazzale Delle Belle Arti 3, Italy, VAT 16695181004 and distinctive title “Mareco” (hereafter referred to as “Mareco”) as far as the management of personal data and the protection of their safety, confidentiality, integrity and accessibility is concerned.
2. SCOPE OF APPLICATION
The present Policy is applicable to all personal data that Onbyte.gr handles in the context of its activities.
3. POLICY’S APPLICATION RESPONSIBLE
Management
Every partner that handles and/or has access to personal data
4. DESCRIPTION
4.1 In general
Mareco identifies and respects the importance of personal data which it handles in the context of its activities, and for that reason it has adjusted its policy towards the guidance and requirements of General Data Policy Directive (herafter referred to as GDPR) 2016/679/EU.
With the present statement Mareco wishes:
To inform the customers in what capacity, for what purpose and with which legal basis it processes personal data, that means information that can be used in the immediate or indirect people identification
To determine the data categories, the data sources (when data are not given by the person itself) and the personal data’s maintenance’s time frame determination criteria,
To inform of the subjects’ ability to exercise in accordance to their personal data their rights of access, the rights to rectification, the right to erasure, the rights to restrict processing and the right to object to the processing, the ability of the people to report any breach of their personal data rights to Data Protection Authority,
To determine the principles that governs observance of the relevant data protection policies and security guaranties of personal data by Mareco.
For any further question or query, or if anyone wishes to receive a copy of the present statement or wishes to exercise any of the personal data related right, the concerned individual may address the Manager of Mareco.
4.2 Information of Data Processor & Representative
Data Processor: Mareco Global
Data Processor’s Representative: Mareco Global
4.3 Who collects personal data?
Mareco is stationed in Piazzale Delle Belle Arti 3 Rome, Italy, was found in 2021 and mainly create and deliver bespoke port and terminal services for investors, operators, funds and concessioners.
The present statement covers the personal data collection by Mareco during the development of its activities, including its presence in third-party websites, platforms and applications.
It is dully noted that during your visit at our Mareco website data are being collected with regard to your interaction with the website and cookies are being installed (see cookie policy). Third-party websites in general apply their own Privacy Policies, Terms and Regulations. We suggest that you read those, before any use or navigation through these websites.
4.4 Which personal data are being collected?
A personal information data is considered every information that has to do with an identifiable or identified physical being (“data subject”) (art 1 Regulation 2016/679). The identifiable physical person is the one whose identity can be verified, directly or indirectly, through reference to an identity element, such as identity card number, position data, online ID or one or more factors that coincide with the physical, physiological, genetic, psychological, economic, cultural or social identity of the human person itself.
4.5 How are personal date being collected ?
With help of each one of the following platforms and social media we collect and process certain data (such as user name you use or phony number or email address etc) which specify your identity.
We may collect personal data through various sources, such as:
Personal data that are being collected by our suppliers and partners,
When you are being registered as a member or providing your data voluntarily,
When you are communicating with us through our website or social media that we handle or through email at the formal business mail account,
In particular, we process:
Data which you provide when creating a user account at our Social Media or Applications or Websites of Mareco through internet browser or mobile or through personal contact with our offices or our salesmen and specifically data such as e mail address and login password or name, surname, address, number etc.
Data which you provide when registering as a customer of Mareco either first hand to our employees or remotely (electronically or by mail) and specifically data, such as identity card, tax details, address, phone number etc.
Data which you provide when you register at our email services
Traffic data of our website
Data which are being collected by using cookies at your browser
User name of your social media account, when you interact with us through these channels, in order to help us respond to comments, questions or remarks.
Moreover, we collect and store specific personal data each time someone interacts with us by internet, where we use cookies and surveillance technology. Furthermore, the browser the users are using, has access to the website and its entries, as well as content which is being projected by Mareco or on its behalf on other websites.
We note that we do not collect personal data of special categories, health data aside, regarding race, national origin, religion, sexual orientation or genetic biometric data etc, which are categorized as special personal data and receive further protection according to European personal data legislation.
4.6 For what reasons are my personal data used?
Purpose of the processing is always correlated to each time’s function. Specifically:
Regarding the sharing of information about our products, services and activities, as well as for other commercial promotion purposes:
Newsletters: With your consent, we will use your personal data, preferences and exchange info in order to inform you through email, internet, telephone (SMS/Viber etc) and/or social media about products and services, including personalized offers, sales etc. You may at any time withdraw your consent.
Web push notification: Depending on your navigation, you may receive, after having given your consent, notifications about our offers, news, wishlist and purchase basket. You may at any time withdraw your consent.
About function, improvement and maintenance of our company activity, our products and services
Development and improvement of systems and services of our products. This is based on our legal business interests.
In order for the most interesting content to be shown to you on our websites or applications or teams handled by us on social media, we will use your data, that we have already collected about your favourite products/services. This is done based on your consent to receive notifications or -for websites- your consent to putting cookies on your device. For example, it is possible to show you a list of products you viewed recently or to offer you suggestions based on your purchase history and any other data you have shared with us.
In order to send you research and evaluation requests in order to improve and enhance our services. These requests may be sent through email or SMS (Viber etc). We have legal interest in doing so, as far as that helps our products and services be more suitable to your needs. Of course, you may at any time object to the reception of these requests, updating your preferences of your account or contacting directly the relevant Mareco
4.7 Which is the legal basis of processing?
Legal basis for processing in cases of newsletters and notifications in general is your consent, which is provided either by your registration as customer of Mareco or through your voluntarily handing of your personal data, when these are requested. In the context of social media, you give your consent by like or follow at our pages, which you can revoke as easily in the same way (unlike or unfollow). Your consent implies that you have accepted our personal data policy, which is shown at an obvious and easily accessible spot at each media.
4.8 Profiling
Mareco does not use personal data for purposes of profiling whatsoever.
4.9 Transfer of personal data to third parties : To whom may my personal data be transferred to?
Mareco does not in general transfer or share your personal data to or with third parties.
Mareco shares to other third parties, to the extent that it is necessary for purposes of:
Compliance to state application, court ruling or law in effect,
Deterrence of websites’ or applications’ or teams’ illegal use or Terms of use and policies’ infringements
Our own protection from third parties’ lawsuits
Contribution to deterrence or research of fraud cases
Yours earlier sharing of your personal data to those third parties with your consent.
4.10.1 Hyperlinks to third parties’ websites
With help of suitable hyperlinks inside our website and pages we handle on social media, Mareco gives access to third parties’ websites. These hyperlinks only serve to ease visitors during their scroll through internet. It does not in any way represent indication or acceptance of these websites’ content. Each hyperlink may lead to a different website, in which navigation and visit is subject to its own terms of use and/or policies.
Mareco does not bear or accepts responsibility of any kind regarding content or personal data policies of the websites where hyperlinks lead. The use and visit of each website these hyperlinks lead to is made solely with the absolute responsibility of each user. We encourage that you read each visiting website’s policy.
Sponsor and/or advertised may use their own cookies, web beacons or other on-line technologies on their banners and/or add-ons that may appear on our websites or emails, special promo actions or newsletters that we send you. Various advertised companies may use other enterprises besides ours, in order to serve you their commercials and measure users’ reactions to them and those enterprises (Ad Servers) may collect non-personal data through cookies or web beacons on our website. In some cases, data collection may be facilitated by an instant redirection of your web browser to a website of an Ad Server or other third party acting on behalf of a sponsor, advertised or partner, before redirecting your web browser to the desired location. This redirection will not be visible to you.
We do not control in any way these third party measurement techniques or how these enterprises handle non-personal data that they collect. However, we request from sponsors advertised and Ad servers that collect info through cookies or web beacons on our website to agree that they will not collect any personal data from users without their consent. You should always check with personal data policies of other websites that you visit through our website, in order to fully understand how they use cookies or web beacons.
4.10.2 Personal data transfer
Personal data we collect (or process) in context of social media, applications and/or teams on social media are stored in Greece and in EU. However, some of our data recipients with whom Mareco shares personal data may be situated in third countries outside of the country where initial collection was made. Legislation in these countries may not provide the same personal data protection level in comparison to the place where you originally provided your data. However, when we transfer your data to third countries’ recipients, including USA, we commit ourselves to protect your personal data as stated in the present policy and according to relevant legislation.
Important note: We are not responsible for means or way that each of the following platforms handles and processes your personal data (Google, Facebook, Instagram).
You should be aware that according to Decision 2010/87/EU it is imposed to every data exporter and data recipient the obligation to check, before any transfer, with regard to specific instances of each transfer, if the required level of data protection is in effect in the third country and that decision 2010/87/EU obliges data importer to inform data exporter for any compliance to standard contractual clauses weakness and, if necessary, to any additional measures except those available by the specific clause, who, in turn, has to suspend data transfer and/or terminate contract with data importer.
With Case C-311/18 (Data Protection Commissioner v Facebook Ireland Limited and Maximillian Schrems), European Court of Justice examined the Decisions’ for the Privacy Shield validity (απόφαση 2016/1250 in regard to adequacy of protection offered by Privacy Shield Clause between EU-USA and judged that USA’s internal legislation’s requirements and specifically certain programs that allow access to data transferred from EU by American public entities for national security reasons, lead to personal data’s safety limitations, which are not delimited in any way suitable to requirements fundamentally equivalent to those set by EU law and that this legislation does not grant data subjects rights that can be invoked against American authorities in front of a court of law. For these reasons, it annulled this Treaty.
4.10 For how long are my personal data kept?
Personal data’s storage’s duration depends mainly on the process purpose, as even simple storage constitutes a process act, which is allowed only if it is governed by processing principles. After passage of time for personal data storage, they are deleted.
Suppliers’ and partners’ personal data are being kept for as long as it is required for the needs of our contractual obligations and to the fulfillment of our legal obligations arising from them.
4.11 What are my rights?
Personal data process is connected to relevant rights of yours, which, notwithstanding possible provisions that may limit their exercise, are:
The right to be informed. You have the right to receive accurate, transparent and understandable information regarding use of personal data and rights. For that purpose we provide you with information with the present Policy and we urge that you address any queries to us.
Τhe right to access and rectification. You have the right to access, rectify and update any of your personal data at any given moment.
Τhe right to portability. Your personal data that you have provided are portable This means that they can be transferred, copied or conveyed electronically.
Τhe right to erasure. If you revoke your consent to data process, you have the right to ask for the erasure of your data.
Τhe right to restrict data processing. You have the right to restrict the extent of processing of your data.
Τhe right to revoke your consent. If legal basis of data processing is your given consent, you can any time revoke this consent by contacting us.
Τhe right to object. It exists in cases where data processing takes place for purposes of direct commercial marketing (eg newsletters etc).
Τhe right to file a complaint. You may address the National Data Protection Authority in order to file a complaint regarding use and processing of your personal data.
Rights in relation to automated decision making and profiling. You have the right to not be subject to a decision based solely on automated process and has legal or other significant consequences for you. In particular, you have the right:
For a human interference to take place,
To express your opinion,
To seek and receive explanations about the decision that occurred after an evaluation and
To object to that decision.
In the event of exercising one of the above rights, we shall take any possible measure to satisfy your request in a reasonable deadline and at the latest one (1) month after the registration of your request, informing you in written for its satisfaction or the reasons that may hinder the exercise of your right according to GDPR. We dully note that in some cases satisfaction of your rights may not be possible, eg when this satisfaction is contrary to legal obligations or objects a certain contractual legal basis for data processing.
If you think that certain right is violated or Mareco does not follow any legal obligation according to this policy and having firstly contacted our offices for this matter, which means that you have exercised your rights towards Mareco and either you have not received an answer in one month time (or two months in cases of complex requests) or you believe that Mareco’s answers is not satisfactory and your issue is not revolved, you have the right to file a complaint to the competent national Data Protection Authority (DPA), L. Kifisias 1-3, ZIP 115 23, Athens, email: complaints@dpa.gr, FAX: 2106475628.
4.12 How are my personal data being protected?
We have taken necessary organizational and technical measures to protect personal data from any misuse, interference, loss, unauthorized access, alteration or publication. The measures we use include application of proper techniques for access control, technical security of information as well as guarantee of encryption, pseudonymization and rendering anonymous, when it is possible and necessary.
Access to your personal data is limited only to authorized employees and partners and only when it is necessary for Mareco operations. This access is subject to strict confidentiality obligations when it is assigned to third party-controllers.
4.13 How can I communicate with Mareco;
You may reach us at our at email franco.cupolo@marecoglobal.it or even submit a request through Contact Form at our website.
4.14 Update of our Personal Data Protection Policy
The present policy is subject to renewal, review and update when needed in order to adjust to legal changes and in order to respond to comments and needs of personal data subjects and of products’, services’ and internal procedures’ changes of Onbyte.gr. Every change and update will be published in a change of last update’s date on Policy. For that reason, we urge that you inform yourselves on a regular basis for any changes in our policy on the website. To the extent that these changes may affect your given consent, we shall inform you directly.
4.15 Applicable law
Law, as it is applied according to General Data Protection Regulation (2016/679/EU) and the national and European legal framework for personal data protection in effect.
Competent jurisdictional authorities for any kind of legal disputes arising in relation to your personal data are Italia Courts.