The new General Data Protection Regulation 2016/679 of the European Parliament and of the Council, known as the GDPR, whereby personal data protection is reinforced throughout the European Union, has been effective since 25 May 2018. ELINOIL S.A., treating your personal data with respect, informs you through this protection policy about the way it protects the privacy of your communications, collects, processes, uses and stores your personal data as well as about the way you can communicate with us in case you object to any matter related to the processing of your Data and the exercise of your rights in general.
Our company reserves the right to amend and adapt this policy whenever it considers it necessary; you will be notified about this by seeing the updated version on our website www.elin.gr
We collect personal data only for purposes directly connected to our business activity. We treat such data very responsibly.
Processing Principles
In the processing of your data, we follow the main principles mentioned below:
Types of data and collection sources – Purposes – Legal basis for the processing
The types of personal data that we collect from you and process are directly related to the agreement concluded between us, or to the services or/and the products which you choose us to provide you with.
What do we collect?
(a) Identification and contact details, information confirming classification under a special customer category (e.g. vulnerable customer) by competent managers, copies of connection contracts signed by competent managers, business commencement certificate from the Tax Office, special information justifying the use of a specific tariff, (b) information about the meter of the property that is or will be the object of a supply contract, proof of legal use of the property, bills or/and from previous supplier, consumption data obtained by customers or/and competent managers, information on transactions and payments made in the framework of our contractual relationship, information related to the communication of prospective or existing customers with the Customer Support Department of the Company, (c) credit reporting information collected from publicly available sources, databases and credit-rating organizations with the purpose of creating a transactional profile and determining the guarantee amount, (d) if you decide to pay your bills through the “myelin” app using a standing order to a Bank for your own convenience: credit/debit card number, expiration date and card holder’s full name.
Our company does not collect or in any way access “sensitive” personal data, unless this is required for grounds of public interest (medical examinations for crews, tanker vehicle drivers), in which cases the only person with access to the data is the company doctor, unless required by the relevant laws in force (vulnerable client or beneficiary of social residential tariff).
We collect such data before or when you sign the agreement between us or when we execute our company’s contractual obligations, when you enter and use the Website, when we provide services, when you enrol into the elin up rewards programme, when we issue an ε-card corporate card, when we receive CVs, when we resolve complaints and when you choose to pay your bills through the “myelin” app using a standing order to a Bank.
In addition, we collect your data from various sources subject to your consent and always pursuant to the legislative framework in place. Given that the processing of your personal data is based on your consent, ELINOIL follows the procedures which are set out by the legislation in force in order to inform you and obtain your consent.
Legitimate grounds for the processing:
(a) the execution of a contract that you have assigned or intend to assign to us;
(b) the safeguarding and protection of legal interests, both yours and ours;
(c) the compliance with a legislative obligation;
(d) the consent you grant under the specific conditions set by the legal framework;
(e) the obvious publication of data by the subject and the processing which is necessary for the protection of the subject’s vital interests regarding any information provided in relation to health data.
More specifically, we use your personal data:
To identify you, to render good service, to serve our pre-contractual or contractual legal relationship between us, to send you personalized information and offers, to respond to your requests, to safeguard legal interests either ours or yours, to inform you about existing or new products and services, to market these, to obtain your opinion for their improvement, to manage and analyse our client base (buying behaviour) in order to improve the quality, diversity and availability of services we offer, and to managerially organise and to run our company, to manage your requests and complaints.
Lastly, to set up Member Accounts for and to provide advice on energy saving to electricity and natural gas clients.
Who else has access to your personal data – Third-Party Data Recipients:
We do not share your Personal Data with third-party private enterprises for an economic or other consideration. Our Company may, after securing the confidentiality of the data, grant access to or transmit your personal data to the following processors so that we can offer you services or boost your service experience.
In these cases, we ensure through contractual terms that the recipients observe the legislation on data protection in a satisfactory fashion.
Your rights regarding the protection of your personal data
You have the following rights:
a) To know what personal data concerning you are being kept and processed by ELINOIL SA as well as their origin (right of access). This entails the right to request and obtain a copy of the personal data you have collected.
b) To request that the data be rectified or/and completed so that it is complete and accurate, by delivering any necessary documents whence the need to complete or rectify the data (right to rectification) arises, which is also an obligation of the processor concurrently.
c) To request the restriction of processing for your data (right to restriction).
d) To deny or/and object to any further processing of the personal data kept by ELINOIL SA (right to object).
e) To request the erasure of your data from ELINOIL SA’s records (right to be forgotten).
f) To request ELINOIL SA to transmit any data received by you to any other processor (right to data portability).
g) To withdraw at any time the consent you have given.
h) Our company shall respond to your request within one month from its receipt. After having you informed, we may extend the above deadline accordingly and if necessary, taking the volume and complexity of requests into consideration. Any rejection of your request shall be justified.
i) If your requests do not meet legal requirements, our company reserves the right either to charge a relevant fee, taking into account the time needed to take the requested action, the expense of employment for intra-company information and any possible relevant announcement, or to deny fulfilling your request altogether.
j) If we have any doubts on the details of the natural person filing the request, we may ask for additional information to confirm their identity.
k) To deny any automatic processing, including profiling.
l) To lodge a complaint to the Authority, if you would like to do so; competence lies with the Hellenic Data Protection Authority (DPA), 1-3 Kifissias Str., Ampelokipoi, P.C. GR-115 23 Athens, Website: www.dpa.gr, Tel.: +30 210 6475 600, Fax: +30 210 6475628.
How we safeguard your data
We do our best to safeguard your Personal Data. We use secure protocols for communication and data transmission and take all appropriate organisational, technical, physical, electronic and procedural safety measures. We use special software to protect our website and server.
Although we try our best, we cannot guarantee the security of the information. Nevertheless, we promise to inform the competent authorities for any suspected data breach. In addition, we will let you know, if there is any threat to your rights or interests. We will do everything in our power to prevent a data breach and to assist the authorities in the event of any such breach.
The company processes data exclusively through designated personnel for the purpose for which it has committed itself, and it is bound by strict obligations of data confidentiality.
Cookies and other technologies we use
Our company’s website uses “cookies”, so that whenever the user connects to the website, the latter can recover information thanks to cookies and offer to the user services related to that information. Our setting up of “cookies” is permitted only with the user’s consent and after their proper information.
Why we use Cookies
We use cookies to make your browsing experience easier and more pleasant.
Relevant Cookies
While you are browsing the website, third-party service cookies may be stored on your computer, e.g.: for statistical purposes related to the measurement of traffic and browsing on the website (analytics), on social media or any other internet marketing and website marketing online (Facebook, Twitter, etc.), for internet marketing in video form (YouTube, etc.), navigation services to the business of the website through a map (Google Maps, Foursquare etc.), updating of corporate, financial, statistical or any other information in various forms (pdf, excel, word, txt, etc.).
Cookies we use:
Electronic forms
The electronic forms of our website contain check boxes whereby the user can only accept COOKIES.
Obligations of the website users
By using the Websites and giving your personal data, you acknowledge that you are obliged to give the real, accurate and complete details asked of you by our Company. You can inform our company at any time about any changes to these details, so that they can remain up to date and accurate.
By using the ELINOIL websites, you confirm that you are over sixteen years old. If you are below the age of sixteen years, you must refrain from any use of the Websites whatsoever as well as from any granting of your personal data without the approval of the holder of parental responsibility. The company bears no responsibility for the violation of the above-mentioned obligations.
The company may erase, cross-check, complete or modify the information you provide based on information collected lawfully by third parties, and shall inform you accordingly.
You may unregister or revoke your consent from procedures and actions which involve processing of your data any time you wish.
Your personal data is retained, so that we can achieve the purposes set out in this Policy and, upon your request, we can remove all information retained by us (unless the legislation in force requires their retainment for a longer period).
Moreover, our company may retain personal data after achievement of the purposes of collection and processing, to use them: before tax, social insurance and auditing authorities as well as any other public Authority or competent Court until the applicable limitation deadline prescribed by the Law, or for as long as we deem necessary for the protection of our rights and legitimate interests.
Once the retainment period elapses, your personal data is destroyed/erased from our records and our system in compliance with our corporate policy and always provided that their retainment is no longer required for the achievement of the aforementioned purposes.
Shareholders’ privacy
ELINOIL, caring deeply about the security of the personal details of its registered shareholders (former and current), their representatives, those deriving or/and exercising rights on the shares or their representatives and anybody participating in its General Meetings in any capacity, commits itself to manage their personal data according to the current National and European Legal and Regulatory Framework for the protection of personal data. In determining the purposes and the way of processing personal data, the company becomes a Processor of said data and collects the following personal details of its Shareholders in the framework of the shareholders’ capacity and the execution of tasks governing the relationship between them:
Shareholders’ personal data is collected through electronic files received by ELINOIL periodically or on a case-by-case basis from the Central Securities Depository, as prescribed by the provisions of the law and the Operating Regulation of the Dematerialised Securities System (DSS), issued by the Capital Market Commission; these files contain information regarding its shareholder base and the transactions related to its shares. Moreover, personal data is collected by the Shareholders themselves for the processing of matters concerning them, e.g. inheritance.
Shareholders make sure that their data is updated in a timely manner, so that the Shareholder Register is constantly up to date. This process takes place through the Operator of their individual share in the Dematerialised Securities System (DSS) of the Depository.
ELINOIL collects and processes the aforementioned Shareholders’ personal data for the purposes mentioned below:
ELINOIL processes Shareholders’ personal data lawfully; for each processing it undertakes there is at least one of the following Legal Bases:
a. Processing is necessary for serving ELINOIL’s legitimate interests.
b. Processing is necessary for the execution of its contractual obligations towards its Shareholders.
c. Processing is necessary for the Company’s compliance with its legal obligations.
d. Processing is carried out with the Shareholders’ consent, who can nevertheless revoke it at any time.
Revocation of the consent does not affect the lawfulness of any processing which had been carried out based on such consent before its revocation.
The period during which the Company retains Shareholders’ personal data, in the framework of their shareholder capacity, as described in the paragraphs above, shall be ELINOIL’s lifetime according to the institutional frameworks in force from time to time.
The aforementioned provisions apply with regard to the security measures, transmission to third-parties, and the Shareholders’ rights.
In the event that we discover a breach of data security, we shall notify the Personal Data Protection Authority within 72 hours, in accordance with the provisions of the Personal Data Protection Regulation.
International jurisdiction and applicable law
The courts of Athens are the competent ones for the settlement of any dispute arising from this data policy, and the Greek law is applicable.
For any further information or request regarding this data protection policy, you may contact the personal data protection officer of our company, Mrs. Stella Kagianni, in writing at 33 Pigon Str., P.C. GR-145 64 Kifissia, at the e-mail [email protected] as well as at +30 210 6241500.
Last adaptation: 15.4.2021.
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