PERSONAL DATA PROTECTION DECLARATION
1. Preamble
This website (“Website”) is provided by DELTA Food Industrial and Commercial Company Limited (hereinafter referred to as DELTA). DELTA, as Data Controller, is subject to all obligations and commitments arising from the personal data protection legislation, including the General Data Protection Regulation (EU) 679/2016 and Law 4624/2019 (hereinafter referred to as the “GDPR Legislation”)
For DELTA, respecting and protecting your personal data is a commitment. In this context, it takes seriously the fact that you are sufficiently aware of your personal data. The personal data provided by visitors to our website are used exclusively for the purpose for which they were submitted on your behalf as indicated at the respective point of collection.
This Privacy Notice describes the personal data we collect on your behalf, how we use and protect it, and the choices you have about the way we use that data. Its purpose is to inform you of the company’s policy regarding the personal data you provide to us so that you are aware of the purpose for which we process it, the category of recipients, and the procedures you can follow to exercise your legal rights.
DELTA, recognizing its ongoing responsibility in the protection of your personal data, if as a Data Controller it processes them lawfully, has taken all technical and organizational measures based in particular on the principles of proportionality, limitation of the purpose and time of processing and minimization of data, exclusively for the purpose of processing for which they have been collected and exclusively for the period of time that the purpose of processing lasts, so that your personal data is completely secure.
We recognize that the protection of personal data is an ongoing responsibility and therefore, we will update and amend this Statement from time to time. Please visit our website https://www.delta.gr from time to time to ensure that you are aware of and satisfied with any changes. If in doubt about any term of this Statement, you may contact us by e-mail at [email protected].
We would also like to assure you that at DELTA we do not process personal data relating to minors under the age of 18.
2. Definitions
Personal Data: any information relating to an identified or identifiable natural person whose identity can be directly or indirectly verified.
Data Subject: the identified or identifiable physical person to whom the Personal Data and/or special category (Sensitive) Personal Data refers.
Processing: any operation or set of operations which is performed, whether or not by automated means, on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, association or combination, restriction, erasure or destruction.
Controller: For the purposes of this policy, the Data Controller means DELTA which determines the purposes and the way in which Personal Data is processed.
Processor: the natural or legal person, public authority, organisation or other body that processes Personal Data on behalf of the Controller.
Special Categories of Personal Data (“Sensitive Personal Data”): personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data, data concerning the health or sex life or sexual orientation of a natural person.
Consent: any indication of the Data Subject’s free, specific, explicit and informed consent, by which the Data Subject indicates that he or she agrees, by a statement or by a clear affirmative action, to the processing of Personal Data concerning him or her.
Personal Data Breach: a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to Personal Data transmitted, stored or otherwise subjected to Processing.
3. Who we are
DELTA is a member of the VIVARTIA Group of Companies in the production and marketing of dairy products and beverages and our vision is to offer superior quality products to the consumer. Focusing on innovation, safety & quality we act with responsibility and sensitivity towards people, society and the environment.
For more than 70 years we support the Greek family and the Greek livestock industry and meet the modern nutritional needs of every household from all over the country with quality products. At the same time, we are proud ambassadors of Greek food at an international level.
4. How we collect your personal data
DELTA in the context of its operation, collects, maintains, stores and generally processes in printed and / or electronic form, data and information concerning your personal data, simple and / or special category (sensitive), which you provide us or in any way disclose to us or come to our knowledge in a legal way and means.
In particular, during your visit to our website DELTA may collect your personal data, as follows:
• When you contact us through our website, by entering your data in the contact forms with DELTA, by e-mail or by telephone.
• When you contact us in order to participate in contests, draws and general promotional activities of DELTA.
• In the process of submitting your CV either via delta.gr/jobs /
• If your personal data is lawfully transmitted to us either by other companies of the VIVARTIA Group or by commercial partners.
• Via social networks, if you have granted access to your data to one or more social networks, for example Facebook, Instagram, LinkedIn
• During your visit to DELTA’s premises.
• In the context of any recording of personal data of your image in the context of using a video surveillance system for the purpose of protecting persons and property of DELTA. The processing is necessary for the purposes of legitimate interests we pursue as controller (Article 6.1 (f) GDPR). Our legitimate interest consists in the need to protect our premises and the goods located within them from unlawful acts, such as, but not limited to, theft, acts of terrorism, etc. The same applies to the security of the life, physical integrity, health and property of our staff and third parties lawfully present in the premises under surveillance. We only collect image data and limit the collection to places where we have assessed that there is an increased likelihood of illegal acts being committed, without focusing on places where the privacy of the persons whose image is taken may be unduly restricted, including their right to respect for their personal data.
5. Why do we collect/process your personal data?
The personal data you provide us with will be processed for the following purposes:
• For the purposes of communication with you and the overall management of the relationship between us, including your participation in DELTA promotional activities. For example, we may contact you by telephone, email or other means in order to inform you or request additional information about a request you have made. We may need to contact you by email or telephone for administrative purposes.
• The company collects and processes your personal data to the extent necessary during the interview and potential recruitment process in order to assess your application for potential employment.
• For the purpose of invoicing products and services provided to DELTA by natural persons/individual businesses, in order to proceed with their payment.
• To safeguard our legitimate interests.
• For purposes of protecting persons and property on our premises and facilities As mentioned above, we use closed circuit television (CCTV) and security cameras that record your visit to DELTA’s physical premises in order to be able to protect the security of natural persons, materials and our facilities, and also, for the same reason, we record the details of visitors, contractors who enter our premises to carry out works and so on and issue them with access cards to DELTA’s premises.
• To comply with an obligation of DELTA imposed by law.
• To prevent and manage fraud. We process your data for the purposes of preventing and managing potential fraud incidents. In addition, we may obtain information about the commission of any offenses where necessary to protect our legitimate interests, i.e. to protect our assets, our employees/collaborators and our premises.
• DELTA makes every effort to minimize the risk to your rights and freedom by not collecting personal data beyond what is necessary to fulfill the purposes stated above. Your data shall not be further processed in a manner incompatible with the purpose.
6. What personal data we collect about you
The data we collect depends on the general context of your interaction with DELTA, as well as the features you use. Some of this data is provided directly by you, for example when you contact us.
Communication Data: DELTA collects contact data such as name, address, postal code, telephone numbers, email address, IP addresses, when you contact us directly either through the web contact form or by telephone or via social media (e.g. Facebook [META]) or when you send us your CV. We also collect the information you provide us with and the content of the messages you send to us, such as questions and information you provide through the online contact form with DELTA or for the handling of your complaints and grievances (CED process). We do not use the contents of our emails, or conversations, collected for the above purposes for your advertising targeting unless you have provided us with your express and free consent and for as long as it is valid.
Pricing information: DELTA collects the invoicing data of individuals/individual businesses that provide products or a service to it, such as their home/headquarters address, VAT number, Tax Identification Number, Tax Office, in order to certify and pay their outstanding fees and to comply with tax regulations.
Your CV: Depending on the position for which you are applying for, DELTA processes the minimum required personal data submitted by you with your CV and indicatively: your educational background, your employment history, your previous employers, your areas of expertise, the professional and other work permits and certifications you hold, the educational institutions from which you graduated, your preferences for the type of work, the verification of information regarding your references and previous employers, any other information you choose to submit through the resume submission process, any other data that may be provided to us during the resume submission process, and any other information you choose to submit through the resume submission process. For the purpose of background checks on your application, we may also obtain minimum information required for your CV from other sources where permitted by applicable law, such as your previous employers, and from publicly available sources, such as information posted on publicly available and publicly accessible websites, social media profiles, information from public search engine results, where such information is relevant and appropriate to your assessment for the position.
Image data: If you visit DELTA’s premises, your image may be recorded by our closed circuit television and security cameras (CCTV), which are designed to detect and prevent malicious actions to safeguard persons and property on our premises.
7. Lawful basis for processing your personal data
Depending on the purpose of the processing of your personal data, the lawful basis of processing may be :
• The conclusion and performance of a written or otherwise established contract between us,
• The consent you provide under the specific conditions set out in the legal framework, e.g. when you communicate in any way with DELTA,
• Our compliance with national and/or European legislation, e.g. for your billing purposes,
• To safeguard and protect our legitimate interests, both ours and yours, e.g. when recording your image when you visit DELTA’s premises,
• The obvious disclosure of personal data by the data subject, e.g. when you send us your CV.
8. Recipients
Your personal data is not processed by third parties, except by those with whom we cooperate and who are necessary or facilitate the provision of our services to you, but always under conditions that fully ensure that your personal data is not subject to any unlawful processing, i.e. other than for the purposes of the transfer as described above. As part of our activities, we use third party providers who provide services on our behalf. In particular, such access may include :
• External partners of DELTA, who provide us with accounting or legal services, consulting services in general, IT services, computer services, website services, especially in the context of a social media campaign, services of a security technician/work doctor, etc,
• External partners of DELTA providing research and/or advertising services, provided you have given your consent,
• Lawyers, bailiffs or other persons necessary for the judicial or extrajudicial handling of claims by DELTA.
We inform you that the above categories of third party recipients of your personal data are processors on our behalf and therefore as such they do not process your data beyond the above transfer purposes.
Where we transfer your personal data to the above third party recipients, or other recipients, this requires that the third parties are committed to complying with personal data regulation, whether they are acting as Processors on our behalf or as Data Controllers jointly.
In any case, DELTA will not make available or otherwise transmit or disclose personal data of visitors/users of its website to third parties, other than those mentioned above, without the consent of the visitor/user, with the exception of the application of relevant legal dictates and to the competent authorities only.
Finally, unauthorized access by persons, including our employees, to your personal data is prohibited.
9. Duration of retention of your personal data
Your personal data are kept only for the time required to fulfill the purpose for which they are collected and processed and in order for DELTA to apply the relevant legal framework. Following this, your data will be deleted/destroyed, unless you give your explicit written consent to their retention or there is another legitimate reason for further processing.
In any case, you have the right to request the termination of communication for promotional or advertising purposes at any time, provided that you have given your consent for this purpose.
In cases where the retention of personal data is necessary for the exercise or protection of legitimate rights of DELTA before judicial or other authorities provided for by applicable legislation, the retention period is extended until the end of the period when the data is no longer necessary for the above purposes.
The data storage period is determined on the basis of the following specific criteria depending on the case:
• Where processing is required as an obligation by labour, tax, insurance or other provisions of the applicable legal framework, your personal data will be stored for as long as required by the relevant provisions,
• CVs of employee candidates will be stored for any future use for a period of up to 6 months,
• In case you accept an offer of employment at DELTA and sign a relevant employment contract, your personal data will be kept on the basis of the Employees’ Personal Data Processing Information (Employee Handbook), which is communicated to all employees, who are demonstrably aware of it, throughout the duration of the employment relationship and after its termination for as long as required by labour, tax and insurance legislation,
• In the context of maintaining a video surveillance system for the purpose of protecting persons and property on our premises, we keep the image data for seven (7) days, after which they are automatically deleted. In the event that we detect an incident during this period, we will isolate part of the video and keep it for up to one (1) month more, in order to investigate the incident and initiate legal proceedings to defend our legal interests, while if the incident concerns a third party we will keep the video for up to three (3) months more. The retained footage is only accessible by our competent/authorized personnel who are in charge of site security. This material is not passed on to third parties, except in the following circumstances:
• a) to the competent judicial, prosecutorial and police authorities when it contains information necessary for the investigation of a criminal offence involving persons or property of the controller,
• (b) to the competent judicial, prosecutorial and police authorities when they lawfully request data in the course of their duties; and
• (c) to the victim or offender of a criminal offence, where the data are data which may constitute evidence of the offence.
10. Personal Data of Minors
DELTA does not deliberately process personal data of minors under the age of 18 (and under 15 in the case of information society services), respectively, without the prior consent of their parent or legal guardian. We undertake to provide the parent/guardian with:
1. information on the specific categories of personal data collected from the minor; and
2. the opportunity to object to further collection, use or storage of such data. Where it is established that personal data of a minor under the age of 18 (and under the age of 15 in the case of information society services) has been collected without the prior verifiable consent of the parent or person exercising parental responsibility, DELTA will take appropriate measures to delete such data from its databases immediately.
11. Guarantees for the security of your personal data
When you provide us with your personal data, we take steps to ensure that it is kept and managed securely. In order to protect your personal data, we take adequate physical, technical and organisational measures to protect it.
In particular, DELTA applies appropriate technical and organizational measures to ensure the secure processing of your personal data and to prevent accidental loss or destruction and unauthorized and/or unlawful access, use, modification or disclosure.
Although the way the internet works and the fact that it is free to anyone does not allow us to provide guarantees that unauthorised third parties will never be able to breach the technical and organisational measures in place, we try to avoid unfortunate circumstances.
We limit access to your personal data to only those employees and contractors and partners of DELTA in general who need to know this data in order to provide you with the services you require. In addition, we train all employees on the importance of confidentiality and maintaining the privacy and security of your personal data.
Among other things, we have implemented the following technical and organisational measures and procedures to protect your personal data from any loss, alteration, unlawful processing or modification:
• access to your personal data is limited only to the number of persons authorised for the specific purposes; access to the IT systems used to process the data is ensured only by authorised persons,
• access to these IT systems is monitored in order to detect and immediately prevent unauthorised access use of information systems and computer programs installed in a way that minimises the use of personal data and/or user identification data,
• adoption of individual procedures for the retention of personal data and their secure deletion/destruction,
• periodic monitoring (every 2 years) and deactivation of inactive accounts.
12. Transfer of personal data outside the European Union
The personal data that DELTA collects from you and generally processes, in accordance with the above, are not transferred or processed in third countries outside the EEA.
13. Links to other websites
Our website may contain links to other websites. This privacy statement applies only to DELTA. Therefore, whenever you follow a link from this website to another website, even to a Vivartia Group website, we recommend that you carefully read the privacy statements of the respective website.
In case you choose to connect to any third party website through special links (links, hyperlinks, banners) that may be contained in the website, the company and any other member of the Vivartia Group shall not be liable for the terms of management and protection of personal data applied by such third parties.
14. Your rights
Any natural person whose personal data is processed by the company may exercise the following rights, in accordance with the terms and specific provisions of Regulation (EU) 2016/679 and Law No. 4624/2019:
• Right of Access: You may request and receive from DELTA information about your personal data that we process, as well as information concerning the processing, such as the purposes of the processing, the recipients and the period of retention (Article 15 of the Regulation). Within the framework of this right, you may request that we provide you with a copy of your personal data processed free of charge. In case the requests are repetitive and manifestly unfounded, DELTA reserves the right to set a reasonable fee. In particular, in order for us to consider a request for access or information relating to your image, you must specify approximately when you were within the range of the cameras and provide us with an image of you, to make it easier for us to identify your own data and to hide the data of third parties shown. Alternatively, we give you the option of coming to our premises to show you the images in which you appear.
• Right of Correction: you may request the correction of any inaccurate or incomplete information, which the company will do immediately without undue delay (Article 16 of the Regulation). Our company undertakes to inform immediately the recipients to whom your data may have been transmitted (Article 19 of the Regulation).
• Right to object: you may object to the processing of your personal data where there is a legitimate interest in doing so in accordance with the terms and provisions of Article 21 of the Regulation, including your right to object to the automated processing of your data and to the processing of your data for marketing purposes. We also point out that the exercise of the right to object does not imply the immediate deletion of data or the modification of processing. In any case, we will reply to you in detail as soon as possible, within the time limits set by the GDPR.
• Right to erasure (“right to be forgotten”): You may request the erasure of your personal data if there is no longer a legal obligation to keep it or if you object to its processing and have a legitimate interest in doing so (Article 17 of the Regulation). In certain cases (such as, but not limited to, where there is a contract, a legal obligation to process personal data imposed by law, public interest), this right is subject to specific restrictions or does not exist, as the case may be. Our company will proceed to erasure without undue delay upon your request under the conditions set out in the relevant applicable Greek and European legislation on Personal Data Protection. The company undertakes to inform immediately the recipients to whom your data may have been transferred (Article 19 of the Regulation). We note that the exercise of the right to erasure does not imply the immediate deletion of data or the modification of processing. In any case, we will reply to you in detail as soon as possible, within the time limits set by the GDPR.
• Right to withdraw consent: where we process your personal data based on your consent, you may at any time withdraw your consent or change the degree of consent you have given, in an easy way and without affecting the lawfulness of the processing for the period before the withdrawal.
• Right to transferability: You may receive your personal data in a structured, commonly used and machine-readable format and request the transfer of such data to other controllers (Article 20 of the Regulation).
• Right of Restriction: You can request the suspension of the processing of your personal data:
o (a) when you question its accuracy and until it is verified,
o (b) where you object to the erasure of personal data and request the restriction of use of personal data instead of erasure,
o (c) where the personal data are not necessary for the purposes of the processing, but are necessary for the establishment, exercise or maintenance of legal claims; and
o (d) where you object to processing and until it is verified that there are legitimate reasons concerning us which override the reasons for which you object to processing (Article 18 of the Regulation).
• Right to make a complaint: You can contact the competent Greek independent authority, which is the Hellenic Data Protection Authority, in case of unlawful processing of your data (http://www.dpa.gr/). Phone: +30 210 6475600, Fax: +30 210 6475628, Email: [email protected]
If you exercise any of the above rights, DELTA will respond within one month, unless your request is particularly complex or there are many similar requests.
In any case, DELTA undertakes to inform you in detail of any incidents of violation where they are likely to put your rights and freedom at high risk, and of the measures planned to deal with them.
15. Social Networking Hubs/Hyperlinks
We offer you the so-called plug-ins of various social networks on our website. If you are a member of a social network and during your browsing on our website, you are logged in to your own user account, the social network provider may link information about your visit to our website with your profile data on the network. Therefore, please visit the social network providers used by you for information on these features.
The relevant services are provided by the respective companies (“providers”). These providers are:
• Facebook (Meta), and Instagram operated by Meta platforms Inc,
• YouTube provided by Google Inc.
16. Use of cookies
We use cookies (small text files that are stored on your device when you browse the internet) to support our website, to provide our online services and to collect information. Cookies allow us to, among other things, store your preferences and settings, provide advertisements based on your interests, and analyze how our website and online services are performing. Please read our Cookie Policy in detail at www.delta.gr.
17. Contacting a Processor & Controller Protection Officer
Responsible for the processing is “DELTA Industrial and Commercial Food Company”. You can contact DELTA for any question or query regarding your personal data and their processing, as well as to exercise your above rights either by sending an email to [email protected] or by sending a written request to the following address: DELTA TROFIMA S.A. 230 km E.O. Athens – Lamia 14565, Agios Stefanos, Attica.
The Data Protection Officer (“DPO”) has been appointed the company NETBULL INFORMATION SERVICES LTD (already NET BULL INFORMATION SERVICES S.A.) and the natural contact person is Mr. Konstantinos Vagenas. You can contact the DPO for any issue regarding your personal data by sending an email to [email protected].
18. Update & Changes
This Privacy Statement was last updated on 23/08/2022.
DELTA reserves the right to modify and update this Privacy Statement at any time and for any reason. Please check our website from time to time to keep up to date with the current and applicable Privacy Statement and especially before providing any new personal data.
If you do not agree to the terms of this Statement as it may be amended, either in whole or in part, you must stop using our website www.delta.gr.
We may send you periodic emails to remind you of changes and updates to this Statement, but you should check our website frequently to keep up to date with the current and applicable Privacy Notice.
Any changes to this Statement will be posted here immediately.