Πολιτική απορρήτου

1. Field of application

This privacy policy lays out the way ThinkData collects, uses, processes, stores, manages, transmits and protects personal data (hereafter “Information”) through its website, so that the company’s data protection standards are met – and comply with the applicable law.

The privacy policy  of the website https://thinkdata.gr/ (hereafter referred to as the “Website”) was compiled in accordance with GDPR 679/2018 (hereinafter referred to as “GDPR”), which is a directly binding legislative act.

This Privacy Policy applies to all Third Party personal data (hereinafter “the User and / or the Client”) managed by ThinkData through the Website and under which ThinkData is committed to protecting the privacy of visitors and Users / Clients of the Website.

The Website https://thinkdata.gr/ Website is not addressed to children. If you are not an adult or unable to enter into legally binding agreements in your country, you may not use this Website. If you believe that we are the recipients of personal data corresponding to a child without the necessary parental consent, please let us know immediately and we will take reasonable steps to safely delete this data.

This policy does not apply to information collected through any other website or to corporate practices that we do not control. Please note that the Website may contain links to other sites. For example, if you click on an ad on the Website and log on to another website, then this privacy policy will not apply to any information collected on this Website. We are not responsible for the privacy practices of other sites and we encourage you to read the privacy policy of each site you visit.

This data protection policy ensures that ThinkData:

• Complies with data protection laws as defined by applicable Greek and European personal data protection (GDPR) legislation
• Safeguards the rights of Client/Users and visitors
• Ensures transparency on data processing and storage issues
• Is protected against data breach risks

2. Legal basis for data processing

Thinkdata is a company that focuses on business growth through data management, analyzing data, up to the point of re-use, or data withdrawalwith more than 15 years of experience in the fields of Business Intelligence, Analytics, KPIs, CRM, DWH design and implementation, and general data value extraction..

We provide specialized consulting services on data value extraction not only in terms of exporting the largest possible information each time, but we are also capable of guiding you through the data creation phase providing our input on how each application or system should be set

The personal data that you provide to us while browsing the Website or when using the licensed applications, are solely used for the purposes of facilitating your transactions with us as detailed in the General Terms of Use, namely:

(a) For the maintenance of your Personal Account on the Website and/or the Application, we retain the personal data you grant to us with your consent.

(b) In order to file a request regarding the pricing policy of our services, you grant us with your consent via e-mail or by completing the relevant information form located on the Website a certain amount of personal data.

(c) For your communication with ThinkData in relation to our products and services, or any inquiries you may have, you grant us with your consent via e-mail or by completing the relevant information form located on the Website a certain amount of personal data.

(d) For the registration of a request for support you grant us with your consent via e-mail or by completing the relevant information form located on the Website a certain amount of personal data

(e) For the right to use of our services  for a trial period, you provide us with your personal data in order to take necessary steps at the request of the Data Subject prior to entering into a contract

(f) For the purpose of purchasing and activating a licence of a licensedapplication,  you provide us with your personal data that is deemed necessary for the performance of the contract in which the Data Subject acts as a party

(g) In order to improve the services provided and ensure the operation of the respective service, we use Functionality Cookies, Advertising Cookies, Cookies Analytics Third Party Cookies, to the use of which you consent

The personal data you provide to us may not be used by any third party (except where provided by law and by the competent authorities), without abiding by the applicable data protection law.

ThinkData operates in accordance with applicable Greek and EU Law and retains your personal data secure for as long as you are registered with a ThinkData service or until your consent by which the personal data have been initially obtained, is withdrawn.

In summary, ThinkData asks for and processes the personal data that are absolutely necessary for the individual processing. In any case, the criterion used to determine the data retention period of personal data, is based on compliance with the time limits allowed by applicable law and the principle of Data Minimization, Storage Limitation and Purpose Limitation.

3. Privacy

ThinkData applies appropriate technical, physical and administrative data security measures to protect data from loss, misuse, damage or alteration, unauthorized access and disclosure, as provided for in Article 32 of GDPR 679/2016 at all stages of the data processing procedure, in order to ensure an adequate level of risk protection. In particular, such measures include, inter alia, as appropriate: (a) the encryption of personal data; (b) the possibility of ensuring confidentiality (Article 90 of GDPR 679/2016), the integrity, availability and reliability of processing systems and services; (c) the restoring availability and access to personal data in due course in the event of a natural or technical event; (d) a procedure for regular testing, assessment and evaluation of the effectiveness of technical and organizational measures to ensure the security of processing. Furthermore, ThinkData takes steps to ensure that any individual acting under the supervision of the  Data Controller or the Processor who has access to personal data, is processing them only in accordance of the instructions of the Controller and restricts the access to your personal information to its authorized employees.

Other key features indicative of our information security system are as follows:

• ThinkData maintains a dedicated information security team that plans, implements and provides surveillance of our information security system
• The company monitors the security and functionality of its products and services before they are introduced to the Internet, for any vulnerabilities in technology
• The company performs ongoing infrastructure checks to detect weaknesses and potential intrusions, vulnerabilities in systems etc.
• The company uses https protocols for secure and encrypted client communication with ThinkData
• The company uses a Secure Sockets Layer (SSL) certificate to create an encrypted connection between the web server and the visitor / user’s browser
• Use of Transport Layer Security (TLS) protocols for ensuring encrypted communication with the servers running on Microsoft’s Azure Cloud Platform
• The servers of the Website are hosted on Microsoft’s Cloud Platform Azure

4. Categories of Personal Data We Collect

When you visit the Website and in order to register as a member of the Website and/or the Application and create an account (Profile), you must first accept ThinkData’s General Terms of Use and this Privacy Notice, since you may be prompted to register your personal information (indicatively name, surname, e-mail address, title) by filling in the relevant registration form on the Website.

In order to file a request regarding the pricing policy of our services, you must provide us with information concerning yourself (such as name, surname, e-mail address, property) by filling in the relevant application form found on the Website, in the application or alternatively via e-mail.

For your communication with ThinkData regarding our products and services or any issues you may inquired about, you must provide us with information concerning yourself (such as name, surname, e-mail address) by filling in the relevant registration form found on the Website, in the application or alternatively via e-mail.

To file a request for support, you must provide us with information concerning yourself (indicatively, name, surname, e-mail address) by electronically filling in the corresponding application form on the Website in the application.

For ordering and purchasing ThinkData products and services, you must provide us with personal data that are deemed necessary for the performance of the contract and for invoicing purposes, such as, but not limited to, name, address, e-mail, VAT number, Tax Authority Department, occupation.

For the purposes of activating and operating the ThinkData Application license, you must provide us with the following personal data:

• User contact information (Full name, email, registration information)
• Licensing Details (company title, country, business purpose, property, title, company size, sector)
• Copy of student identity or other proof of academic capacity

5. Sources of Personal Data Collection

• Directly from users and visitors to the Website
• Internet (corporate sites)
• Directly from Clients/User of our Application and services
• Third-party licensed applications
• Resellers, associates and affiliate companies

6. Information on the Processing of Personal Data from ThinkData (by its capacity as Data Controller and Data Processor in accordance with the General Data Regulation EU 679/2016)

1. Why do you process my Personal Data (PD)?

ThinkData provides services based on its intended purpose as outlined in paragraph 2 hereof. The content of the personal data collected by the Website varies and depends on the type and purpose of the ThinkData provided services.

In particular, ThinkData processes your personal data that it collects through the Website or the Applications for the following purposes:

In order to allow the User and or /prospective customer to be registered as a member of the Website or Applications, where such processing is necessary for the purposes of the legitimate interests pursued by the data controller.

In order to be able to respond to requests submitted by the  User and or /prospective customer with respect to the pricing policy of its services and products.

To ensure the ability of the  User and or /prospective customer to communicate with ThinkData regarding our products and services or any other issues  that may have been raised.

To provide support services in relation to our products and services, as well as to manage the respective requests of the User and or /prospective customer

To register the order and purchase the company’s products by the User/Client, as well as for the purpose of managing activation of licence requests for the Application.

1. Information collected automatically during your visit and interaction with the Website: We inform you that your personal data and the information that are collected and processed when you manage your account on the Website https://plexearth.com/, are suitable for the occasion and absolutely necessary for the processing of your requests and the use of ThinkData services.

In particular, when you visit and interact with the Website, certain information may be collected automatically, such as:

• the Internet Protocol (IP) address of your computer,
• the type of browser and the configuration of your operating system,
• the websites you visited immediately before and after your visit to the Website,
• Websites, ads and links that you click within the Website,
• Basic connection information of your server and
• Information collected through HTML cookies, and other similar technologies.

During the use of the Application the following data may be collected:

• the Internet Protocol (IP) address of your computer,
• the type of browser and the configuration of your operating system,
• Information on your internet connection speed
• Information regarding software applications installed that are related with the use of the Application
• Basic connection information of your server
• Your computer name και hardware id (for licensing purposes)
• The Application records data on local data logs, which are sent along with the error reports or if requested by the User/Client for the provision of troubleshooting or bg fixing services.
• In addition the Application records data related to its use

ThinkData does not manage, collect or process geolocation data, which is collected and processed exclusively by the companies that offer the operating system of your particular device (in the case of ios – Apple Inc., while in case of android – Google Inc.). ThinkData does not have access to the GPS refresh rate.

The Google Inc tool (Google AdWords) also collects cookies during your visit to the Website, which are stored in your browser. This tool serves to capture visits to the Website for advertising purposes (Remarketing) on ​​Google and the Display Network. Your browser saves cookies while visiting the Website, which allows you to be re-identified as a visitor when retrieving the websites belonging to the Google advertising network. These pages can then show you, as a visitor, content ads that you previously retrieved on other websites using Google’s Remarketing feature. You can deny data logging through Google AdWords at http://www.google.com/settings/ads.

ThinkData will use the Client/User email contact information to directly promote similar products or services, to inform users of the status of the trial application and to serve similar purposes, unless the Client/User informs ThinkData at support@ThinkData.com or at its mailing address, 12 Ilektras str., GR-15122 Marousi, e:ask@thinkdata.gr,t: +30(210)6209723, Attn: Customer Service Department, that he/she does not wish for the collection and use of his electronic information for these purposes.

Access to personal data is strictly limited to ThinkData’s personnel, which applies appropriate technical and organizational measures to ensure their proper level of security and only to achieve the intended purpose.

ThinkData does not systematically and extensively evaluate personal aspects of individuals, based on automated processing, including profile training.

1. For how long will you maintain the records of my account in logs?

• In case where the legitimate basis of processing is the exercise of legitimate interest, processing of personal data will take place for as long as necessary, to achieve the intended purpose of ThinkData, as well as for as long as is required until the limitation period for related claims has lapsed.
• In the event that the Client’s/User’s personal data (Account Details-profile) are provided with their consent in the context of subscribing to the services of the Website, we will retain the personal data for as long as the consent is received voluntarily by you and until the consent of the data subject is withdrawn. In the event that, for any reason, the consent is withdrawn, we will retain the information for as long as it is required until the limitation period for related claims has lapsed.
• If the legitimate basis of the processing is the performance of the contract, we will retain your data for as long as you maintain a contractual relationship with us, both in hard copy and in electronic form, or for as long as it is required until the limitation period for related claims has lapsed.

1. What are my rights concerning my data processing?

• You may exercise your rights under the applicable Greek Legislation and the Regulation (EU) 2016/679 (GDPR), as follows: (a) the right to information (Articles 13, b. the right of access by the Data Subject (Article 15); c. the right of rectification (Article 16); d. the right to erasure (to be forgotten-Article 17); e. The right to restriction of processing (Article 18) f. Right to data portability (to get your data in a structured and commonly used format – Article 20 and (g) the right to object (Article 21).
• These rights are exercised at no cost to you by sending a relevant letter to ThinkData’s customer service atemailask@thinkdata.gr, or via phone call at +30(210)6209723. In case however the aforementioned rights are exercised excessively and without good cause thus causing us administrative burden, we may chargeyou with the cost related to the exercise of the respective right.
• In case you exercise any of your rights, we will take all appropriate measures available for the satisfaction of your request within thirty (30) days following the receipt of the relevant request. We may either inform you on the acceptance of your request or on any objective grounds that hinder the processing of your request.
• In addition, you may oppose your processing of your personal data at any time by withdrawing your consent (Article 7 (3) of CISA 679/2016), provided that the legitimate basis for that processing is the consent of the data subject.

7. Where will you disclose my data?

• Your data may be disclosed to divisions of ThinkData, tha are responsible for the proper and uninterrupted operation of the Services of the Website
• Your data may be transmitted and become accessible by legal entities with which, we have entered from time to time into contractual agreements for the purpose of fulfilling our company’s legitimate interest (such as, for example, storage / hosting / data processing companies acting as data processors (Google Inc. – Google Drive, Dropbox, Bitlocker)
• In the context of certain features of the Website, we may transfer to legal entities (Google Inc) certain personal data of visitors/Users collected through the use of Cookies s (such as, but not limited to, the IP address and the entire user interaction with the application)
• The data that the google analytics tool collects, such as the URL that the user has visited, the action that he has taken and the time remaining on the Website (retention), are usually transmitted on a Google Server located in the U.S. and stored there.
• During all data transfers, we always take all appropriate measures so as to ensure that the transmitted data are the minimum required for the intended processing purpose and that the conditions for legitimate and lawful processing will always be met

8. How can I file/register a complaint / protest?

• For any matter concerning your data processing, please contact the ThinkDataat

– address:12 Ilektras str., GR-15122 Marousi,

– e: ask@thinkdata.gr,

– t: +30(210)6209723

• Moreover, you shall always be entitled to contact the Hellenic Data Protection Authority, which may accept the submission of relevant complaints in writing at its protocol in its offices at 1-3, Kifisias Street, Postal Code 115 23, Athens or by e-mail (contact@dpa.gr) in accordance with the instructions indicated on its website. It is recommended however to contact first Flexscape’s DPO prior to filing a complaint to the competent Data Protection Authority.

9. Cookies & other technologies

• What are cookies and why ThinkData uses them: Cookies are pieces of information, in the form of very small text, usually consisting of letters and numbers, which are stored in the browser used by the individual Customer / User (Chrome, Mozilla Firefox etc.), assisting us to make the Website work more efficiently. Cookies do not in any way cause damage to users’ computers or files stored on them. Information stored in cookies is used for identification purposes. In this way we manage to operate the Website in an efficient way for the service we offer. The Website uses the Cookies to provide Clients/Users with information, to perform the services provided through it, and to improve the level of service provided.
• Under no circumstances will the cookies contain personal information or information that will allow anyone to contact the Website’s visitor by phone, e-mail, etc. Additionally, using cookies does not provide access to your computer’s documents or files.
• Additionally, cookies help us evaluate the performance and traffic of our Website, thus improving its presentation and content, according to the preferences of our visitors.
• Which cookies are we using? The cookies described below may be stored in the browser. You can view and manage cookies in your browser (however, mobile browsers may not offer this visibility). Of the different types of cookies available, ThinkData uses the following:

• In addition we use third party marketing cookies (google.com, youtube.com) with which we seek to project advertisements based on the personal preferences of the Client/User
• We also use third party performance and analytics cookies (typekit.net., Google Tag Manager, Google Optimize, youtube.com)
• The essential technical cookies are of critical importance for the proper operation of the Website as they allow you to browse the Website and make use of its functions. These cookies do not identify your personal ID. Without these cookies, we are unable to offer proper functioning of the Website. In addition these cookies allow to the Website to store and remember your preferences (preference cookies) so as to provide improved and personalized services. όπως το μέγεθος γραμματοσειράς, ή αν έχετε απαντήσει σε κάποια δημοσκόπησή μας, ώστε να παρέχει βελτιωμένες και προσωποποιημένες λειτουργίες.
• If the Client/User accepts the use of cookies, the following types of cookies may be used: Function Cookies, Advertising Cookies, Cookies Analytics, Third party Cookies
• You do not wish to use cookies? You can enable, disable, or even completely erase cookies through the setup options in your browser. For example, in Chrome, you can click the Chrome menu and then select Settings / Privacy / Content Settings and change the cookies settings to suit your preferences. If you choose to disable cookies, some parts of the Website and / or the Application may not work properly.
• The Software of the Website is designed to ensure the highest level of security and trust. All information contained in requests submitted through the Website is secure and confidential. Only authorized employees with appropriate training in handling Client’s/User’s personal data will have access to this information and only when it is necessary to meet your requests and to perform the contract.

10. Amendments

This policy may be renewed from time to time, due to changes to the relevant legislation or to changes in the corporate structure of ThinkData. Consequently, we encourage Clients / Users to periodically check the Website to update their recent privacy practices. In any case, Clients/Users will be notified via e-mail or through a warning on the Website of changes to this policy.