1. Introduction

The protection of personal data is important for us.

This website www.mykilada.com is operated by the company under the corporate name “MINDCOMPASS OVERSEAS S.A” located at 32, Akadimias, 10672, Athens, Greece, with telephone no. +30 2103614255 and email address info@mykilada.com, including its wholly owned subsidiaries and successors (together referred to as the “Company” or “us” or “we”) to offer to our website visitors (“you”, “your” or “users”) general information about the activities of the Company and its affiliates.  This Privacy Policy explains how the Company, collects, stores, uses, processes and in general handles personal data when you visit, use or get registered to the website of the Company (hereinafter the “Site”). This Policy is designed to assist you in making informed decisions when using our website or interacting with us.

Individuals are recommended to read carefully this Policy before disclosing any personal data and/or filling in any electronic form posted on this website. By visiting our website or by providing us your personal data, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Policy.

“Personal Data” means any information or set of information that relates to an individual such as name, address, email, telephone number etc. which can be either direct or indirect, and can be collected by or on behalf of the Company.

2. A few words about the Site

This website is used by the Company in order to inform the users about Kilada County Club, Golf and Residences, a new development located in the Peloponnese, and the property investment opportunities available there.

3. Personal Data we collect

We may collect and process the following personal data about you, including but not limited to:

• General data such as name, postal and/or email address, phone number, date of birth, and other information such as photographs and digital imagery, your communications preferences; queries you make to the Company;
• Professional data, such as your address, email address, phone numbers, job title/position, educational information, professional qualifications;
• Identification data, such as your registration/identification information (for example, identity card numbers) insofar as required by the Company and permitted by law;
• Digital data generated from your use of our website or for the delivery of services to the Company, such as IP address, login user credentials, your browser type and version, time zone setting, time period of user’s staying on a single page, the internal path analysis and/or other parameters regarding the user’s operating system and computer environment, browser plug-in types and versions, operating system and platform and other data transmitted via cookies. This data is collected and used only in an aggregated and not immediately identifiable manner; they could be used among others to ascertain responsibility in case of hypothetical crimes against the site or upon public authorities’ request;
• Publicly available information.

4. Ways of obtaining personal data

In most cases, the Company will collect data directly from you, although sometimes we will obtain data about you from public or third-party data sources.

Below are some examples of how you may provide personal information to the Company:

• searching and browsing for content;
• subscribing to or ordering newsletters and/or publications;
• registering for premium online services;
• participating in “join our mailing list” initiatives;
• registering for events and conferences;
• contacting us for further information;
• visiting our Websites while logged into a Social Media platform; and/or
• providing us with business cards or other contact information.

When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary for us to provide the requested services, we may not be able to provide you those services.

5. Purposes of processing personal data

The Company will process your personal data only for purposes permitted by applicable laws, which may vary depending on where you live, and where the Company operates, and on the terms set forth in this Policy. The purposes of the data processing activities may include:

• Managing our business and to provide you goods and services.

• Managing our relationships/communications with individuals: for example, responding to questions and comments or inquiries, inviting individuals to the Company’s events, making proposals for future service needs.

• For collaboration and research purposes: for example, to enable Company to make more informed and objective decisions when identifying, engaging with individuals interested about our projects and managing the collaboration relationship with hospitality and real estate professionals.

• Market research: processing data about individuals for lawful market research purposes. We collect data to help us improve our products and services.

• Direct marketing: to provide promotional material and engage in marketing and promotional activities with individuals in accordance with applicable laws.

• Website functions: to ensure that content from our website is presented in the most effective manner for you and for your device.

• Legal or regulatory obligations and the directions of law enforcement agencies and court orders: to comply with our legal or regulatory requirements (reporting for the safety of information and product quality complaints) or to fulfil transparency requirements.

• Sending you newsletters and other marketing material related to our project provided that you consent on these.

• Ensuring that the content of our Site is presented in the most effective way for you and your device.

The Company will process personal data for further purposes, where lawful to do so or when legally obliged to do so.

6. Legal basis of processing

The Company processes personal data based on one or more of the following conditions:

• Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);

• Where it is necessary to comply with contractual obligations with you;

• Where the processing is necessary for our compliance with a legal obligation;

• Where the processing is necessary to protect the vital interests of an individual;

• Where processing is necessary in the public interest or for a public task; or
• Where the processing is in the Company’s legitimate interest, for example, the Company processes data for the improvement of our products and services, to provide security measures to protect the Company’s employees, contractors, information and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations) or in other ways strictly necessary to carry out our business.

7. Redirect to other websites 

From this website, you can connect through special links to other websites of third parties. The Company does not endorse or recommend these sites’ content or services and assumes no responsibility regarding the processing activities of personal data or any activity by or content on third-party sites to which our website provides links. We encourage you to read and be aware of the privacy policy, and all other policies, of each site you visit. Remember, the statements in this Policy apply solely to information collected by the Company.

8. Disclosure of your personal data

Personal data are not disseminated to unspecified recipients. The Company discloses your personal data to third party recipients on a need to know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal data will be disclosed only in accordance with applicable laws, and appropriate safeguards through contractual agreements, will be established to protect your personal data.

Access to your personal data is provided to the absolutely necessary staff of the Company, which has committed to maintain confidentiality and our partner companies or third party service providers, who process your personal data as persons who execute the process on our behalf and in accordance with our orders.

The Company shares your personal data with:

– Companies of the Company’s group for the purposes and in the context of the terms mentioned above in this Privacy Policy.

– Third party service providers who process personal data on behalf of the Company, for example (indicatively mentioned) advice / outsourcing, hosting service providers, event management organizations, travel agencies, banks and other providers of support and provision of administrative services that provide support services to us, business associates and associates for the management and maintenance of, email distribution, research and analysis, brand and service promotion, Google, Facebook, and management of certain services and data under agreements that have been made. In addition, the disclosure of personal data may take place if the Company or all of its assets are acquired by a third party, in which case the personal data held by us as individuals will be included as transferred assets or if the Company has obligation to disclose or share the information of individuals in order to comply with any legal or regulatory obligations.

– Other third parties, to the extent required for the following purposes: (i) compliance with a state request, court decision or applicable law, (ii) prevention of illegal use of our Site or breach of the Terms of Use of our Site and our policies, (iii) our protection against third party claims, and (iv) contribution to the prevention or investigation of fraud.

– To other third parties when you have provided us with your consent.

Detailed information on the names of the data processors can be requested by emailing the Company at info@mykilada.com.

The following is the policy we apply to those with whom we share your personal data:

– We only provide the information needed to perform their specific services.

– They may use your personal data only for the exact purposes set out in our contract with them.

– We work closely with them to ensure that your personal data are respected and protected at all times.

– If we stop using their services, any of the data they hold will be deleted or anonymised.

The third parties processing your personal data on our behalf have agreed and committed contractually with the Company:

– to maintain confidentiality;

– not to send to third parties your personal data without the consent of the Company;

– take appropriate security measures;

– comply with the legal framework for the protection of personal data and in particular Regulation 979/2016 / EU (otherwise GDPR).

9. International Transfer of Data

Your personal data may be accessed by staff or suppliers or service providers in, transferred to and stored at, a location outside the EU or the EEA. Where the Company processes personal information in countries that may not provide the same level of data protection as in the EU/EEA or in your own country, where you are resident, the Company will implement reasonable and appropriate legal and technical and organisational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorised access, use or disclosure.

For residents of EEA – whenever we transfer your information outside of the EEA, we will take all reasonable steps to ensure that adequate safeguards are put in place to protect your information (unless we are permitted under applicable data protection law to make such transfers without additional formalities e.g. where the recipient country is considered an adequate destination). Such safeguards include the use of European Commission approved standard contractual clauses as mentioned above. Where appropriate we may also ask for your explicit consent.

10. Security and data retention

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, applicable data protection laws and regulations as well as international security standards. All data you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. The Company has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Access to your personal data is limited to a restricted number of the Company’s employees whose duties reasonably require such information and third parties with whom the Company contracts to carry out business activities on its behalf.

We will retain your personal data for the time strictly necessary to achieve the purposes for which the data were collected and any other permitted associated purpose. Data may be retained for a longer duration where applicable laws or regulations require or allow the Company to do so. When your data is no longer needed it will be either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.

11. Choices about marketing

If we intend to use your data for marketing purposes or if we intend to disclose your data to any third party for such purposes, we will inform you respectively. You have the right to object to personal data being used for the purposes of direct marketing and newsletters. You can also exercise the right at any time by contacting us as set out below.

12. Your data protection rights

Under applicable laws and subject to any legal restrictions, you may have the right to request us to:

• Provide you with further details on the processing of your personal information;
• Provide you access to your personal data that we hold about you;
• Update any inaccuracies in the personal information we hold that is demonstrated to be inaccurate or incomplete;
• Delete any personal information that we no longer have a lawful basis to use;
• Provide you or a third party, with a copy of your data in a digital format (data portability);
• Stop a particular processing when you withdraw your consent;
• Object to any processing based on the legitimate interests or public interest to process information, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
• Restrict certain aspects of the processing of your information.

All data protection related requests should be addressed to the Company at info@mykilada.com.

If we do not handle your request in a timely manner, or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority. Further information and contact details of the competent supervisory authorities can be found here.

13. Policy updating

The Company reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and the Company’s business practices, subject to applicable laws. If the Company changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Policy. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.

14. Contact information

If you have any questions in relation to this Policy, or you want to obtain more information about the Company’s privacy practices, please contact us by email at info@mykilada.com.

LAST UPDATED ON 21^st MAY 2020.