- Who is the Personal Data Controller?
- What data are we processing?
- For what purposes do we use your data?
- On what legal basis do we base the processing of your personal data?
- How long do we keep your personal data?
- How do we protect your personal data?
- Who has access to your personal data and to whom is it disclosed?
- What are your rights and how can you exercise them?
- What about Facebook / Instagram and ads in particular?
- LinkedIn Advertisements, LinkedIn Analytics and LinkedIn Marketing Solutions
- Pinterest targeting capabilities (Interest / Keyword / Audience targeting)
- YouTube video
- Twitter and advertising
1.1. Marmara Gonianaki Industrial and Commercial S.A., Z-G Industrial Area of Heraklion, Crete - Greece, PC 71601, with Tax Identification No. 999979183, Tax Office of Heraklion (hereinafter the "Company"), has official accounts on social media (Facebook, LinkedIn, Instagram, Pinterest, etc.). On its websites, the Company incorporates hyperlinks to social media, thus proposing to visitors to follow the Company on the respective media (Follow / Like), as well as to make posts and comments in accordance with the Social Media Use Policy. During your transfer or visit to the respective social media we have the ability to collect some of your data. Every time you transfer to or visit the accounts, groups, profiles, pages, etc. that we maintain on our social media or profile elsewhere (eg Google maps) (collectively the "Pages") you fully and unconditionally accept the following terms, which are posted on the Pages and websites of the Company.
Who is the Personal Data Controller?
2.1. As a rule, the Company is considered a joint controller for the processing of your data together with the social media in relation to a part of your data kept by the social media and to which the Company accesses. The Company processes this data only when you interact through the respective Page or the websites of the Company. The Company is not responsible for the manner or means by which each social media provider processes your data and it is your responsibility to be informed in accordance with the respective social media privacy policies. However, the Company is the Controller of your personal data when it decides the purposes and means of data processing for certain processes, in which case the social media is the data processor.
2.2. For any questions you may have regarding this Policy, you can contact the Company and the Data Protection Officer at the following contact details:
Address: Z-G Industrial Area of Heraklion – Crete, Greece
Telephone: +30 2810380054
What data are we processing?
3.1. The Company collects information that you provide to us, information that we collect when you contact us, when you visit our Pages, when you make an evaluation, as well as when you check our ads on the Pages or other websites. In particular, when you interact through your profile on our Page or other websites, the Company may process data resulting from your profile, such as, for instance, username and profile photo on the specific social media, as well as name, surname, demographic data such as gender, age, other biographical and professional data, data that you voluntarily publish or share on social media with posts or other functions, information about your lifestyle and interests, information about shopping and your online shopping behavior, the categories of products, or services that interest you the most, as well as geographic data, data contained in your communication with our Pages and data resulting from your activity on our Pages. In addition, the Company may collect anonymized / statistical data regarding your visits to our Pages.
3.2. The Company does not process special categories of data. We urge you not to send us messages or post comments and posts that contain sensitive information about you or third parties, as well as not to disclose personal data of other persons without first obtaining their consent. In the event that you provide us with such information, we declare that we will delete it immediately and will not process or reply further.
For what purposes do we use your data?
4.1. The purposes of the processing of your data are the display and promotion of the Company and its products and services, the provision of updates or communication with you, to respond to messages / comments / requests / questions you send us, to manage our websites and our services, the management and optimization of the content of our Pages, the statistical analysis and market research for the users who interact with the Pages or the websites of the Company, the exercise of our legal rights, the assurance of your compliance with the Social Media Use Policy, the conduct of a contest.
4.3. In addition, we may collect data in relation to job vacancies published by the Company on the Pages for the purpose of evaluating user data and / or establishing a business relationship.
On what legal basis do we base the processing of your personal data?
5.1. The Company bases the processing of your personal data on one of the following:
- the legitimate interest of the Company to promote its products, services and activities and to improve the image of the Company
- the legitimate interest of the Company to prevent the violation of the Company's Social Media Use Policy and any law, order or regulation, as well as the misuse of the Pages by internet users and to defend the legitimate interests of the Company
- the consent you have given to the respective social media
- the consent you have given to the respective social media regarding cookies and similar tracking technologies
- the performance of a contract in the context of a contest
- the performance of a contract or the adoption of pre-contractual measures aimed at performing a contract with you in the case of posts by the Company regarding career opportunities.
How long do we keep your personal data?
6.1. We process your personal data strictly and only for the time required to fulfil the intended purposes and then we will delete it. However, we will retain any of your personal data to comply with our legal obligations and for the time period required by law, or until any dispute between us is definitely resolved, whereas we may retain some anonymous or pseudonymous data for statistical analysis purposes.
How do we protect your personal data?
7.1. The Company undertakes to maintain the confidentiality of personal data during their processing and has taken all appropriate technical and organizational reasonable measures (such as restricting user access rights of Pages administration) to prevent breach of personal data concerning exclusively the same. Any issues of personal data breach that relate exclusively to social media platforms, such as malicious software, identity theft, phishing and any other form of cyber attacks, are not related to the Company. We invite you to visit the respective social media privacy policies to learn about the security measures they take in relation to the processing of your personal data. The data you post on our Pages are handled by authorized persons who are under the control and act as mandated by the Company. For the processing, the Company selects persons with professional qualifications who provide sufficient guarantees in terms of technical knowledge and personal integrity for the observance of confidentiality.
Who has access to your personal data and to whom is it disclosed?
8.1. Access to your personal data is available only to duly authorized employees of the Company, or service providers who help us manage our business or any external partners of the Company who are either related to the marketing of the Company and the management of the Pages, or gain access due to legal obligations. or due to a dispute that may arise (e.g. legal counsel of the Company). Your personal data is not disclosed to third parties and is generally not transfered outside the European Union. However, in the event of any transfer of your personal data outside the European Economic Area, including countries for which there is no adequacy decision of the European Commission or to International Organizations, all appropriate guarantees under current personal data protection legislation will be taken.
8.2. In addition, in case the Company receives a request from a competent Administrative Authority, Prosecutor, Court or other Authority, it may be necessary to forward this data to the said Authorities (with or without your prior notification) based on the provisions of the law.
What are your rights and how can you exercise them?
9.1. You have the right to be informed, right of access, right to rectification, erasure, restriction of processing where permitted, object and portability, human intervention in automated individual decision-making, including profiling, and withdrawal of consent, as provided in GDPR and in law 4624/2019, as in force. In order to exercise your rights, you are requested to contact us at the contact details mentioned above under clause 2.2. To withdraw your consent on social media, you must submit your request directly to the social media. You also have the right to submit a complaint regarding the processing of your personal data to the Hellenic Data Protection Authority (www.dpa.gr).
9.2. The Company is not required to comply with a request for erasure if the processing of personal data is necessary to comply with a legal obligation, or to fulfill another legal purpose or other legal basis or to establish, exercise or defend legal claims.
9.3. The right to object applies to any processing of personal data, based on the legitimate interest of the Company. If the data subject exercises the right to object, the Company has the right to demonstrate compelling legitimate grounds for the processing which override the rights and freedoms of the data subject.
9.4. The Company reserves the right to request proof of your identity when exercising the above rights. The exercise of rights is free of charge, unless the request for access to information is unfounded or excessive, in which case the Company may charge a reasonable fee, of which the Company will inform you before completing the request. Valid requests will be served no later than one (1) month from their receipt, unless they are particularly complex or numerous, in which case the Company will try to respond within three months.
What about Facebook / Instagram and ads in particular?
10.1. As mentioned above under 2.1., Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, D2 Dublin, Ireland (“Facebook”) is also a Data Controller. For more details, please see here: Facebook for Facebook and Data Policy | Instagram Help Center (facebook.com) for Instagram (Note: Instagram belongs to Facebook).
10.2. You can contact Facebook’s Data Protection Officer here: https://www.facebook.com/help/contact/540977946302970
10.3. You will find more details regarding the processing of your personal data by Facebook in your profile, in the section Settings and privacy or here: https://www.facebook.com/help/568137493302217
10.4. Insights: We receive statistics from Facebook about visitors to our Pages through Facebook's Audience Insights service. We cannot link this information to a specific person. This feature allows us to better analyze our Pages and adapt them to the needs and interests of our visitors. Facebook processes personally identifiable information about this service at its own risk. For more information, visit: https://www.facebook.com/iq/tools-resources/audience-insights.
10.5. Interactions with our Pages: We can also see when a particular Facebook user likes or subscribes to one of our Facebook Pages. We can also link comments to individual users on our Pages. The same applies to Instagram.
10.6. Review: We review the comments on our Pages for any inappropriate content. In this way, it is easy to see under which Facebook profile a particular comment was posted. A link is created between the content of the comment, the timestamp that is created when the comment was posted, the user ID, the Facebook username, and a reference to previous posts and comments. We can hide the comment or block the user, following such review.
10.7. Processing for advertising purposes. The Company uses certain Facebook and Instagram services to display ads and targeted ads by creating audiences. In particular, Facebook Custom Audiences allows us to target existing contacts and visitors for Facebook and Instagram ads. Facebook takes the data we give it and then tries to match it with the users of the platform. These users can then view - and interact with - our ads. Website Custom Audiences allows us to target visitors who have visited the Company's website in the past by using a Facebook Pixel. Custom Audience follows people who have been involved with our Facebook or Instagram content. These actions of users can be used as a resource for a similar audience, in order to find people who have similar characteristics to people who have interacted with our Facebook (Facebook Lookalike Audience) content. It is also possible to use a customer list to create a custom audience, which we "upload" to Facebook, targeting the customers of this list.
Facebook Audience Network: The Facebook Audience Network is an advertising service provided by Facebook. The Company's website may use mobile IDs (including Android Ad ID or iOS Ad ID) and cookie-like technologies for the operation of the Facebook Audience Network service. One of the ways that this service displays ads is by using the user's ad preferences. The user can configure this usage through the Facebook ad settings (https://www.facebook.com/ads/settings) and Instagram respectively (https://www.facebook.com/help/instagram/245100253430454). Additionally, the user may be excluded from a specific Audience Network targeting through the applicable device settings, such as the device ad settings for mobile phones.
10.8. Processing to measure results: The Company uses certain Facebook services for statistical analysis purposes and conversion tracking.
Facebook ad conversion tracking (Facebook pixel): Facebook ad conversion tracking (Facebook pixel) is an analytics service provided by Facebook that links data from the Facebook ad network to actions performed on the Company's website or Pages. The Facebook pixel monitors conversions that can be attributed to ads on Facebook, Instagram and the Audience Network.
10.9. Processing for targeted or repetitive marketing via Custom Facebook / Instagram Audience: This type of service allows the Company and its affiliates to update, optimize and display ads based on previous use of the Company's website or Pages by the user. This activity is performed by tracking usage data and using Cookies. Some services offer a remarketing option based on email listings. In addition to any opt-out offered by the third party service provider (Facebook), the user may opt out of the use of a third party service cookie for certain remarketing capabilities by going to the Network Advertising Initiative opt-out page, or the Digital Advertising Alliance, or the European Digital Advertising Alliance. Users may also opt out of certain ad features through the applicable browser or device settings, such as mobile device ad settings or ad settings in general.
10.10. Targeting links: As mentioned above, Facebook allows us to target our ads to people who have subscribed to our Page, and / or our event. Keep in mind that a person is considered to be "connected" to one of the above elements if they have interacted with them or are friends with someone who has done so. This option applies to all social media platforms where we maintain Pages.
LinkedIn Advertisements, LinkedIn Analytics and LinkedIn Marketing Solutions
11.1. We use the services of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Dublin, Ireland ("LinkedIn"). As part of these services, LinkedIn collects and stores usage data in alias profiles to enable site usage statistics, evaluate ad success, and display ads on our site, LinkedIn, and LinkedIn affiliate sites, which are relevant to your interests. If you are a LinkedIn user, LinkedIn may also combine data with your user account. LinkedIn also sets cookies for data collection. You can withdraw your consent for these cookies through the Linkedin platform. You can also disable cookies and related data collection through the following websites:
You can find more information about data protection for LinkedIn at: https://www.linkedin.com/legal/privacy-policy.
11.2. In particular, we can target ads to you through LinkedIn's Matched Audiences tool, either by uploading a list of companies or contacts, or by re-targeting people who visited our site, watched a video ad, interacted with our Page, responded to an Event invitation from us on LinkedIn, opened or submitted a Lead Gen Form, either by integrating contacts from a third party system or by creating a uniform audience.
Pinterest targeting capabilities (Interest / Keyword / Audience targeting)
12.1. The Company uses the services of Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Dublin, Ireland for targeted advertising, which creates a custom audience on the dashboard and is one of the following:
- Previous visitors to our websites or Pages
- Email subscribers (or other list of data we may have from customers)
- Pinterest interaction audience - people who previously interacted with one of our pins (click, save, open, comment)
- Pinterest actalike audience - an audience that shares similar characteristics based on the aforementioned audience categories.
12.2. In addition, our pins appear to you based on the interests you have declared on Pinterest, as well as keyword-based search results. For more details see here: https://help.pinterest.com/en/article/edit-personalization-settings. You can change this through your account settings.
12.3. The Company receives an ad performance report from Pinterest. You can control this by changing your personalization options from your account settings.
12.4. You can always disable the relevant cookies through the applicable settings of your browser or device, as well as here: http://optout.aboutads.info/
Twitter and advertising
14.1. We use the services of Twitter International Company (Co. number 503351, VAT number IE9803175Q), based in Ireland (One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Dublin), to display ads to you and to measure the efficiency of our ads. We have the ability to re-target specific groups of people through the use of custom audiences that have been created based on a list or based on internet activity (previous visitors of the Company's website) through the website tag tool. You can find out more here: https://twitter.com/en/privacy, in the settings section of your Twitter account about your data (https://twitter.com/settings/your_twitter_data) and personalization (https: //twitter.com/settings/account/personalization) as well as here: https://help.twitter.com/en/rules-and-policies/twitter-cookies. You can also set cookies via your browser or device settings, or here: http://optout.aboutads.info/.