Code of Conduct and Personal Data (GDPR) Security Policies

In the course of the Company's operations, data is collected in order to enable the provision of its services. This data is necessary for the fulfilment of the Company’s contractual obligations to clients. In addition, the Company works with third party vendors (airline companies, hotels etc.) the data of which is collected as part of this cooperation. The Company also collects personal and sensitive data of its employees, such as sick leaves, pregnancies etc. Any personal data collected by the Company is ordinary (namely, data relating to the name, e-mail address, ID or passport numbers of clients or persons representing such clients, TIN, profession, address, phone numbers, credit or debit card numbers, and any tax documents necessary to invoice the services provided etc.), The collection and processing of such data is intended to enable the provision of better and faster service by the Company.

Data collection results from entering into contractual relations with clients, vendors and employees. Data is collected by the following departments:

As part of our operations, any data collected by the Company may be transferred to third parties or third countries. Such transfer applies exclusively to data required for the provision of services requested by the client and the discharge of other contractual obligations for the implementation of any project. All cooperation agreements between the Company and third parties explicitly stipulate that the contracting third parties must comply with the Regulation. Furthermore, such data may be transmitted to any judicial and/or tax authorities and/or lawyers.

Personal data is retained for the duration of such relation (contractual obligations) with the data subjects.

The personal data of clients are retained for a period of at least fifteen (15) years to enable the Company to fulfil its obligation to submit accurate information to the tax or other administrative authorities.

• 7.1. The Company shall keep such personal data in printed and/or electronic form.

  • 7.1.1. The Company shall keep all client, vendor and employee details, as well as any electronic correspondence with the data subjects in electronic form in files stored on an external server installed at its registered office. Each PC has a unique password which is changed from time to time and which is known and managed by Controller and/or any authorised employee working under his/her direct supervision. Any processing by unauthorised users is prohibited. However, in cases where it is absolutely necessary and with the personal responsibility of the Controller or his/her authorised employees, data may be stored on USBs kept under lock and key, as well as on electronic reading devices (PCs and notebooks, tablets and smartphones) owned and used by the Company.

    The Company shall update and monitor its security technology on an ongoing basis. The Company shall restrict access to your personal data to employees who need to know such information. In addition, the Company shall provide training to its employees on the importance of confidentiality and non-disclosure as well as on the security of personal data. Among other means, the Company applies technical and administrative measures and procedures to protect such data from any loss, alteration, unauthorised processing or modification, including but not limited to encryption, detection and management of security breaches, use of information systems and software installed on PCs in such a way that minimis es the use of personal data and/or user identification data, adoption of individual procedures for the retention and safe deletion/destruction of personal data.

    Copies of all data kept in electronic form are also kept in back-up files stored on an external hard disk kept in the Director's office that can be locked, and the only person who has the key is the Legal Representative of the Company. All electronic devices where personal data is stored must not be exposed in places accessible to the public or where their display screen can be viewed by any person other than the authorised users of such devices.

  • 7.1.2. The Company keeps paper-based files of clients, vendors and employees (and, specifically, documents including the details of clients, vendors, employees and others) that are stored in cabinets or archive boxes secured with locks in the Company's administration offices which are accessible only by the Legal Representative/Controller of the Company, and the Company has also installed an alarm and fire warning system.