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PERSONAL DATA PROTECTION POLICY

PREAMBLE



The Protection of Personal Data Policy covers and concerns the conditions of collection and management of personal data of the readers/guests/users/members from BTH PUBLICATIONS, during the visit and use of its services and pages. BTH PUBLICATIONS is the owner, creator and beneficiary of all rights of their pages and services, as well as the Controller of Data Processing that may be declared by the guests/users thereof. This policy/contract will in no way cover the legal relationship between the guests/users of pages and any other services that are not subject to the control and/or ownership of BTH PUBLICATIONS.

1. SCOPE


The present policy of protection of Personal Data applies only to pages owned and managed by BTH PUBLICATIONS and does not apply to information collected through any other website or other corporate practices which BTH PUBLICATIONS does not control. 
The pages may include links to other websites that are not controlled by BTH PUBLICATIONS but by third party carriers (natural or legal entities). In no event shall BTH PUBLICATIONS be held responsible for the terms of protection of personal data of guests/users which these carriers adopt and apply. 


2. PERSONAL DATA RECORD KEEPING POLICY


No personal data of the guest/user is collected through the simple browsing of the pages of BTH PUBLICATIONS. The use by BTH PUBLICATIONS of personal data of guests/users takes place exclusively for the updating and support of users during the operation of the services to which they subscribe, to meet their individual requirements and to notify them regarding the promotion of new services. The above information may be requested for the subsctription of the guest/user to the mailing list for the dispatch by BTH PUBLICATIONS of website newsletters. Also, when sending the registration form to BTH PUBLICATIONS, the IP address of the guest/user is also collected and a cookie is sent to the user’s computer. The pages provide guests/users with the option to delete their personal data and information at any time, to correct and to update them, or inactivate their registration. A page collects personal data when the guest/user: A. registers in its services, B. uses its services and C. visits its pages. In particular, the technical means by which personal data of users are collected when using the pages’ services are the following:

3. METHODS OF COLLECTION OF PERSONAL DATA



a. Personal data which may be requested by the page. When the guest/user uses certain functions of the pages, such as when registering for certain services, accessing certain content or functions, or when communicating directly with a page or service, various details may be requested of him/her, such as: – contact details, such as full name, email address, mailing address, phone number and mobile phone number – user name and password – information posted in discussions in the community and other interactive online functions, – search queries conducted on the page and – mail sent to BTH PUBLICATIONS through the page.

b. Information collected automatically during the visit and interaction of the guest/user with the page: When the guest/user visits and interacts with the page, and, in this way, certain information may be automatically collected, such as: – the IP address of the computer, – the type of browser and the operating system – the sites visited immediately before and after the visit to the page, – activities within the community discussions – websites and advertisements seen and links clicked on within the page – the speed of the connection and information about the software programs that are installed on the computer – aggregated data on email click-through and displayed user videos – basic information on the connection to the server and – information collected through HTML cookies, Flash cookies, web beacons and other similar technologies.

c. Information can be collected from other sources: Through the use of services of a page, access to information about guests/users may be available to third party sources and platforms (such as social networking sites, databases, online marketing companies and companies which target ads), which include: – if the guest/user gains access to social networking services of third parties (such as Facebook Connect or Twitter) through the page, the user name and his/her connection lists for these services – demographics data such as age group, gender and interests, – interactions with advertisements and viewership data as ad click-through and information about how many times he/she has seen a particular advertisement – unique identifiers, including the identification numbers of mobile devices, which can identify the physical location of these devices in accordance with applicable law. Note that the page may combine information collected directly with information obtained from third party sources.

d. Polls: For the participation of users in polls conducted by the Website, no personal data will be requested. The vote of the guest/user is registered solely for the purpose of drawing conclusions in relation to the position of public opinion on a certain issue. The polls and results thereof are property of BTH PUBLICATIONS.

e. Advertisements: In order for BTH PUBLICATIONS to provide free access to the content of its pages, advertisements appear in it, many of which are targeted based on information individually regarding each guest/user. For example, using the information collected through cookies, web beacons and other sources, demographic data or information may be used regarding the online activities or interests of the guests/users, for displaying targeted advertisements. Note that the practices of third party advertisers or platforms that collect data in the pages are not covered by this policy of protection of personal data.

4. CHANNELING AND DISCLOSURE OF PERSONAL DATA.


a. BTH PUBLICATIONS strictly complies with the Greek legislation on Personal Data Record Keeping. The data reported and collected in the above cases are not disclosed to third parties and are in no way disclosed or become subject to exploitation by BTH PUBLICATIONS. 


b. BTH PUBLICATIONS commits to not sell, rent or in any way publish and/or disclose personal data of guests/users to any third party carrier. 


c. BTH PUBLICATIONS may channel the personal data of its guests/users to third parties exclusively in the following cases: – If having the explicit consent of the guests/users to channel their personal data, which is deemed given when the guest/user registers as a member in any of the Websites owned by BTH PUBLICATIONS and does not submit an objection application, as detailed above. – In the event in which the channeling of the personal data of guests/users to third parties collaborating with the pages owned by BTH PUBLICATIONS becomes necessary for the implementation of the users’ requests. Third parties (natural or legal entities) working with websites owned by BTH PUBLICATIONS have the right to process the personal data that guests/users of the pages submit to them only to the extent strictly necessary in order to provide support to these services. – If the channeling of personal data is required by provisions of the Law and exclusively to the competent Authorities.

d. For statistical analysis purposes and in order to gather information on how its pages and services are used, BTH PUBLICATIONS may also keep in aggregated form and analyze the data collected, in order to improve the functionality of the pages and services and better formulate their content and design.

5. SPECIAL CASES OF USE OF PERSONAL DATA



a. Communications via email: With the consent of the guest/user, the personal information collected may be used in order to send to him/her (the user) communication material via e-mail, such as updates of main articles, information regarding his/her account or changes in the page he/she visits, and, with his/her consent, advertising messages for BTH PUBLICATIONS products and services or products and services of its partners regarding marketing subjects. If the guest/user subscribes to one of the email newsletters of BTH PUBLICATIONS, the newsletter he/she requested will also be sent to him/her.

b. Communications via mobile devices: With the consent of the guest/user, the number of his/her mobile phone may also be used, in order to send to him/her promotional messages, updates, or other services.

c. Electronic Commerce Services: For the use of e-commerce services of chronosplus.gr by the guest/user, the following details are requested: Full Name/Company Name – Address of natural entity/Company Headquarters- Postcode – Telephone – E-mail – fax – TIN – Tax Office – City – Country – Credit Card Details. The above details are also required for issuing the relevant invoices (for tax purposes) and retained in the financial records of BTH PUBLICATIONS. BTH PUBLICATIONS may utilize – process the data collected from user transactions in order to record the purchasing interests of the transacting party and to proceed to new offers, unless the user of these services requests not to receive such offers. The details concerning the purchasing interests of the guest/user may never be disclosed to third parties except for exceptions explicitly mentioned in this contract.

CREDIT CARD DETAILS

The Credit Card that the guest/user will use for the payment of services/subscriptions of BTH PUBLICATIONS, is charged only once and only for the particular transaction, unless the guest/user has chosen to automatically charge his/her credit card every time he/she renews the subscription or service in which he/she is participating. BTH PUBLICATIONS is not responsible for the terms of use of personal data adopted by financial institutions with which it cooperates for the completion of commercial transactions.

d. Sharing information with third parties: BTH PUBLICATIONS respects the privacy of guests/users and shares information relating to them under certain circumstances only. In particular, details related to users are made available to other companies, applications or individuals, exclusively under the circumstances described below: – Aggregate information or information that does not directly identify users may be disclosed to third parties, in order to facilitate the development of content, services and advertisements. It is emphasized that no contact information is disclosed to third parties that are advertised on the pages. – The provision of services associated with the pages, such as database management, provision of maintenance services, analytics, marketing, processing and distribution of e-mail and text messages can be assigned by BTH PUBLICATIONS to third parties. These third parties will have access to information regarding the Users only for the execution of the aforementioned duties on behalf of BTH PUBLICATIONS. – If a page is acquired or merged with another company, information concerning guests/users may be disclosed. However, in such a case, BTH PUBLICATIONS will inform its guests/users, placing a conspicuous notification on its pages or by sending a notification to the primary email address specified in their account, before such information is transferred and subject to a different policy of data privacy. – Information regarding guests/users may be disclosed in order to investigate and/or prevent illegal activities in case of suspicion of fraud, if there are circumstances involving potential threats to the physical integrity and other rights and interests of any person, or if required by law and in other cases in which BTH PUBLICATIONS in good faith considers that the disclosure of information is necessary. – In general, apart from the above cases, the information collected can be used for any other purposes which will be disclosed to the guests/users at the time of collection of the information or upon their consent.

e. Third party services: To simplify the registration process on the pages, guests/users are provided with the option of access or interaction with third-party services, such as Facebook and Twitter. When connection to the pages through these third party services takes place, information may be disclosed to third party providers and, conversely, they may disclose data about guests/users to BTH PUBLICATIONS. When guests/users allow BTH PUBLICATIONS to have access to their data through a third-party service for the creation of profiles on a page, this data can be used for various purposes, such as: – Automatic creation of links to the system of BTH PUBLICATIONS. For example, if the guest/user is connected to a page through a service with a public list of friends, such as Twitter, the Company can check whether any person followed by the respective guest/user on Twitter is also a member of the page. In this case, the relationship of the guest/user on Twitter with these members will be reproduced, adjusting them in order to be fans, followers or friends on the page. – Relationship proposals. For example, if the guest/user is connected with the page through a service that has a private list of contacts (such as Google and Yahoo!), BTH PUBLICATIONS, on its part, will check his/her contacts for persons who are members of the page and will suggest to him/her to become a fan of these users. It is stressed that this process is not automatic. The guest/user must choose to accept to become a fan of these suggested users. –Completion of the list of potential friends to whom the guest/user can send an e-mail. When users share content with their friends, using, for example, the “forward-to-a-friend” function, the page can use lists of friends from third-party services to create a list of contacts to which the respective guest/user can choose to send the e-mail. – Completion of list with potential friends to whom the guest/user can send specific by service messages. For example, lists of friends from a third-party service can be used to create a contact list, to the members of which the guest/user can choose to send an invitation for viewing an interactive presentation. – To enhance and personalize the guest/user experience on pages, when he/she is connected through a third party service, BTH PUBLICATIONS may have access to certain details of his/her account, such as the image of his/her profile, which stories are popular in his/her network and what his/her friends are saying on certain articles or posts. 
In addition, when connected through Facebook with the page, the guest/user can automatically see which stories are popular in his/her network and what his/her friends are saying on specific stories.

F. Contests: Personal data of participants in Contests organized by the Websites is collected and kept in a file that is processed by the Organizing company (BTH PUBLICATIONS). The purpose of the collection, retaining and processing of the personal data is to support the necessary activities only for the purpose of the respective contests organized under the care of BTH PUBLICATIONS. The personal data of participants will be retained by the organizing company and will be used for the purposes of the contests, namely for verification of the winners’ details, to award the gifts to them, to communicate with them on setting the details of their participation and generally for the completion of all necessary actions as well as to inform them (such as sending any advertising material, if requested by the participant).

6. COOKIES

The pages may use cookies for the proper functioning of their services and pages. The cookies are small text files (in .txt format) sent and stored on the hard disk of the computer of the guest/user, if the latter has chosen to accept cookies. The cookies are only used to facilitate the access of the guest/user to specific page services, as well as for statistical purposes in order to determine the areas in which the page services are useful or popular. The guest/user may configure his/her browser in such a way so as to warn him/her (the user) on the use of cookies on certain page services, or to refuse in all cases to accept the use of cookies. In the event that the guest/user does not desire the use of cookies for his/her identification, he/she cannot further access these services.

7. IP ADDRESSES


The IP address is determined by the provider of the connection through which the guest/user has access to the internet and subsequently to the Website. The IP address is kept for technical reasons as well as to address issues relating to the security of page systems (server, database, network, etc.). The IP address with which the guest/user has access may be disclosed by BTH PUBLICATIONS, if requested by the competent police or judicial or other state authority, always in compliance with the stipulated legal process.

8. USER OPTIONS


a. The guest/user may at any time deactivate his/her account by visiting the preferences page in his/her profile. When deactivating the account, the profile will be disabled, but the public comments will remain on the page that he/she has visited and has made use of its services. The page will not deactivate, remove or edit any of his/her public activities or any submission which is the result of his/her public activities.


b. In addition, many third party advertising networks are IAB members. In order for the guest/user to be excluded from the use of information collected by IAB members for advertisement with behavior analysis, to obtain information about the technologies that may be used by these advertising networks, and to see the personal data protection policies they implement, it is recommended that he/she visits the IAB Website.


c. Flash Cookies. The guest/user can control how Flash cookies are used by visiting the Adobe website. Adobe enables the guest/user to allow certain Flash cookies from certain websites, to restrict the ability to store Flash cookies, and to block all Flash cookies entirely. Additionally, if he/she uses the Mozilla Firefox browser, he/she can download the BetterPrivacy add-on in order to automatically delete Flash cookies every time he/she closes the browser.

d. BTH PUBLICATIONS does not have access nor has control over cookies of advertisers or service providers and the information policies of third parties are not covered by this policy of protection of personal data.

9. ACCESS TO PERSONAL DATA


BTH PUBLICATIONS entitles users to delete their personal data, to correct and/or update their personal data and/or inactivate their registration at any time, simply by visiting the relevant service of BTH PUBLICATIONS. In accordance with applicable laws and regulations, he/she must send, along with the request, proof of identity and will receive an answer within thirty (30) days of receipt of the request.

10. CONFIDENTIALITY AND SECURITY


Access to contact details of guests/users is restricted to employees and service providers deemed reasonably needing to know those details in order to provide products or services to guests/users or for the execution of their work. They have also adopted technical, physical and administrative procedures which are suitable for the protection of information relating to Users from loss, misuse and alteration. It is emphasized that any transmission or storage of data cannot be guaranteed as 100% secure.

11. MINORS UNDER 18 YEARS OF AGE


Users of pages who are minors are not allowed to have access to their services, which may be considered inappropriate for minors and which cannot be controlled by BTH PUBLICATIONS. Each section or service which may contain material inappropriate / offensive / immoral includes a notification to guests/users. In the event that underage users still voluntarily visit pages with material inappropriate / offensive / immoral and which cannot constantly be kept in check, BTH PUBLICATIONS holds no responsibility. BTH PUBLICATIONS does not knowingly collect personal information from minors under 18 years of age. If it finds that it has collected any personal information from a minor under the age of 18 without verifiable parental consent, it will delete the information from its database as soon as possible.

12. APPLICABLE LAW


The management and protection of personal data of the guest/user of page services of BTH PUBLICATIONS is subject to the terms of this policy and the relevant provisions of Greek legislation (L. 2472/1997) on the protection of personal data, as amended and currently in force and supplemented by the decisions of the Chairman of the Commission for Personal Data Protection and other relevant legislative acts in this context, any potential relevant regulation will amend the present in the particular scope. In any case, BTH PUBLICATIONS reserves the right to modify the terms of this policy of protection of personal data within the existing or potentially new legal framework, after the relevant notification of guests/users. The use of the services of pages implies full and unconditional acceptance of the terms hereof. In the event that a guest/user does not agree with the terms of protection of personal data provided herein, he/she must not use the services of the pages.

TRANSACTION SECURITY


In its websites, BTH PUBLICATIONS uses the SSL protocol with 128bit encryption (the most powerful today), for secure on-line transactions. In this way all your personal information is encrypted, including your credit card number, name and address, so that they cannot be read or changed during their transmission over the Internet. The SSL protocol (Secure Sockets Layer) is now the global standard for website certification to web users and for date encryption between web users and web servers. An encrypted SSL communication requires that all information sent between a client and a server is encrypted by the sending software and decrypted by the receiving software, thus protecting personal information during their transmission. In addition, all information sent by the SSL protocol is protected by a mechanism that automatically detects whether the data has been altered during transmission.