Personal Data Protection Policy

At Alpha Asset Management MFMC (hereinafter “the Company”) we recognise the importance of the personal data (hereinafter “the Data”) of our website’s visitors. The protection of your personal data, always in compliance with the applicable regulatory framework on the protection of personal data, constitutes a commitment for us.

This Personal Data Protection Policy applies to the Company’s website. It aims to provide information regarding the collection, storing, use and any other form of processing of visitor data by the Company, in its capacity as Data Controller, as well as regarding your rights pursuant to applicable provisions.

1.1 Data required for the submission of online comments through the Company’s website, complaints, questions and requests:

• full name, email address, landline and/or mobile phone number, comments, requests, etc.

1.2 Cookies:
As described in detail in the Cookies Policy, we collect information using cookies.

1.3 Device data:
When you visit our website, we receive the URL address of the website you accessed prior to visiting our site, the date and time of your visit, the operation system of the device and the browser used, as well as the IP address of your device.

We collect information that you disclose to us when you visit and/or browse our website, when you submit an online comment, complaint, question, or request. Furthermore, we may collect information from third parties (persons or legal entities), e.g. IT and technology companies and social network platforms.

The Company collects and processes only the data required to pursue the following purposes. In particular:

3.1 We may process your data in the context of the contractual relationship between us:

• For the management of your complaint, in relation to one of our products or services.
• For the management of a request you submit regarding one of our products or services.
• For your information regarding our products and services, for which you have previously expressed an interest.

3.2 We may process your data to pursue our legitimate interests, provided that they do not exceed the rights and freedoms of the visitors of our website, e.g.:

• For the accurate and more efficient operation and management of our website.
• In order to investigate and resolve technical issues in the context of the provision of our services (e.g. coding errors).
• For security purposes or to investigate possible fraud or other violations of the terms of use of our website or this policy.

In any case, the Company may process your data for purposes of compliance with the obligations imposed by the currently applicable legal and regulatory framework and the supervising authorities, as well as with the decisions of competent authorities or courts.
 

We may disclose your data, in addition to the employees of the Company responsible for the processing of requests, the management of comments, complaints and questions you submit through our website, provided that the currently applicable statutory conditions are met, to the competent employees of companies of our Group in the context of their activities, as well as to third parties (natural persons and legal entities, to whom the Company assigns from time to time the performance of certain tasks on its behalf), under the condition to maintain at all-time professional secrecy and the confidentiality, e.g.:

• Advertising and marketing agencies for the products and services of the Company.
• Database and website administration companies.
• Providers of innovative solutions for payment technologies and services, providers of postal services, development services, maintenance, customisation of IT solutions, email services, hosting as well as cloud services.

In any case, the Company guarantees that it will not transfer, disclose, provide, etc. your data to third parties for any purpose or use, other than those expressly disclosed in this Policy. However, we reserve the right to disclose information related to you, if we are obligated by the law or if said disclosure is required by the competent supervisory, audit, independent, judicial, public and/or other authorities. Furthermore, keep in mind that the Company may transfer the data it collects from its website to countries outside the European Union or to an international organisation in the following cases: a) if the European Commission has issued an act regarding the sufficient protection of personal data in that specific country or international organisation, b) if you have been specifically informed and you have expressly given your consent to the Company and the other conditions of the legal framework are met, c) if the transfer is necessary for the performance of a contract, e.g. if the transfer is necessary for the execution of orders concerning the Alpha (LUX) Global Funds, d) if the transmission is necessary for the establishment, exercise or defence of legal claims or the defence of the Company’s rights, e) if there is a relative obligation arising from a statutory provision or a transnational/ international convention.
 

The Company implements appropriate technical and organisational measures to ensure confidentiality, integrity and availability of the information on a permanent basis, in order to be protected from incidental or unlawful destruction, loss, alteration, prohibited dissemination or access and any other form of unlawful processing.

The Company audits, pursuant to the established procedures, the compliance with the Group’s Information Security Framework, conducts special security audits (penetration tests and vulnerability assessments), trains and educates its personnel on security matters and continuously assesses the elevated information security level, taking further measures to address new threats and the associated risks, as this is deemed appropriate.

These measures contain but are not limited to, special, multilevel security mechanisms for the protection of the services provided via the internet and the entire infrastructure of the Company, mechanisms for the prevention of data loss (DLP), recording of access, protection of systems, central management of user access control based on their operational duties, as well as encryption and pseudonymisation of information, when required.

However, it is your responsibility to ensure that the equipment (e.g. personal computer), software, telecommunication equipment that you use is sufficiently secure and protected from malware (e.g. viruses). You should be aware that not using sufficient security measures (e.g. secure settings on your browser, updated malware protection software, avoidance of use of software and hardware of dubious provenance, etc.) entails the risk that the data, as well as the passwords you use, can be disclosed to unauthorised third parties.

6.1 We will keep your data as long as you are a customer of the Company and for a period of at least five (5) years after the liquidation of the mutual fund.

6.2 If you are not a customer of the Company, we may keep the data collected from our websites for a period of up to five (5) years after their collection thereof.

6.3 We will keep your device data for two (2) years after their collection.

6.4 Regarding the retention period of cookies, please refer to the Cookies Policy.

6.5 After the lapse of the retention period, the Bank will ensure the secure destruction and/or deletion of your data.

You have the following rights regarding the data we keep for you:

Right of access: You may request to receive information regarding the processing of your data (e.g. the categories of data, the purposes of processing, etc.).

Right to rectification: You may request that we rectify or supplement your data if they are incomplete or contain inaccuracies.

Right to erasure: In some cases, you may request the erasure of all or part of your data (e.g. if the data is no longer required for the purposes for which it was collected).

Right to restrict processing: You may request the restriction of the procession of your data, where specified by law.

Right to object: You may object, at any time, to the processing of your data, in the context of pursuing our legitimate interests, as specified above.

Right to data portability: You may request that we give you or transfer to a third provider some of the information you have provided us, in electronic form.

If you wish to exercise one of the aforementioned rights, you may contact us:

• in one of the Alpha Bank branches, by filing in the relevant request form.
• by email to CSO@alpha.gr. 
• at the address "Alpha Asset Management M.F.M.C., 45  Panepistimiou Street, 105 64 Athens.

In case of submission of a request to exercise your rights, the Company shall respond to your relevant request within one (1) month. Said time limit may be extended by two (2) months, following your prior notification, taking into consideration the complexity of the request and the number or requests being processed.

Keep in mind that our response to your aforementioned request is provided free of charge. However, if your requests are obviously inadmissible, excessive or repeated, we may charge a reasonable fee, after notifying you in advance or refuse to respond to your request.
If you believe that your rights are infringed in any manner whatsoever, you may also submit a complaint to the competent Supervising Authority.

Hellenic Data Protection Authority

Address: 1-3 Kifisias Avenue, 11523 Athens, Greece
Call Centre: +302106475600
Fax: +302106475628
Email: contact@dpa.gr 

9.1 The Company does not collect or gains access to, in any manner whatsoever, special (“sensitive”) categories of personal data. The visitor has the obligation to refrain from providing such data, related to their person or third parties. Otherwise, the data will be deleted as soon as we become aware of it. The Company shall not be held liable to any visitors or third parties for the provision and/or processing of such data, caused by their acts or omissions in breach of the aforementioned obligation.

9.2 Our website may contain links to other websites that are not controlled by the Company, but by other third parties (e.g. Greek and European supervising authorities, other services, etc.). This Policy does not apply to said websites and we recommend visiting them directly in order to be informed about their data protection policies.

This Policy does not apply to said websites and we recommend visiting them directly in order to be informed about their data protection policies. 

9.3 We may amend this Policy from time to time, to remain compliant with the statutory requirements and the procedures of our business activities. If we decide to replace this Policy or effect very important changes, we will notify you with a notice on this website. In order to be informed about the most up-to-date version of this Policy, visit this page regularly.

If you have questions or complaints related to this Policy, you may contact us using the following information:

Data Controller
Alpha Asset Management MFMC
Address: 45 Panepistimiou Street, 10564 Athens, Greece
Contact number: +302103266505

Data Protection Officer
Data Protection Officer of Alpha Bank Group
On behalf of Alpha Asset Management MFMC
Address: 105 Athinon. Av, 104 47 Athens
Contact number: +302103266971
Email: contact-DPO@alpha.gr