Privacy Protection Policy
Your personal data includes any information that may lead, either directly or in combination with others, to your identification as a natural person. This includes data such as name, surname, VAT number, social security number, physical and electronic addresses, home and mobile phone numbers, e-mail addresses and any other information that allows you to identify yourself under the provisions of the General Personal Data Protection Policy (CPC 2016 / 679) and the relevant Greek legislation and the decisions of the Personal Data Protection Authority (ADAP).
- Collection and processing of Personal Data
Alpha Trust Mutual Fund and Alternative Investment Fund Management S.A. (“Alpha Trust”) collects and process personal data as the Controller:
- For the performance of a contract with regard to investment products or services.
- When you are requesting information for an investment product or a service, or you are contacting with us to submit questions or complains.
- When subscribing to our newsletter service.
The personal data we collect are the absolutely necessary to implement the action or service requested by the Data Subject.
We collect and process different types of personal data, such as:
- Name, surname, VAT number, social security number, physical and e-mail addresses, fixed and mobile phone numbers, as well as the documents that are necessary to prove your identity.
- Financial data, and documents necessary to provide investment services and products.
- Your preferences for certain products or services, if you have informed us about.
- Our communication – i.e. recorded calls or e- mail, or letter, or any other form of communication.
- Information about the investment products, of your interest
In addition we collect information with regard to the way you use our products and services, such us:
- The personal data of co – beneficiaries that you have provided to us
- Information with regard to the way you use our site
- Purpose and legal basis of the Processing
We process your personal data in accordance with the GDPR and national data protection legislation for one or more of the following purposes:
- To contact business transactions and offer services under the contract we have with you.
- To comply with a Legal or Regulatory Obligation
- To inform you about the new products and services of Alpha Trust and our financial reports (unless you have chosen not to be contacted for marketing purposes), as well as to invite you to events
- For pricing purposes
- To respond to your questions or concerns with regard to the investment products or services.
- To protect our legitimate interests
- How long are your personal data Kept
We will retain your personal data for as long as we have a contractual or any other kind of relationship with you. We may keep your personal data for a longer period of time if we cannot delete it for legal or regulatory reasons.
- Transmission of personal data outside the EEA
Your personal data may be transmitted to third countries [i.e. in countries outside the European Economic Area]. Any such transfer shall take place only on the basis of an adequacy decision of EU or subject to the appropriate safeguards.
- Recipients of your personal data
In fulfilling our contractual and legal/regulatory obligations, your personal data may be disclosed to:
- Regulatory and public authorities, to the extent we are legally bound to provide these information, i.e the prosecuting authorities.
- Service providers (data processors)
- Third persons authorized by Alpha Trust
- Law Firms and / or legal counselors
- Automated decision making, profiling
In general, we do not use automated decision making when creating and conducting a professional activity. We may automatically process some of your data to evaluate some aspects (limited profiling) in order to recommend, conclude or execute a contract with you.
- Personal data security
We recognize the importance of protecting your privacy and all of your personal data and we continuously improve the technical & organizational measures, to ensure the security of the processing and to avoid any unauthorized use, access, or disclosure of, loss, accidental or unlawful destruction.
Every employee of Alpha Trust, who has access to the above information, uses your personal data only to serve the above purposes.
The service providers appointed by us for the processing of personal data, are bound by a contract to observe confidentiality and data protection in accordance with national law on protection of personal data and the GDPR. The service providers are not entitled to use your personal data for their own purposes.
We share the information you give us only in the ways described in this Personal Data Protection Policy.
- Your Rights
- You may contact us to inform you about your personal data retained by us and the way of processing, to receive a copy of your personal data. To obtain a relevant copy, you can fill out the form that you can download here and send it to us signed with the authentication of your signature by a competent authority.
- If you think that your personal data are incomplete or inaccurate, please contact us to proceed with the appropriate rectification.
- You may request the deletion of your personal data, If you believe that there is no legitimate reason to continue processing it.
- You may object to the processing of your personal data [known as the “right to object”] on grounds relating to your particular situation. If you file such a relevant request to us, we will no longer process your personal data, unless we demonstrate compelling and legitimate grounds for the processing that override your interests, rights and freedoms, or for the establishment, exercise or support of legal claims.
- You also have the right to oppose to the processing of your personal data for marketing purposes or you may choose to oppose to certain ways of communication, i.e. e-mail, phone, etc.
- If you don’t wish to receive e-mail for marketing purposes, you can unsubscribe from our list.
- You may request a copy of your personal data in a structured, commonly used and machine-readable format, and to transmit those data to another controller. [known as data portability rights]
In order to exercise any of your rights or if you have any other questions regarding the process of your personal data by us, you may contact us Alpha Trust or fill out the relevant form, which you can find it here and send it to Alpha Trust, 21 Tatoiou Str. 145 61 Kifissia, phone num: 210 6289100, e-mail: firstname.lastname@example.org.
Alpha Trust will respond to your request within one month following its receipt. If it is not possible for us to satisfy your request within the period of one month, we will inform you of the reasons for the delay.
Alpha Trust shares your concern about your personal data. For any information you can contact Alpha Trust’s Data Protection Officer at email@example.com
- Right to submit a complaint
If you have exercised some or all of your rights regarding data protection and you still feel that your concerns about the way we process your personal data have not been duly addressed, you have the right to submit a complaint. You also have the right to submit a complaint with the Hellenic Data Protection Authority, Kifissias 1-3, PC 115 23, Athens. On the relevant website you will find information on how to submit complaints (http://www.dpa.gr).
- Changes to the present Personal Data Protection Policy
We may change or modify our Personal Data Protection Policy from time to time and we will accordingly change the review date at the end of this Policy. We recommend, however, that you reexamine this statement periodically so that you are always aware of the way we process and protect your personal data.
The present Personal Data Protection Policy was reviewed on June 1, 2018