1. ON THE PERSONAL DATA PROTECTION REGULATION
For Dog Payment Institution S.A. the protection of personal data is of primary importance and is treated with the utmost seriousness. Respecting the personal data we manage and ensuring their correct processing is one of our Company’s priorities. For this reason, we take all appropriate technical and organisational measures to protect the personal data we process and to ensure that they are always processed in accordance with the requirements set by the applicable legal framework and in particular by the General Data Protection Regulation (EU) 2016/679.
2. DATA CONTROLLER/PROCESSOR CONTACT DETAILS
Dog Payment Institution S.A. acts as a Data Controller for all personal data it collects, processes and stores.
For issues relating to the processing and general management of personal data, you can contact the Data Protection
Officer at firstname.lastname@example.org.
3. WHAT DATA WE COLLECT AND PROCESS
In order to provide our services and to execute money transfer and payment orders, we collect and process all the information provided on the relevant forms or online application forms, such as “indicatively” full name, patronymic, full address details, telephone number, e-mail, birth details (country, city, date), occupation, VAT number/country of issue/date of issue and expiry of any identity document (ID card, or passport, or military ID,
etc.), a recent tax return and a sample of your signature. Finally, in cases where you use our online services through the website of Dog Payment Institution S.A., we collect and process information such as your full name, telephone number, email.
4. TYPE OF DATA PROCESSING & LEGAL BASIS FOR PROCESSING
All the above personal data are collected and processed in order to provide services to our customers and more specifically to carry out remittances and payments. Some information may also be used for purposes of information and promotion of Dog Payment Institution SA’s services to existing or potential customers, always with their consent.
Legal bases for data processing may be as appropriate:
a) The conclusion and execution of a contract between the Company and its customers (for the execution of money transfers and payments). Without the collection and use of the above information it will not be possible to carry out your transaction (Contractual relationship & your Consent)
b) The compliance of the Company with its legal and regulatory obligations arising from the applicable legal framework concerning the Company’s business activities. (Legal obligation)
c) Safeguarding the vital interest of a natural person
d) Public interest task/exercise of public authority by the controller
e) Legitimate interest
We are required by law (and are thoroughly checked by governmental mechanisms in this regard) to use and sometimes share data with the relevant governmental bodies to verify the identity and ensure the transparency and legality of financial transactions.
The safeguarding and protection of the legitimate interests of both Dog Payment Institution S.A. and its clients, in case we need to support legal claims or defend our rights and interests before the courts.
The consent that you may give us in order to receive information about the Company’s services, its pricing policy, commercial actions and activities, etc. Where consent is given, you can withdraw your consent at any time. The processing of personal data concerning you is stopped as soon as you withdraw your consent. However, the previous processing remains lawful.
5. TRANSFER OF YOUR PERSONAL DATA
Your personal data are transmitted to the representatives of Dog Payment Institution S.A., who facilitate the realization of transactions. In this case, Dog Payment Institution S.A., continues to be the Data Controller and has bound its network of agents with a data processing contract, in which all the individual processing elements are specified in detail, thus ensuring compliance with the requirements of the General Data Protection Regulation.
In addition, your data may be disclosed – as required or permitted by applicable law – to payment providers, banking partners and regulatory, financial or other governmental authorities and public bodies and courts, in order for the Company to comply with its legal obligations or to defend its rights and interests.
6. INTERNATIONAL TRANSFERS OF DATA
Where required by the nature of the transaction, it is possible that your data may be transferred to countries or organizations outside the European Economic Area. If such transfers are not covered by an adequacy decision of the European Commission, they will be protected by appropriate safeguards or other mechanisms approved by the European Commission as required by the relevant legislation.
7. TIME PERIOD FOR STORING DATA
Your data is stored at least for as long as required by the respective legal frameworks that regulate financial transactions and the general business operation and with which Dog Payment Institution SA is bound and must comply. For security reasons and in order for Dog Payment Institution S.A. to be able to respond to a possible audit by a government authority, or to exercise and defend its legal rights your data is kept 5 years longer than the mandatory retention period required by law.
If the processing is based on your consent, the personal data is kept until you withdraw that consent. It is clarified that the withdrawal of consent does not affect the lawfulness of the processing based on consent prior to its withdrawal. In any case, Dog Payment Institution S.A. applies all appropriate technical and organizational measures to ensure the protection of the personal data it processes and constantly ensures the prevention of any unauthorized access to these data.
8. RIGHTS YOU HAVE IN RELATION TO YOUR PERSONAL DATA
With regard to the processing of your personal data you can exercise the following rights rights:
a) Right of access
You have the right to know what data we hold and process about you, for what purpose and other additional information about them, and to ask us to their copy.
b) Right to rectification
You have the right to request the correction, modification and completion of your personal data
c) Right to erasure (“right to be forgotten”)
You have the right to request the deletion of your personal data when they are processed after your consent. In cases where the processing is based on another legal basis (such as, but not limited to, the performance of a contract, a legal obligation or the protection of the Company’s legitimate interests, etc.) your right may be subject to restrictions or may not exist.
d) Right to restrict processing
You have the right to request the restriction of the processing of your personal data when their accuracy is questioned and until they are verified, alternatively, instead of deleting them when they are no longer necessary for the processing purposes for which we collected them, but are necessary for the establishment, exercise or support of legal claims by you, when you object to their processing and until it is verified that
there are legitimate grounds for such processing by Dog Payment Institution SA.
e) Right to object to processing
You have the right to object to the processing of your personal data when it is based on legitimate interest, as well as for direct marketing and profiling purposes.
f) Right to portability
You have the right to request and receive your personal data in a format that allows you to access, use and process them by commonly used processing methods. In addition, for your data that we process by automated means and on the basis of your consent or for the performance of a contract, you may request us to transfer them directly to another controller, if this is technically feasible.
g) Right to withdraw consent
If the processing of your data is based on your consent, you have the right to withdraw it at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal.
To exercise the above rights and for any query, complaint or other information regarding the processing of your
personal data, you can contact us at email@example.com.
9. RIGHTS OF COMPLAINT TO THE PERSONAL DATA PROTECTION AUTHORITY (PDPA)
You have the right to lodge a complaint with the Personal Data Protection Authority (www.dpa.gr) on issues relating to the processing of your personal data.