Information notice regarding the processing of personal data within the framework of participating in a product placement promotional activity of the Organizer BARBA STATHIS S.A in television broadcasts.
1. The implementation and performance of promotional activities in television broadcasts necessitates and requires the processing, on behalf of the Organizer and the relevant television station, of personal data records of natural persons (Data Subjects) who legally participate in them, containing the information required for their participation (Personal Data). The processed personal data on behalf of the Organizer and the television stations are limited to the minimum required (and for the minimum required time), also based on the purposes they aim to serve during and after the promotional activity. Additionally, the relevant television stations and the Organizer have implemented the necessary technical and organizational measures to preserve the confidentiality, availability and integrity of the participating viewers’ personal data. Personal Data is processed by the Organizer and the relevant television station as they are provided by the participants through the television station's call centre, which conducts the promotional activity's draw exclusively for the needs of organizing, conducting and implementing the promotional activity in general. Such needs include the selection of the participants, the conduct of the draw for the winners, any evaluation of the promotional activity, the announcement of the results, as well as the delivery/collection of prizes (based on the database of the winners’ names, phones and addresses, sent by the television station to the Organizer) and the potential use of snapshots (photos/videos) for promotional purposes of the promotional activities etc., all conducted within the framework of the purposes outlined herein and under all applicable legislation in force. Furthermore, the Organizer and television station can, on a case-by-case basis and for the completion and fulfilment of the promotional activity, share the personal data to third-party associates and representatives for the delivery of the prizes, under the condition that the Organizer and the television station have further committed the aforementioned third parties to strict personal data protection terms, for the data disclosed to them and processed in the framework of the promotional activity, so as to communicate with the Winners of the promotional activity, to deliver and procure the collection of the prizes, and potentially to “promote” the respective promotional activity, by announcing the results, the name/usernames of the winner(s) through their websites, social media pages or otherwise, as stated below under 2, with the explicit reservation that they will be provided only for specific use, purposes and duration. Following the completion of the current promotional activity, the Organizer, television station and third parties, acting as agents of the first two, are obliged to remove or otherwise destroy the personal data, which was processed within the framework of the promotional activity for the aforementioned purposes.
2./ The Organizer reserves the right to announce, on a case-by-case basis, the name and surname and/or username (in the case where the current promotional activity is being conducted via social media) of the winners and potential runner-ups on the website or potential Organizer smart device application, and/or on the Organizer’s social media pages. Furthermore, using the aforementioned measures, the Organizer can also engage in any type of promotional use of the relevant items of the promotional activity and prizes, such as, for instance, photographs/videos during prize collection by the winner. Through their participation in the promotional activity, all participants explicitly consent to the use of any display materials (shaded videos, images, photographs etc.) as described above, which may be created during and due to the promotional activity or during the collection of their prize. All above personal data (shaded videos, images, photographs) are subject to immediate erasure/destruction from whatever media they have been recorded in following the end of the promotional activity and the purpose for which they were recorded within its framework. It is understood that the respective winner will not have the right to any monetary or other reward or compensation of any nature for the aforementioned reasons. Any refusal to the above entitles the Organizer to deny the award of the relevant prize to the winner.
3./ Participation in the promotional activity requires and recommends the free, unreserved and explicit declaration, approval and consent of each participant (over 18 years of age) or any legal guardian (in the case where the participant is under-age), for the processing of personal data mentioned herein above, the record-keeping for the aforementioned purposes and for the term specified herein, and the acceptance of the terms specified in this notice regarding the processing of their personal data. The breach of the aforementioned obligation on part of a participant and, more specifically, the registration of an under-age participant in the promotional activity without the consent of their legal guardian exercising parental responsibility, renders their participation null and void. In this case, the Organizer and the television station, reserving all their rights, will not take the specific participation into account and will immediately erase the information of the said participant, without assuming any compensatory or other liability towards them and any third party, in accordance with legislation on personal data. The claim, acceptance and collection of prizes from the Competition winners constitute full, unreserved and explicit consent on their part for, on a case-by-case basis, the use of their name (or username or other information), their image (as per above) with the sole purpose of publishing the promotional activity and its results, as well as for the use and processing of the necessary personal data on a case-by-case basis for the purposes of the promotional activity, as mentioned herein.
4./ Each participant (or any legal guardian if the participant is under-age) guarantees to provide truthful, accurate, up-to-date and complete information for themselves during their participation, through the television station's call centre or otherwise, as well as consent to their participation (theirs and/or the individual they are legally responsible for) in the promotional activity. The Organizer has no liability if the participant uses or fabricates untrue, inaccurate, outdated or misleading information. For any potential failure to communicate with the participant or non-delivery of a prize, the participant is solely responsible.
5./ The Organizer and the television station will retain the aforementioned personal data from the participants in hard copy and/or digital form for one (1) month following the end of the promotional activity and the draw of the winners, with the sole purpose of properly and appropriately completing the activity and distributing the prizes to winners and runner-ups. Thereafter, the data will be permanently destroyed/erased.
6./ The Organizer and the television station maintain the right to modify, recall, extend or shorten the duration of the promotional activity or to modify the terms, participation dates or prizes thereof at their discretion (or even cancel the activity altogether) without any prior notice, notifying the participants by all appropriate means and not bearing any further responsibility toward the participants or any third parties in relation to the provisions hereof or any other reason. Each participant understands and accepts that (unless otherwise decided on a case-by-case basis by the Organizer) by participating in the promotional activity, if not determined to be a winner, they will not receive a prize, financial or other compensation, or any other form of reward or reimbursement in sole relation to their participation and/or the processing and collection of their personal data pursuant to this notice
7./ Any participant can, at any time, exercise the rights provided for by Regulation (EU) 2016/679 and Law 4624/2019, including the right to information and access, rectification, erasure (“right to be forgotten”), restriction of processing, objection to processing, as well as the right to seek human intervention. These rights shall be exercised by sending the relevant request to the Organizer's or television station’s address. In the latter case, the television station should immediately inform the Organizer. Requests shall be submitted free or charge, unless a request is unfounded or excessive, especially if deemed unnecessarily repetitive, in which case the request will be satisfied upon condition of a reasonable administrative fee being provided. If a participant exercises one of these rights, the Organizer will take every possible action and care to satisfy the request within thirty (30) days from receipt of said request, provided it is feasible. Otherwise, it will inform the Data Subject on extending the request’s satisfaction term for up to two (2) months, having previously informed the Subject on whether their request will be satisfied or such satisfaction is not possible, stating the reasons that potentially obstruct said request's satisfaction. In addition, each participant maintains the right to address the Hellenic Data Protection Authority, which can also accept the submission of relevant complaints, either in written form at its secretariat through its address (Kifissias Ave. 1-3, Athens, PC 115 23), or digitally, through it's website (www.dpa.gr).