Email Marketing Personal Data Protection Policy (fastroad.gr)

INTRODUCTION

Υuboto Ltd. (hereinafter “YUBOTO”), acting as Data Controller, processes the data required for you to acquire and use the Services it provides, for your navigation on its Website, and for the purposes described in detail in this Policy.

With full commitment to legality and transparency, YUBOTO manages all personal data communicated to it with absolute respect, limiting processing activities to the minimum necessary and solely for the fulfillment of their intended purposes.

CONTACT DETAILS
Yuboto Ltd.
Katsantoni & Olympias 2
14452 – Metamorfosi, Greece
Tel.: (+30) 211 114 4111
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
For any clarification or request regarding Personal Data, a Data Protection Officer (DPO) has been appointed and may be contacted directly at: This email address is being protected from spambots. You need JavaScript enabled to view it.

PURPOSE OF PROCESSING

The purpose of data processing is the proper provision of services in accordance with applicable legislation, customer support throughout our contractual relationship, and promotional activities within the scope of our relationship, provided that you have given your consent. This purpose includes, indicatively:

• Provision of the acquired Service
• Provision of Technical Support and Customer Service
• Provision of Billing and Notification services
• Handling of Access Requests and Complaints
• Provision of Information, Balance, Payment, and Settlement services
• Compliance with regulatory requirements, including legislation on the confidentiality of communications and crime investigation in response to requests from public authorities
• Protection of YUBOTO’s legitimate interests and operations, confidentiality, security, and effective handling of arising issues

For direct marketing purposes, subject to your consent, YUBOTO may carry out decision-making or profiling based on automated data processing.

The legal basis for data processing consists of the terms of the contractual relationship, whether described in a written agreement or in the Service Terms of Use, the regulatory framework governing telecommunications legislation, and your consent where required.

CATEGORIES OF DATA

For the above purposes, YUBOTO may collect and process the following categories of data:

• User Identification Data: First name, Last name
• Unique User Identifiers: Tax Identification Number (VAT)
• Billing Information: Name/Company name, Billing address, Bank account
• User Contact Details: Telephone number, Email address
• User-generated Data: Email addresses of final recipients, Sending history, Campaign statistics
• Browsing Identification Data: IP address, Cookies
• Usage-generated Data: Communication data, End-user/recipient actions

DATA RECIPIENTS

Data recipients may include the following categories:

• YUBOTO and its personnel, within the scope of their duties
• Authorized representatives and/or subcontractors of YUBOTO for the purposes of support, promotion, and execution of the contract
• Competent Public Authorities, including indicatively the Hellenic Telecommunications and Post Commission, the Hellenic Authority for Communication Security and Privacy, and Judicial Authorities

YUBOTO’s partners have contractually and in writing committed to:

• Maintaining confidentiality, as well as ensuring their employees do so, regarding any personal data they may become aware of
• Not transferring data to third parties without YUBOTO’s written authorization
• Implementing organizational and technical security measures to protect the logical and physical security of data
• Designing their systems in such a way that, by design and by default, they are able to comply with these obligations
• Immediately notifying YUBOTO of any personal data breach concerning the CUSTOMER and complying with the applicable legal framework, in particular the General Data Protection Regulation (GDPR), in their capacity as Data Processors

DATA RETENTION / DELETION

YUBOTO retains data in physical and/or electronic form for the entire duration of the contractual relationship.

Data relating to inactive contracts are retained for the necessary period for settlement purposes: 14 months after the termination of telecommunications contracts, 2 years for other services, unless legislation requires longer retention (e.g. tax legislation) or until the final settlement of pending matters. Thereafter, data are permanently deleted without any possibility of recovery.

TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES

YUBOTO has implemented appropriate organizational and technical measures to ensure the security and protection of your data, in accordance with its Information, Communications, and Personal Data Security Policy and the regulatory framework of the Hellenic Authority for Communication Security and Privacy (ADAE).

Furthermore, YUBOTO is certified under ISO 27001:2013 and ISO 9001:2015 for quality assurance in service provision. Data processing of any kind is permitted only to authorized persons, employees, and partners, exclusively for the purposes stated above.

These measures are reviewed and updated whenever deemed necessary.

CUSTOMER RIGHTS

The CUSTOMER has the right to be informed, at the time of data collection, about the identity of YUBOTO, the purposes of processing, the data recipients, and any third parties to whom data may be transferred.

The CUSTOMER has the right of full access to their data, including the right to know whether and how their data are processed. The CUSTOMER may submit written or electronic requests and has the right to: rectification of inaccurate personal data, erasure of data (where they are no longer necessary for the stated purposes or upon withdrawal of consent, where applicable), data portability in a machine-readable format, restriction of processing (while objections are under examination), withdrawal of consent and objection to processing,

In the event of an objection, YUBOTO shall cease processing unless there are compelling and legitimate grounds overriding the CUSTOMER’s rights or where processing is no longer necessary for the stated purposes.

Requests are answered free of charge, without undue delay, and in any case within one (1) month of receipt. Where requests are complex or numerous, this period may be extended by two (2) additional months, with prior notification. Where requests are manifestly unfounded or excessive, particularly due to their repetitive nature, YUBOTO may charge a reasonable fee reflecting administrative costs or refuse to act on the request, providing justification.

AMENDMENT OF THE PERSONAL DATA PROTECTION POLICY

YUBOTO reserves the right to amend this Personal Data Protection Policy and will notify users by any appropriate means.

REQUESTS – INQUIRIES – COMPLAINTS

For any request or exercise of rights related to personal data, as well as for specialized information, the CUSTOMER may contact: This email address is being protected from spambots. You need JavaScript enabled to view it.

The CUSTOMER has the right to lodge a complaint with the Hellenic Data Protection Authority (Kifisias 1–3, 115 23 Athens, Greece, Tel: +30 210 6475600, Email: This email address is being protected from spambots. You need JavaScript enabled to view it.) if they consider that the processing of their personal data violates applicable national or regulatory data protection law.

This Policy entered into force on 24/05/2018 and was last updated on 31/10/2024.