Genaral Data Protection Regulation- GDPR

Last update: 25th May 2018

Welcome to the Website of “Alternative Administration of Waste Lubricating Oils”.

Our Company takes into serious consideration the privacy of our costumers. For this reason, we pursue with severity the following protection policy, which ensures the high level of products and services offered and complies strictly with the current legislative framework.

With this Privacy Statement we want to let you know how our Business protects the privacy of your communications and collects, processes, uses and stores your personal data through our website as well as the options and rights that you have with regard to the above collection and processing of your personal data. By visiting our Site you acknowledge and accept the data protection policy that follows.

This Privacy Policy only applies to the website Users must bear in mind that our Site may also contain links to other sites,although our business is not responsible for the practices and terms of data protection or the content of such websites.


1.1. This Policy defines the terms and conditions that are maintained by our Company to protect the privacy of the Users of the Website. This policy includes the rules on the basis of which we collect and process your personal data and ensures that this information is kept confidential.

1.2. Our Business reserves the right to modify and update this policy whenever it is deemed necessary. These changes will take effect from their public appearance on the Site.

1.3. If any of these terms are considered invalid, illegal or abusive for any reason, the other terms will remain valid and strong as they are to the extent that they do not contradict the will expressed in this policy.


We fully respect your fundamental rights and consider the protection of your privacy a priority for our Company. In this context, during the processing of your personal data, we follow the basic principles below:

2.1. We legitimately and fairly process your personal data and maintain full transparency about the way we manage them.

2.2. We collect and process your data only for specified, explicit, and legitimate purposes as outlined in this policy and we do not process them further in a way that is incompatible with those purposes.

2.3. We process your personal data only to the extent they are appropriate and relevant to the above purposes, while limiting the processing to the extent necessary for these purposes.

2.4. We make reasonable efforts along with your assistance to ensure that your processed data are accurate and, where necessary, up-to-date with the purposes of the processing, taking all reasonable steps to immediately delete or correct them in case of inaccuracy.

2.5. We hold your personal data in a form that allows for your identification only for the time required for the above processing purposes.

2.6. We process your personal data in a way that guarantees their security by using appropriate technical or organizational means.

2.7. We do not intend to further process your personal data for a different purpose of which they were collected.

2.8. We inform you that there is no obligation to provide your personal data and there are no possible consequences of not providing them in case of non-registration. Furthermore, we hereby notify you that your personal data will not be used for automated decision-making including the profile creation.

2.9. Subject to what is stated in this policy, we do not disclose or transmit your personal data to third parties without your consent unless permitted by law or by our agreement.

2.10. Please be advised that we do not pass on your personal data to a third country or international organization for which there is no European Commission decision under the GDPR.

2.11. In general, as the lawful person responsible for processing your personal data we abide by the applicable law and comply with all of our obligations arising out of this.


3.1. The types of personal data that we collect and process from you, depend on the services that you choose to acquire. When (a) entering and using the Site, (b) subscribing our newsletter, (c) creating your personal account and (d) acquiring products, website users grant to our Company the following types of personal data.

3.2. When entering and using the site, website users grant to our Company the following personal data:

• Internet Protocol Address (IP Address)
• Site Navigation Data.
• Product Preference Information.
• Performed Transactions.
• User Generated Content.
• Types of operating systems/ screen width.

3.3. When subscribing our newsletter website users grant to our Company the following personal data:
• E-mail address

3.4. When creating your personal account as a Waste Lubricating Oils Exploiter, website users grant to our Company the following personal data:
• Brand Name
• Registered Business Name
• Full Address
• VAT Registration Number/ Tax Office
• Legal Representative
• Contact Official
• Contact Details (E-mail, Phone Number)
• Plant Operating License
• ISO Certificate 14001/EMAS

3.5. When creating your personal account as a Waste Lubricating Oils Collector, website users grant to our Company the following personal data:
• Brand Name
• Registered Business Name
• Full Address
• VAT Registration Number/ Tax Office
• Legal Representative
• Contact Official
• Contact Details (E-mail, Phone Number)
• Collection and Distribution of Waste Lubricating Oils License
• License Type
• Vehicle Registrations
• Active Civil Liability Insurance Contract

3.6. When creating your personal account as an Obliged Administrator, website users grant to our Company the following personal data:
• Brand Name
• Registered Business Name
• Full Address
• VAT Registration Number/ Tax Office
• Legal Representative
• Contact Official
• Contact Details (E-mail, Phone Number)
• Type of activity in the field of Waste Lubricating Oils

3.7. When submitting a communication form website users grant to our Company the following personal data:
• Full name
• Email.
• Phone number
• Message
Additionally, if any user communicates with us via email or other ways, we will collect personal data relating to such communications under the terms and conditions thereof in order to meet the relevant requirements and requests and improve our provided services.

3.8. When using our website, users grant to our Company the following personal data:
• User or Business User-generated content.

3.9. Additionally, if any user communicates with us via email or other ways, we will collect personal data relating to such communications under the terms and conditions hereof in order to meet the relevant requirements and requests and to improve our provided services. (4.7)

3.10. Our Company does not collect or access in any way to sensitive customer data or data related to criminal convictions or legal offenses of our users- clients. You are obliged to abstain from posting this type of data about you or third parts data If any user uploads sensitive data to our Site, such sensitive data will be removed as soon as we become aware of it. We do not bear any responsibility, in case you or any other third part post or/and process sensitive data which resulted from acts or oversights in violation of the obligation above.


4.1. Your personal data, which is necessary for the navigation and use of our site pursuant to Article 6 § 1 (b) of the GDPR, are collected and processed by our Company for the following purposes:
• Technical capacity for the uninterrupted operation of our Website.
• User-friendly operation of our website.
• Improvement of your on-line experience while navigating and using our website.
• Recording consumer habits through the use of anonymous statistical data.
• Submission of our newsletter to our subscribers.• Registration to EN.DI.A.L.E. S.A. or companies relevant to Lubricating Oils and their recycle.

4.2. Your personal data, which are necessary for the provision of our products and services within our contractual relationship under Article 6 § 1 (b) of the GDPR, are collected and processed by our Company for the following purposes:
• Implementation of the contractual obligations of our Company towards the users of our Website.
• Immediate, adequate and efficient delivery of our products and services.
• Use for tax purposes and use for invoicing and proof of delivery of ordered products.
• Communicating with our customers in the framework of good execution of our commitments, as well as to resolve any complaints.
• Improvement and renewal of our products in order to meet the needs of our customers as much as possible.
• Administrative organization and operation of our Business.
• Management of our customer base.
• Updating and extension of the company register.
• Support for legal claims.

4.3. Our Business collects and processes personal data of its users/customers only for the above mentioned purposes and only to the extent strictly necessary for the effective service of these purposes. This data are always relevant and not more than absolutely necessary for the purposes set out above and are accurate, and where appropriate, subject to updating. Furthermore, such data shall only be retained during the period necessary to carry out the collection and processing purposes and 20 years after the end of that period and will be subject to any law that provide the right to keep this data for a longer period.


5.1. Our Business may process personal data only with the legal consent of the users of the Site for the following purposes:
• For commercial communication, marketing and advertising of our products via sms, telephone, e-mail, internet, fax, mail social media and / or any other appropriate communication channels.
• For research and/or analysis purposes to better understand your needs, preferences, interests, experiences and/or habits as a consumer.
• For the operation and management of any rewards programs that may be available via the Website.
• For the publication of any type of catalog relevant to collection, recycling and regeneration of Lubricating Oils.

5.2. You freely give us your consent for the processing of your personal data for the above purposes with an electronic statement in a manner clearly distinct from other matters in a comprehensible and easily accessible form. Your consent is given freely and your personal data are provided but you are not obliged to do so in order to enter a contract with us.

5.3. In this context, by ticking the appropriate field on-line, you explicitly state that you wish and that you provide your consent for the above purposes in accordance with the terms and conditions of this policy. You provide your consent above in the following ways:
• By subscribing our newsletter.
• By creating your personal or business account.
• By completing the relevant product order form and by drawing up contracts through our website.

5.4. You have the right to withdraw your consent at any time. Withdrawal of consent does not affect the legality of consent-based processing prior to its revocation. Your consent is revoked in the same way it is provided.


6.1. Our Business does not grant your personal data or connect its files for financial or other gain with any third-party private companies, legal persons, public authorities, agencies or other organizations.

6.2. In order to serve the processing purposes referred to this policy, our Company may provide access to or transmit the following types of personal data to the following processors by order and on behalf of it:
• Your financial data to the credit institution with which we co-operate to process payments to and from your bank accounts and credit card accounts for the purpose of repaying your debts to the Company.
• Your personal and communication details in order to inform the public and all the interested authorities.
• Your Personal Data to the provider of web hosting services with which we maintain a contractual relationship with the purpose of hosting them on this website.
• Your personal data to the company which provides us with maintenance and support services for software and database programs needed to support the site.
• Preference data and contact information to third-party marketing and advertising companies for the commercial communication, marketing and advertising of our products.
• Your personal data to third-party consultants to provide data analysis services.
• Your financial and contact details to debtor briefing companies in the event of overdue debt towards our Company and after we provide you with prior notice.
• Your personal data to auditors, accountants, financial or professional consultants as well as investors in the context of transfer in part or in whole, merger, secession of a branch or other total succession, liquidation or bankruptcy of our business.

6.3. The processing of your personal data by the above cooperating entities is conducted under our control and only at our command and we ask that the same data protection policy or policy of at least the same level of protection be maintained by them.

6.4. If ordered by a court or other administrative authority and in any other case that is legally bound to do so, our Company may transfer your personal data to the extent specified by law but after you have been informed.


7.1. In order to ensure the proper use and integrity of the collected personal data, as well as prevent unauthorized or random access, processing, deletion, distortion or other use thereof, our company implements different internal policies, while adopting all the necessary organization, technical, physical, electronic and procedural safety measures, as well as technological standards in accordance with the applicable Laws and Regulations.

7.2. The processing of your data by our Company is conducted in a manner that ensures their confidentiality and physical and logical security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for your rights and freedoms.

7.3. Your personal data is processed solely by authorized personnel of our Company, bound by strict obligations of confidentiality.


8.1. We keep your personal data for as long as it is each time necessary for the relevant purposes of their processing and are listed above.

8.2. Our Company may retain your personal data after the expiration of their relevant processing purposes in the following limited cases:
• In case that there is a legal obligation under a relevant statutory provision.
• For reasons of tax and social security audit reasons within the statutory limitation period.
• For the proper organization and operation of our business provided that anonymity or pseudonymization of your data takes place.
• In case of any claims against our Company, for as long as necessary to defend our rights and legitimate interests before any competent court and any other public authority.

8.3. After the period of retention, your personal data is erased from our databases and systems in accordance with our data protection policies and provided that their retention is no longer required for the fulfillment of the purposes we have described above.


9.1. Without prejudice to applicable law and subject to any limitations thereof, you have the following rights :
• Request for access to your personal data and information related to their processing and obtain a copy thereof.
• Request for the rectification of any inaccuracies or any missing personal data of yours.
• Request for the erasure of your personal data.
• Request for the restriction of the processing of your personal data in cases explicitly provided for by law.
• Request for the portability of your personal data to another controller in a structured, commonly used and machine-readable format (ex. cd).
• Object to the processing of your personal data in cases explicitly provided for by law.
• Object to a decision taken solely on the basis of automated processing, including profiling, which has impact on you or significantly affects you. Any requests relevant to the above are addressed in writing to our contact details mentioned in this Notice.

9.2. Our Company will respond to any of your requests within one month from their receipt. Upon prior notice, this period may be extended by a further two months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of your request, we will provide relevant justification.

9.3. If your request does not meet the requirements of applicable law, our Company reserves the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject your request.

9.4. In the event of any violation of your personal data, which may place your rights and freedoms at a high risk, and provided that it does not fall under one of the exceptions expressly provided for by applicable law, we undertake to inform you without undue delay.

9.5. If there are any doubts as to the identity of the individual submitting the request, we reserve the right to request the provision of additional information necessary to confirm his identity.

9.6. If your rights are infringed, we inform you that you have the right to file a complaint with the Greek Data Protection Authority or with any other competent supervisory authority.


10.1. By using our Website and by providing your personal data upon your consent, you acknowledge that you are required to state your actual, accurate and complete information requested by our Company. Furthermore, you must inform our Company of any changes to your information so as to ensure it is kept up-to-date and accurate.

10.2. If found that you do not abide by your obligations or if our company suspects that the information you have provided us with are false or incomplete or by any means it violates the laws or our privacy policy, we keep the right to reject your application for subscription, or suspend, or immediately terminate your account without notice. In that case, you have no right for compensation due to the rejection of your application, or the position of your account in suspension, or termination.

10.3. You acknowledge that our Company may delete, cross-check, supplement or modify the information you provide based on information lawfully provided by third parties. In this case, our Company will provide you with relevant notice in compliance with applicable law.

10.4. By using our Website you confirm that you are over sixteen (16) years old. If you are under the age of sixteen (16) you have the obligation to abstain from any use of our Website and from any transfer of your personal data without the consent of the person who exercises your parental responsibility. If you fail to comply with the foregoing obligations, you must immediately notify our Company. In any case, using the Site, you acknowledge that our Company is not responsible for your violation of the obligations mentioned above to the extent that it is unable, even if it makes reasonable efforts, to verify your age or to receive consent from your guardian.


11.1. Our website uses cookies.


12.1. Any dispute between you and our Company arising from or in relation to the subject matter of this Privacy Notice shall be governed and construed in accordance with Greek law without reference to its conflict of laws principles and shall be subjected to the exclusive jurisdiction of the competent courts of Athens, Greece.

12.2. If a provision of the present Privacy Notice is canceled by a decision of a competent court as unlawful, invalid or unenforceable, this will not affect the validity and enforceability rest of its provisions, which will remain in full force and will be accordingly applied.


13.1. For any request in relation to the protection of your personal data you may contact our Data Protection Officer as follows:
• Irodou Attikou Street 12Α
• P.C. 151 24, Marousi
• Greece
• email: [email protected]