PERSONAL DATA PROTECTION AND COOKIE USE POLICY

1. GENERAL
1. This Personal Data Protection and Cookie Use Policy describes the types of personal information we collect about users of this website, how we use this information, with whom we may share it, and the rights of users regarding how we use such information. It also provides further information to users regarding the measures we take to protect the security of this information, the duration for which we retain it, and how users can contact us directly with questions about our practices concerning the handling of their personal information.

2. This Personal Data Protection and Cookie Use Policy applies solely to the site www.aperolmadetoshare.gr (hereinafter referred to as the “site” or “website”). Please note that the website may contain links to other websites. The Company is not responsible for the personal data protection practices of other websites, and we recommend that you always read the personal data protection policy of each website you visit.

3. By using our Website in accordance with the Terms and Conditions of Use of this site, you consent to this Personal Data Protection Policy.

2. DATA CONTROLLER

The data controller for the processing of your personal data for the purposes of operating this site is the société anonyme under the name “CHAPTER FIVE Société Anonyme,” with the distinctive title “CHAPTER FIVE S.A.,” headquartered in Athens, Syngrou Avenue and Aftokratoros Nikolaou No. 128, VAT number 099899571, Tax Office: K.E.FO.D.E. Attikis, and G.E.MI. number 004653701000 (telephone: 210 9525255, contact email: dataprotectionreport@chapter5.gr), hereinafter referred to as “the Company.”
Data Protection Officer (DPO): Ioannis Kagkelaris

3. DATA COLLECTED BY THE COMPANY
1. During your visit to the website www.aperolmadetoshare.gr, no registration, account creation, or submission of your personal information is required. During your visit, the following information may be collected anonymously through QR/RFID technology embedded in the wristbands of participants:
 Anonymous unique wristband code
 Date and time of QR scan
 Event code (location and time period)
 Whether the user is a “repeat visitor”

2. During your navigation on the website, technical data such as IP address, device type, and browser are automatically collected, exclusively for statistical and technical purposes (as further explained in the section on cookies below). No personal data that would allow your direct identification is recorded or stored.

4. PURPOSE OF PROCESSING OF DATA COLLECTED BY THE COMPANY
1. The Company collects and processes only technical data during your browsing of the website www.aperolmadetoshare.gr, which are necessary for the technical operation of the website and for the statistical analysis of user participation in the physical Events. No commercial transaction, recording of your personal data, or sending of products takes place.

2. The limited processing of your technical data (such as IP or cookies) is carried out exclusively for operational and statistical purposes, by personnel of the Company who are bound by confidentiality obligations and apply appropriate security measures.

3. No personal data, such as name, address, or contact details, are collected or stored, nor is there any sending of products or communication with users. Access is anonymous, with no data entry required.

4. No personal data are disclosed to third parties, as no such data are collected or stored through the site.

5. In the event that the Company proceeds in the future with the collection of personal data, this will be done only with clear notice and the explicit consent of the user, as provided by law.

5. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
1. The Company applies the Principles of Processing under the General Data Protection Regulation (GDPR) 2016/679 and relevant EU Directives. The Company fully complies with the requirements of the applicable Greek legislation on the protection of personal data as in force today. The Company protects and safeguards all your rights concerning the use of your personal data, as set out in the following terms of this Policy.
2. The legal basis for the collection and processing of the data is your explicit consent to this Data Protection Policy, for the above-described purposes of processing. Your consent may be withdrawn at any time by expressing your intention to the Company in accordance with the present terms.

3. The legal basis for the limited processing of technical data that may be collected (e.g., through cookies) is as follows:
(a) your consent upon accepting cookies when entering the website.
(b) the reasonable expectation of technical necessity for the proper functioning of the website, without the storage of identifying personal data.
(c) the anonymous collection, during your visit, of the following information via QR/RFID technology embedded in participants’ wristbands:
 Anonymous unique wristband code
 Date and time of the QR scan
 Event code (location and time period)
 Whether the visitor is a “repeat visitor”

No identifying personal data (such as name, email, or address) is collected, recorded, or processed, and no commercial transactions or product deliveries are conducted through the website.

6. WITH WHOM WE SHARE YOUR PERSONAL DATA
1. The Company does not collect or store personal data that identify the users of this website. Therefore, no personal information is transferred to third parties.

2. Technical data that may be recorded through cookies (e.g., IP address, browser type, time of visit) are used exclusively for the optimization of user experience and the operation of the website. The Company may cooperate with technical service providers (e.g., server hosting or analytics), who are legally bound to comply with European Union and national regulations on the protection of personal data.

3. The Company does not transfer data outside the EEA, as no identifiable information is collected or stored.

4. No disclosure of information to authorities or third parties is foreseen, as no personal data are recorded.

5. In any case, the hosting and management of the website are carried out with technical and organizational security measures that ensure the protection of browsing technical data.

7. RETENTION PERIOD OF DATA
1. The Company does not collect identifiable personal data, nor does it create user accounts. Any information that may be temporarily recorded is stored only for as long as necessary for the production and display of the relevant material and is automatically deleted within five (5) days.

2. No transactional data or consent data are retained, as the use of the platform does not require registration or storage of information. No information is stored beyond the technically necessary duration and is not linked to the user’s identity.

8. RIGHTS OF THE DATA SUBJECT

1. Every user of our website has the right to be informed about the processing of their personal data by contacting the Company at the telephone number: 210 9525255, or via email at the contact address: info@chapter5.gr, as well as the Data Protection Officer directly at the email address: dataprotectionreport@chapter5.gr.

2. Every user, as a data subject, may exercise their rights at any time, as provided under the General Data Protection Regulation (GDPR) 679/2016 EU and in particular Articles 15–23 thereof, as well as under national legislation, and specifically the right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability, the right to object, and the right to human intervention in automated individual decision-making, as such rights may be exercised, as applicable, within the framework of the operation of this website.

3. In the event that the user exercises any of the aforementioned rights, the Company shall take all reasonable measures to satisfy the request within five (5) days at the latest from its submission.

4. The exercise of any of the user’s rights may take place:
• By submitting a relevant request to the Company at the email address info@chapter5.gr
• By contacting the Data Protection Officer (DPO) at the email address dataprotectionreport@chapter5.gr

9. GUARANTEED SECURITY OF YOUR PERSONAL DATA

1. The data necessarily collected under the terms of this Policy is protected by technical and organizational methods that comply with Greek and European legislation, ensuring its security and confidentiality.

2. The Company obtains written commitments from its partners to guarantee and implement adequate security measures that ensure the protection of the personal data entrusted to them for processing, in accordance with the legal requirements for personal data protection.

3. However, no security system is perfect, and we cannot promise that information about you will remain secure under all circumstances, including the security of your data during its transmission to us or the security of data on your mobile device.

11. USE OF COOKIES

1. This website uses cookies. We use cookies on our website to ensure that it is functional and operates more efficiently, to improve your browsing experience, to provide you with the website’s full capabilities, to ensure the correct display of content, and to understand how you interact with us.

2. Cookies are data files that are transferred from a web server to the device (computer, mobile phone, tablet) of the person visiting the website, for the purpose of maintaining statistical records. Cookies constitute an industry standard, are used by most websites, and facilitate users’ repeated access to and use of a specific website. Cookies are not harmful to the system of the access device you are using or to your files, and only the website from which a specific cookie was transferred to the device has the ability to read, modify, or delete it.

3. The cookies used by the website are the following:

Necessary – Technical Cookies: These cookies allow you to browse and use the functions of the website. These cookies do not recognize your individual identity and, without them, the smooth operation of the website is not possible.
Traffic Measurement Cookies: These cookies allow us to obtain visitor statistics, compare them with other websites, and make decisions regarding actions.

Functionality Cookies: Functionality cookies allow the website to remember your choices in order to provide enhanced and personalized features. If you reject these cookies, the performance and functionality of our website may be affected, and your access to its content may be limited.

4. When you visit our website for the first time and the Company intends to place cookies other than the strictly necessary – technical cookies, we inform you about the use of cookies through an informational banner at the top of the page. By continuing to browse the website when this banner is displayed, you consent to the use of these cookies.

5. Cookies are installed only if you accept their installation upon visiting our website. By accepting cookies upon entering our website, you expressly declare that you have read and understood the specific conditions and terms regarding the installation, operation, and purpose served by the cookies, and you provide your consent to their use. Alternatively, you may choose not to accept cookies. In such case, only those cookies that are strictly technical and functionally necessary for the operation of the website will be installed.

6. The information stored in the cookies of our website is used exclusively by the Company’s site as well as by partner companies such as Google, for statistical purposes.

12. USE OF HYPERLINKS
The Company’s website may provide links to other websites for your convenience and information. These websites are beyond the influence and control of the Company. Linked pages may have their own privacy statements or policies, which we recommend you read if you visit any of the linked websites. The Company bears no responsibility for the content of these hyperlinks or for the personal data protection practices of the pages to which they refer.

13. AMENDMENT OF THE TERMS HEREIN
The Company reserves the right to modify the terms of this Privacy and Cookie Policy at any time, without prior notice to you. In such cases, the Company will post a clear notice on the website to inform you of any significant changes to the Privacy and Cookie Policy.

14. DISPUTES
This Privacy and Cookie Policy, along with any amendments thereto, as well as the use of the website, are governed by Greek Law. Any dispute that may arise from this Policy shall be subject to the exclusive jurisdiction of the competent courts of Athens.
If you have any questions regarding this Privacy and Cookie Policy, please email us at: info@chapter5.gr