Privacy Policy

Last updated on 29/08/2022

Welcome to intralot.com

žžƵ and its Group of Companies (hereinafter referred to as “žžƵ”) take seriously into account the privacy of their clients and Users (as defined hereunder). This Privacy Notice is to let you know how companies within the žžƵ Group protect the privacy of your communications and collect, process, use and store your personal data through our Website (as defined hereunder), as well as the rights you have with regard to the foregoing collection and processing of your personal data. By visiting our Website and using our services you acknowledge of having read and fully taken into account this Privacy Notice.

This Privacy Notice applies only to our Website under the top level domain intralot.com.
Users should be aware that our Website may also contain links to other websites, yet our Company cannot be held responsible for the data processing practices or the content of such websites.

1. Who We Are
1.1. The žžƵ Group of Companies consist of many different legal entities. We will let you know which you have a relationship with when you take out a product or service with us.
1.2. For any further request or query about how we use your personal information, you may address us by using the following contact data of our Data Protection Officer.
Address: 19 km, Markopoulou Ave., 19 002 Peania - Attica, Greece.
[T]: +302130398050
[E]: dpo@intralot.com.
1.3. Any notice, demand, request, or other communication which you address to žžƵ shall either be sent by certified mail, return receipt requested, or by email. All notices given by e-mail shall be deemed given as of the business day following the day of transmission.

2. Definitions
For the purposes of this Privacy Notice the following definitions shall apply:
2.1. “Cookie” - short text of software code, which is transmitted from the web server of our Company and stored at your device each time that you enter the Website. “Personal Data” - Any information relating to an identified or identifiable user of intralot.com.
2.2. “GDPR” - the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time and as transposed into member-state legislation.
2.3. “Personal Data” - any information which relates to a User, who can be identified directly or indirectly.
2.4. “Processing” - Any operation or set of operations which is performed by žžƵ upon the personal data of the users of intralot.com, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;
2.5. “Website” – The worldwide web website which is accessible through the domain name intralot.com including all of its webpages.
2.6. “Consent” - Any explicit, specific, and freely given indication of intent by which the User, after having been thoroughly informed, expresses his/her agreement to the processing of personal data relating to him/her.
2.7. “User” – Any internet user who accesses and browses at intralot.com

3. Subject Matter
3.1. The present Notice sets out the terms and conditions followed by žžƵ in order to protect the privacy of its clients and/or Users. It describes the conditions under which we make any collection and processing of your personal data and ensure their confidentiality (“Privacy Notice”).
3.2. žžƵ reserves the right to amend and update this Privacy Notice, whenever it deems it appropriate, and any changes thereof shall come in force and effect from the instance they appear online at the present webpage of intralot.com

4. Principles of Data Processing
We fully respect your fundamental rights and render protection of your privacy a priority of žžƵ. In this context, when processing your personal data, we follow the following basic principles:
4.1. We submit your personal data to lawful and fair processing, and we maintain full transparency vis-à-vis the way we handle your personal data.
4.2. We collect and process your data only for specified, explicit, and legitimate purposes as outlined in this policy, and we do not process it further in a manner incompatible with these purposes.
4.3. We process your personal data only to the extent that it is appropriate and relevant to the above purposes, while limiting the processing to the measure necessary for these purposes.
4.4. We make reasonable efforts with your own assistance to ensure that your processed data are accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.
4.5. We keep your personal data in a form that allows you to identify yourself only for the time required for the above processing purposes.
4.6. We process your personal data in a way that guarantees its security by using appropriate technical or organizational measures.
4.7. We do not intend to further process your personal data for purposes other than the ones for which they are collected.
4.8. We inform you that there is no obligation to provide your personal data and that there are no possible consequences from the choice not to provide it. Furthermore, we inform you that your personal data will not be used for automated decision making, including profiling.
4.9. Without prejudice to what is stated in this policy, we do not disclose and transmit your personal data to third parties without your consent, unless permitted by law or by our contractual agreement with you.
4.10. 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.
4.11. In general, we comply with all applicable laws and comply with all our statutory obligations, as data controllers of your personal data.

5. Types of Data Collected
At the point of your access and during your use of our Website, you may provide to žžƵ the following types of personal data:
5.1. At the point of your access and during the use of intralot.com
• IP Address.
• End user device data
• General communication data.
• Browsing data.
• Information on user preferences regarding intralot.com products / services.
• Data regarding executed transactions.
5.2. At the point of giving us permission to obtain personal data from personal accounts for social media and / or other online services of third parties :
• Information stored in such accounts.
5.3. At the point of submitting your CV, cover letter, your contact information, enquiries or reports/complaints through our web site forms (including without limitation the Enquiry Form, the Whistleblowing Form etc.):
• All personal data directly provided by you.
5.4. At the point of accepting the receipt of advertisements [e.g. banners, hyperlinks, or plugins] and any other type of commercial communications placed at or communicated through intralot.com or through our social media channels:
• All personal data directly provided by you.
• Non-personally identifiable information regarding the popularity of such commercial communications.
5.5. Any other personally identifiable information directly provided by you during interaction with our social media channels.
5.6. žžƵ does not collect or gain access in any way to special categories (“sensitive”) of personal data or data relating to criminal convictions and offenses by its clients. You have an obligation to refrain from posting such data concerning yourself or third party data subjects. In the event that you submit such data to our Website, these will be removed as soon as we become aware of them. We have no liability to you or to any third parties for any processing of sensitive data due to your actions or omissions in breach of this obligation.

6. Purposes and Legal Bases of Data Processing
6.1. Personal data necessary for the navigation and use of our Website is collected and processed by žžƵ pursuant to Article 6 § 1 (b) of the GDPR for the following purposes:
• Technical capability for the smooth operation of our Website.
• Friendly and user-friendly operation of our site.
• Improve your online experience while navigating and using our site.
6.2. Personal data necessary for the provision of our services within our contractual relationship is collected and processed by žžƵ pursuant to article 6 § 1(b) of the GDPR for the following purposes:
• Performance of our contractual obligations towards our Users and Clients.
• Immediate, adequate, and efficient provision of our services.
• Communicating with our clients in the framework of the execution of our services and for the resolution of any complaints.
• Improvement, management and review of our products and services to meet the needs of our clients as much as possible.
• Administration, organization, and function of our business.
• Management of our clientele.
• Extrajudicial or judicial use for the protection of our lawful rights and interests.
6.3. Personal data necessary for the recruiting process is collected and processed by žžƵ pursuant to article 6 § 1 (b) of the GDPR for the following purposes:
• Communicating with you and processing your employment application in accordance with the žžƵ recruitment and hiring process
6.4. Personal data necessary for complying with a legal obligation pursuant to Article 6 § 1 (c) of the GDPR, for the following purposes:
• Replying to your enquires and addressing reports or complaints submitted through the Whistleblowing Form.
6.5. Personal data for which you have explicitly consented to be processed by žžƵ pursuant to article 6 § 1 (a) of the GDPR, for the following purposes:
• Communicating with you and replying to your enquiries submitted through the Enquiry Form.
6.6. žžƵ collects and processes your personal data solely for the purposes mentioned above and only to the extent that is strictly necessary to effectively serve them. Data collected are relevant, appropriate, and no more than what is required in view of the above purposes, whereas we strive to keep them accurate and up to date. Furthermore, your data are retained only for the period required to achieve the purposes, for which they are collected and processed, and are afterwards deleted.

7. Consent
7.1. žžƵ may process personal data only with your lawful consent for the following purposes :
• For the purposes of commercial communication, marketing, and advertising of our services or third party services via SMS, telephone, email, internet, fax, mail, social media and / or any other appropriate communication channels.
• For personified market research and / or analysis purposes to better understand your needs, preferences, interests, experiences and / or habits as a consumer.
• To operate and manage any reward programs.
7.2. You give us your consent to the processing of your personal data for the above purposes with an electronic statement in a manner clearly distinguishable from other consents or notice and in an intelligible and easily accessible form using clear and plain language. Your consent is freely given and your personal data are given without such a provision being a legal or contractual obligation or a requirement on behalf of žžƵ for the performance of a contract between us.
7.3. In this context, by giving your consent, you explicitly state that you wish to provide your consent for the above purposes in accordance with the terms and conditions of this policy. You may provide your consent in the following ways :
• When submitting your CV, cover letter and contact / personal details
7.4. You have the right to withdraw your consent at any time. Withdrawal of your consent does not affect the lawfulness of the treatment of your data prior to its revocation. Your consent is also revoked in the same manner as provided.

8. Data Recipients
8.1. žžƵ shares your data with its subsidiaries in the process of pursuing the purposes of data processing at Group level.
8.2. žžƵ does not assign your personal data or interconnect its database with any third parties, public authorities, or other organizations for financial or other consideration.
8.3. For the execution of the purposes mentioned in this Notice, žžƵ may provide access to or transmit the following types of your data to the following processors for and on behalf of :
• Your personal data to our internet and data hosting providers for hosting purposes.
• Your personal data to our information technology maintenance and support providers for the smooth operation of Website and our information and communication systems.
• Your personal data to third-party consultants to provide data analysis services.
8.4. The processing of your personal data by our data processors mentioned above is executed under our control and orders and is subject to the same data protection policy or to a policy of at least the same level of protection.
8.5. In the event that we are required by a court or other administrative authority and in any other case that we are legally bound to do so, our Company may transfer your personal data to public authorities to the extent specified by law before informing you.

9. Data Security and Confidentiality
9.1. In order to ensure the proper use and integrity of your personal data and to prevent their unauthorized or accidental access, processing, deletion, alteration, or other use, žžƵ applies appropriate internal policies and takes all appropriate organizational, technical, physical, logical, and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.
9.2. The processing of your data by žžƵ 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, which are applicable in each circumstance.
9.3. Your personal data are processed solely by authorized personnel of žžƵ, bound by strict obligations of confidentiality.

10. Retention of Personal Data
10.1. We keep your personal data for as long as it is each time necessary for the relevant purposes of their processing.
10.2. žžƵ 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 research or statistical purposes of 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 žžƵ, for as long as necessary to defend our rights and legitimate interests before any competent court and any other public authority.
10.3. After the period of retention, your personal data are 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.

11. Your Rights
11.1. 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 (e.g., 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.
11.2. žžƵ 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.
11.3. If your request does not meet the requirements of applicable law, žžƵ 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.
11.4. 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.
11.5. 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/her identity.
11.6. 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.

12. Your Obligations
12.1. 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 žžƵ. Furthermore, you must inform our Company of any changes to your information so as to ensure it is kept up-to-date and accurate.
12.2. If you are found to be in breach of your obligations or if our Company has reasonable suspicion that the information you provide is false or incomplet or in any way contrary to applicable law or this Privacy Notice, we retain the right to reject your application for registration or to suspend or terminate your account immediately without notice. In this case, you have no right to any compensation due to the rejection of your application, or the suspension or termination of your account.
12.3. 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.
12.4. 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 žžƵ. In any case, using the Site, you acknowledge that žžƵ 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.

13. Cookies
13.1. Our Website uses cookies. For more information please review our Cookie Notice below:
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data are removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

14. International Jurisdiction and Applicable law
14.1. Any dispute between you and žžƵ arising from or in relation to the subject matter of this Privacy Notice shall be governed and construed in accordance with the Greek law and shall be subjected to the exclusive jurisdiction of the competent courts of Athens, Greece.
14.2. 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.

For the Greek version you may click here

Information on the processing of personal data through a video surveillance system

1. Data Controller:
žžƵ S.A. 19 km. Markopoulou Ave., 19 002 Peania – Attica, Greece
Tel.: +30 210 6156000, E-mail: info@intralot.com

2. Purpose of processing and legal basis:
We use a surveillance system for the purpose of protecting persons and property. Processing is necessary for the purposes of legitimate interests we pursue as a controller (Article 6(1)(f) in the General Regulation (EU) 2016/679, hereinafter referred to as GDPR).

3. Legitimate Interests Analysis
Our legitimate interest is the need to protect our premises and property contained therein from unlawful acts, such as theft. The same applies to the safety of life, physical integrity, health, and property of our staff and third parties lawfully present in the premises under surveillance. We only collect image data and limit the collection to areas where we have assessed that there is an increased likelihood of illegal acts e.g. theft, such as at entry and exit points.

4. Recipients
The material held is accessible only by our competent/authorized personnel that is in charge of the physical security of the premises. Such material shall not be transferred to third parties, except in the following cases: a) to the competent judicial, prosecutorial and police authorities when it contains information necessary for the investigation of a criminal offence involving persons or property of the controller; (b) to the competent judicial, prosecutor and police authorities when requesting data lawfully in the exercise of their duties; and (c) to the victim or perpetrator of a criminal offence, in the case of data which may constitute evidence of the offence.

5. Data retention time
We retain the data for a period of fifteen (15) days, after which they are automatically deleted. In the event that during this period we detect an incident, we isolate part of the video and retain it for up to an additional one (1) month, in order to investigating the incident and initiate legal proceedings to defend our legitimate interests, while if the incident concerns a third party, we will keep the video for up to an additional three (3) months.

6. Data Subjects’ Rights
Data subjects shall have the following rights:
• Right of access: you have the right to know if we are processing your image and, if so, to obtain a copy of it.
• Right to restriction: you have the right to ask us to restrict the processing, for example not to delete data that you consider necessary to establish, exercise or support legal claims.
• Right to object: you have the right to object to processing.
• Right to erasure: you have the right to request that we delete your data.
You can exercise your rights by sending an e-mail to the address dpo@intralot.com or a letter to our postal address or by submitting the request in person to our Company's address. In order for us to address a request related to your image, you will need to inform us approximately when you were in range of the cameras and us with an image of you to help us identify your data and hide the data of third party subjects. Alternatively, we give you the option to visit to our premises to show you the images in which you appear. We also note that the exercise of the right to object or erasure does not imply the immediate deletion of data or the modification of processing. In any case we will reply to you in detail as soon as possible, within the deadlines set by the GDPR.

7. Right to file a complaint
In case you consider that the processing of your data is in breach of the GDPR, you have the right to file a complaint with the Hellenic Data Protection Authority (Kifissias 1-3, 115 23, Athens, https://www.dpa.gr/ tel. 2106475600).

For the Greek version you may click here