PRIVACY POLICY

1. Introduction

This Privacy Policy was posted on our website on 21.12.2018 and replaces any earlier post. This Privacy Policy generally is addressed towards any natural person who has or intends to have any kind of cooperation with us. It applies to the Personal Data (PD) you provide to us, as well as to the PD we collect as part of our operation activities as the Process Controller. 

Consequently, when you come into contact, as natural person, with our Company or use any of our products and services, you disclose your personal information (PD).

Moreover, this Privacy Policy aims to inform you (the natural person) what PD we collect, why we collect it, what the legal basis is for your PD processing, and how to update, manage, export and delete your personal information.

This compilation and posting declares our compliance with legislation - and specifically the EU General Data Protection Regulation 679/2016 - and also our respect for the protection of privacy and security of personal data.

2. Who we are

DMP Dental Industry S.A., is a leading dental materials manufacturer that has been established in Greece since 1985. Today it is based in privately-owned and modern facilities in the Industrial Zone of Markopoulo and is staffed by high-level professionals with excellent training.

It is, for the most part, an export company active in the global dental material’s market with a significant presence in Europe, America, Canada, etc. where, in the context of applying the relevant regulatory requirements, it operates either as a manufacturer or as a contract manufacturer.

Initially it started out by manufacturing amalgam alloys and then, by investing heavily on research and development, it developed a variety of high precision silicones, composites (resins) and bonding systems. Its laboratory is fully equipped and modern to support its strict quality control during production, the continuous research program of the company as well as test requirements determined by the international standards.

All of its products are categorized as medical devices and are CE marked, they are available either with the DMP brand or under private label (OEM). DMP’s Quality System is certified according to the standards ISO 9001 and EN ISO 13485 (Medical Devices).

DMP's aim is to respond to market demands in the best possible way while at the same time enhancing its portfolio and maintaining its main objective for the production of reliable high-quality products at competitive prices.

3. What PD we process and why

Personal data (PD) means any information that can be used to identify directly or indirectly a specific individual (you as a natural person).

We have to process PD (i.e. to collect, manage, store, delete) for the effective execution of our everyday business functions and services and, in some occasions, for the compliance with relevant legislation and regulations.

When you call us, visit our website, ask questions about one of our products/services, cooperate with us, we may ask you for relevant personal information (PD such as: name, address, email, telephone number, IBAN, date of birth) depending on the type of our cooperation.

You (as a natural person) are not obliged to provide us the personal data that we request, but if you choose not to do so, we may not be able to provide you with specific services, or with a high quality of service or respond to any queries you may have.

Furthermore, it is likely that you choose to voluntarily disclose to us additional PD (such as on sending a CV) or additional personal information data (e.g. fiscal, professional and tax data) as part of our information and cooperation.

4. How do we get PD

We may collect personal data from a variety of sources. 

This includes:

• Personal data you give us directly, e.g. during our communication
• Personal data we collect automatically, e.g. during a visit in our website
• Personal data we collect from other sources, e.g. a professional chamber

Most of the PD we process are provided to us directly by you, on voluntary basis, for one of the following reasons:

• You are interested in our products/services
• Information you disclose when you contact us or visit our website
• Information we receive from your usage of our products/services
• During your visit in our website our web server collects information (such as IP address, search engine (browser), or operating system) for activities such as calculating number of visitors at our website, checking communication effectiveness, etc. We do not process GPS-type data
• You have made an information request, an enquiry or a complaint to us
• You were interested in attending or attended a corporate event
• You have applied for a job or cooperation with us
• You are representing your organization 

We also receive personal information indirectly, in the following scenarios:

• We have seized personal information as part of market research or an investigation.
• From our partners or cooperating organizations
• One of our employees delivered your contact details
• It is likely to use information from advertising networks, our customers or third parties
• Your personal information is publicly available

When you contact us, we keep a record of our communication messages so as to resolve any issues that may arise. We do not allow any unauthorized entities, especially without your consent, to access your personal information.

5. How we use PD

We process (i.e. collect, store, disclose, delete etc.) your personal data (PD) only for specific and limited purposes. Moreover, we will only use your personal data, where we have a legal ground to do so, in order to:

• Process your request and satisfy your demand
• Provide you with personalized and updated services/products
• Contact you to ask for your opinion or let you know about new products/services that may interest you 
• Respond to your questions or complaints
• Implement the framework of this Privacy Policy
• Develop and improve our products/services, communication methods and the functionality of our websites

6. How long we keep your Personal Data

We keep your personal data for only as long as we need to. It depends on what we are using it for, as set out in this Privacy Policy. 

For example, we may need to use it to answer your queries or complaints about a service and, as a result, we may retain your personal data for a reasonable amount of time after the service has been completed (e.g. a period of possible claims). We may also need to keep your personal data for accounting purposes (the retention period depends on legislation relevant to tax authorities or financial investigation units). 

If we no longer need your data, we will permanently delete / destroy them. 

In addition, your personal data maintenance/storage period depends on the lawfulness of processing (legal basis for the processing), such as:

• When the processing of PD is necessary for the purposes of the legitimate interests pursued by the company, then processing of personal data will take place for as long as is necessary for the pursuit of the Company’s intended purposes and for as long as it is required until the lapse of any relevant claim has expired.
• When PD is voluntarily provided by natural persons themselves, for example as part of our communication or our website visit, we will retain your data (both in hard copy and in electronic form) for as long as we maintain a contractual relationship with you or as long it is necessary for compliance with our legal obligations or until your relevant consent has been withdrawn. In any case we shall retain your PD depending on our legal obligations or the lapse of possible legal claims.
• When you (the data subject) have given consent to the processing of your personal data and we have no other legitimate reasons to continue this process, and you withdraw your consent, then we will destroy/delete your personal data. However, when you unsubscribe (e.g. from marketing communications or webpage) we will maintain your email address to ensure that we do not send you any mail in the future.
• When processing is necessary for the performance of a contract to which you (the data subject) are party or in order to take steps at your request prior to entering into a contract; then we will retain your data for as long as you maintain a contractual relationship with us or as long it is necessary for compliance with our legal obligations or as long as it is required until the lapse of possible legal claims.

7. Disclosure of your PD

We do not disclose or share your PD with any third parties for any marketing or communication purposes. 

In the following circumstances we share (disclose) information: 

• With your own consent: we share your personal information with companies, organizations and natural persons when we have your explicit consent.
• For external processing: We use data processors, who are third parties, who provide elements of services for us. We have contracts in place, with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct them. All are aligned with the EU General Data Protection Regulation 679/2016 and our privacy policy.
• For legal purposes: We share personal information with public services when it is reasonably necessary and in order to comply with laws, regulations, legal procedures or governmental demands.
• For scientific research: We may provide non-identifiable data for scientific research or statistical studies.

8. Your Rights 

Under data protection law, you have rights we need to make you aware of. The rights available to you (as our guest, customer, employee, user of our products/services or our website visitor) depend on our reason for processing your personal information (i.e. your rights should not be contrary to relevant legislation).

These rights are:

• Your right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This Privacy Policy is providing you with relevant information.
• Your right to access and rectification: You have the right to access, correct or update your personal data at any time. 
• Your right to PD portability: You can receive your personal data, which you have provided to us, in a structured, machine-readable and interoperable format, and to transmit it to another organization. This right should apply where your personal data has been provided on the basis of your consent or in the framework for the performance of a contract.
• Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances. The exercise of your right can always be done in accordance with legal requirements (e.g. you cannot ask for a deletion of your PD when labor law or tax authorities require to be retained for certain period).
• Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances, including processing for direct marketing.
• Your right to submit a complaint to the Hellenic Data Protection Authority, http://www.dpa.gr/ or any national Data Protection Authority about how we process your personal data.

Your right to withdraw consent: If you have given your consent to anything we do with your PD, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your valid consent up to that date is unlawful). You can withdraw your consent to the processing of your PD at any time by contacting us, through ‘’Contact Us’’ (see § 13).

To exercise your rights, see § 10. Further information and advice about your rights can be obtained from the Hellenic Data Protection Authority, http://www.dpa.gr/ or any national Data Protection Authority in your country.

9. Our Obligations

We are accountable; in respect with the principles of processing personal data (ie legitimacy, objectivity and transparency, purpose limitation, minimization of PD, accuracy of PD, limitation of storage period, security, integrity, and confidentiality).

We will only use (process) your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. 

In each case, the legal ground will be one of the following:

• Your consent: You have provided your consent to receive product information, offers or marketing emails from us. You can withdraw your consent at any time by submitting an email to “Contact Us’’ (Section 13 of Privacy Policy).
• Contract Implementation: The execution of a contract signed with you, as a natural person, requires the processing of your PD both prior to contract and during its implementation.
• Compliance with legislation: We have legal obligation to process / retain your personal data, (e.g. compliance with legislation relevant to tax authorities or financial investigation units). 
• Our legitimate interests: Processing of PD is necessary for the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. This is the case when it is necessary to understand our customer, promote our services or operate our sites and apps efficiently. For example, we will rely on our legitimate interest when we study what content has been viewed on our sites and apps, so that we can understand how they are used. It is also in our legitimate interest to carry out marketing analysis to determine what products/services may be relevant to the interests of our customers and potential customers. 

In addition, we implement the appropriate technical and organizational measures to protect us and our partners against unauthorized access or alteration, tampering or destruction of PD we have in our possession. 

Specifically:

• We control data collection, storage and processing practices, including security measures, to protect against non-authorized access to systems and processes.
• Access to personal information is limited & controlled, and subject to strict contractual obligations of confidentiality.
• In case that partners (third parties for maintenance or support purposes) have potential access to PD, certain appendices of the existing cooperation contracts cover the requirements of the Data Protection Regulation.

Throughout the entire processing cycle of PD (from collection to destruction), we take the appropriate technical and organizational measures to ensure the confidentiality, integrity and availability of PD. Similar measures are required by third parties who handle or process PD on our behalf.

Our products, services and site are not aimed at children under the age of 15, We do not knowingly process children’s personal data. 

10. Access to your own information

Within the scope of the rights granted to you by the Data Protection Regulation, you can view and request a correction or limitation of processing or deleting your PD (see in detail your rights in § 8). 

You can exercise your rights by sending an email to ‘’Contact Us’’ (§ 13) asking for a Subject Access Request (SAR) form, and submitting the properly filled SAR form through the “Contact Us”. We are obliged to respond to you within one month of the receipt of your SAR.

11. Use of Cookies 

Our website uses only session cookies, which process information as long as a guest visits our website. In particular, permanent cookies are not used except when necessary for the operation of the application. When guest is in idle mode for 20 minutes, the session ends and cookies are deleted.

12. Links to other websites

Where we provide links to websites of other organizations, this Privacy Policy does not cover how that organization processes personal information. We encourage you to read the privacy notices on the other websites you visit.

However, sending information via the internet is not completely secure. Although we will do our best to secure your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.

13. Contact Us

There are many ways you can contact us, including by phone, email, web and post:

DMP Dental Industry S.A.

Compliance Officer

Kalyvion Avenue, Markopoulo Industrial Zone, 190 03, Attiki

Tel: +30 22990 23041

Fax: +30 22990 23043

Email: info@dmpdental.com, with the distinctive title: GDPR

Web: www.dmpdental.com