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PRIVACY NOTICE FOR HELPE GROUP’S FACEBOOK PAGE

The company HELLENIC PETROLEUM S.A. (“we/us”, the “Company”, the “Controller”) manages the HELPE Facebook page (@HELPEgroup) and, in accordance with the applicable data protection laws and regulations, is the Controller in terms of the data processed through the HELPE Group’s Facebook page. This Privacy Notice explains which data we collect and process through the HELPE Group’s Facebook page and how we use such data.

1.         Objective and legal basis

As many other webpages, we collect limited anonymous information concerning users and their systems. When users access the “Timeline” of HELPE Group’s Facebook page, no personal data are collected, other than the aggregate data provided to us by Facebook, which are metrics, such the number of visitors, clicks, “Likes” or “Reactions”, “Posts”, “Comments”, etc. This type of information is anonymised and is not related to specific users or information from public or private user profiles. We collect this data to serve the Group’s legal interests, namely to analyse user habits, improve page features and provide more useful information to page visitors.

2.         Data collected and collection sources

When you decide to follow our page or interact with us, (e.g. when you “Like” or react to a post, when you “Share” it or post a “Comment”), we gain access to your name, age and gender. We do not store your personal data nor do we extract it to store it in another database. Your data is used by the Company solely to enable the interaction between you and the Company via the specific social medium. We may delete your comments if they do not comply with our social media policies (e.g. if your comments are insulting, unlawful or made in bad faith), but we cannot amend your comments or use your data in any other way whatsoever. 

We use Facebook Insights, a Facebook app which installs cookies on the devices of our Facebook page users to collect information and provide statistical analysis on the bases of certain pre-determined criteria. Cookies are small pieces of information collected via small files installed on your devices (desktops, laptops, mobile phones, tablets, etc.) when you browse through webpages or apps. The provider of each individual website or application (in this case, Facebook) collects and processes this information for various purposes, such as to understand user behaviour during navigation in the website or the app. To find out more about Facebook Insights, cookies managed by Facebook, the information collected and transmitted via cookies and the time period for which they remain installed, please refer to Facebook Terms of Service and Facebook Information on the General Data Protection Regulation (GDPR).

The Company does not manage nor controls the cookies managed by Facebook but, through the use of Facebook Insights, Facebook provides the Company with certain reports, as described below. These reports contain aggregate data, i.e. statistics and analytics (e.g. the number of users who “liked” or “reacted” to a post, the number of user who visited again the company’s page, etc.), but the Company is in no position to know which are the specific users to whom these statistics and analytics refer. 

Some report examples sent by Facebook to the Company are the following:

  • The total number of people who “liked” or “unliked” the page on a daily, weekly and 28-day basis.
  • The total number of people who “followed” or “unfollowed” the page on a daily, weekly and 28-day basis.
  • The number of people on a daily, weekly and 28-day basis who interacted with the page (interaction involves any click, “like” or other reaction, any share or following of the page or the posting of any “comment”).
  • The number of people on a daily, weekly and 28-day basis who saw on their screens the company’s page or any content from the company’s page. This report includes “posts”, “check-ins” and social data of individuals who interact with the company’s page, as well as other data.
  • The number of people on a daily, weekly and 28-day basis who saw on their screens the company’s page or any content from the company’s page, without any paid promotion having been in place. This report includes “posts”, “check-ins” and social data of individuals who interact with the company’s page, as well as other social data.
  • The number of people on a daily, weekly and 28-day basis who saw on their screens any content from the company’s page, as a result of a paid promotion (ad, campaign). This report includes “posts”, “check-ins” and social data of individuals who interact with the company’s page, as well as other social data.
  • The number of people with other social data who saw on their screens the company’s page or any content from the company’s page on a daily, weekly and 28-day basis. This social data report is created when a “friend” of a user who has “liked” or “followed” the page interacts with the page or any post therein, “likes”, “reacts” to or interacts with a post, shares a photo or checks-in at the company’s page.
  • “Page Views” on a daily, weekly and monthly basis from Facebook users (total number and unique users number)
  • The number of people on a daily, weekly and 28-day basis who saw on their screens any “posts” from the company’s page. These “posts” include photos, “status updates”, “links”, videos, etc.
  • The number of people on a daily, weekly and 28-day basis who saw on their screens any “posts” from the company’s page, without any paid promotion having taken place (unique users).
  • The number of people on a daily, weekly and 28-day basis who saw on their screens any “posts” from the company’s page,  as a result of a paid promotion (unique users).
  • Daily, weekly and monthly clicks to any content on the company’s page.
  • Daily, weekly and monthly number of individuals who gave a negative evaluation to the company’s page.
  • Daily, weekly and monthly number of individuals who “checked-in” at the Company premises (total number and number of unique users).
  • Daily, weekly and monthly number of individuals who “checked-in” at the Company premises using mobile devices (total number and number of unique users).
  • Daily, weekly and monthly number of video views, without any promotion for the video in question (total number).
  • Daily, weekly and monthly number of video views for more than 3 seconds, as a result of a paid promotion (total number).
  • Daily, weekly and monthly number of video views, for more than 30 seconds, without any promotion for the video in question (total number).
  • Daily, weekly and monthly number of video views for more than 30 seconds or the entire video, as a result of a paid promotion for the video in question.
  • Daily, weekly and monthly clicks to the contact details on the company’s page.
  • Daily, weekly and monthly clicks to the company’s page (total number and unique users).
  • Daily, weekly and monthly clicks to the website and the contact e-mail on the company’s page (total number and unique users).

Please note that the cookies which allow Facebook to provide us with the foregoing statistics are installed by Facebook on your device when you access any professional Facebook page, either you are a registered Facebook user or not. This is why you must pay particular attention to Facebook’s Cookies Policy before consenting to their installation. You may delete the cookies installed by Facebook on your device through the relevant settings of your browser.

It is necessary to provide your consent to Facebook’s Terms of Service and Privacy Policy for the processing of your personal data for the aforementioned purposes; without such consent, we cannot communicate with you via this social medium and Facebook will not be allowed to use its cookies and other similar tools on your devices.

If a competition or lottery is organised via our page, a Privacy Notice concerning the specific event will be published, in order to inform the participants on how we will collect, use and process their personal data for this specific purpose.

3.         Transfer of data to third parties

The Company does not transmit in any manner whatsoever your personal data, nor does it share its files against a financial or other consideration with any private third party enterprises, individuals or legal entities, State authorities or agencies or other organisations.

The Company may give access to or transmit your personal data to third parties which process the data in their capacity as Processors, mainly in the context of the provision of advertising and promotion services. This processing is carried out under our control and only upon our order and is subject to the same privacy protection policy or a privacy policy that ensures at least the same level of protection.

The Company may transmit your data to tax, audit and other State authorities, when we consider, in good faith, that the law or other regulation obliges us to give access or transmit such data or relevant law enforcement agencies, provided that this is required under the law or any other lawful enforceable act or order.

Any transmission of your data to third countries outside the European Economic Area (i.e. outside EU member states, Norway, Iceland and Lichtenstein) shall comply with the data protection legal framework and only when sufficient guarantees for the protection of your data are provided.

4.        Retention period

As specified above, the Company does not store your personal data and manages your information only as explained under sections 1 and 2. Your personal information, such as “comments”, “check-in”, “likes” or “reactions” and their processing are subject to Facebook’s Terms of Service, Privacy Policy and Cookies Policy and we recommend that you carefully review these texts. We remind you that you may delete or amend any comment or post that you have published, using the relative features and that Facebook cookies can be deleted from your device via your browser settings.

The reports we receive from Facebook include only aggregate data, statistics, anonymous data and not personal data; therefore, there is not a specific time period set for their retention.

5.         Your rights

According to the General Data Protection Regulation, you have the following rights:

  • to be informed about the processing of your data;
  • to access your personal data;
  • to request correction of inaccurate data that concern you and are kept by the Group;
  • to request deletion of your personal data in some cases;
  • to receive your personal data that have been provided to the Group in a structured, commonly used and machine readable format, as well as to request the transmission of such data to third parties in some cases;
  • to prohibit the processing of your personal data conducted for the company’s legitimate interests ;
  • to request restriction of the processing of your personal data in some cases;
  • to submit a complaint to the data protection supervisory authority.

You may contact the Data Protection Authority as follows:

  • Postal address: Data Protection Authority, Offices: 1-3 Kifisias Avenue, P.C. 115 23, Athens
  • Call Centre: +30 210 6475600
  • Fax: +30 210 6475628
  • Email: contact@dpa.gr

 More information about these rights, including the circumstances in which they are exercised and how they are exercised,, , can be found in the PERSONAL DATA PROTECTION DECLARATION published on the corporate website (https://www.helpe.gr/en/media-center/personaldataprotection/gdpr/ ). For any matter related to the exercise of your rights with regard to the processing of your data by the Company, please contact the Data Protection Officer using the contact details below.

6.        Data Protection Officer’s contact details

Telephone +30 210 6302252
email DPO@helpe.gr

 

If you have any questions, feel free to contact us.

If you have any questions on this Notice, please contact us via e-mail or telephone using the Data Protection Officer’s contact details.