Privacy Notice

INTRODUCTION

1. Welcome to the G. Samaras S.A.-Medical Gas Systems website ("G. Samaras S.A.", "we", "us"). G. Samaras S.A. takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of our G. Samaras S.A. website (the "Site"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Notice (“Privacy Notice”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. This Privacy Notice is also designed to assist our users who live in the European Union (the “EU”) to understand their applicable data privacy rights that exist under the EU's General Data Protection Regulation when they use the Services. Please read this Privacy Notice carefully. If you have any questions regarding this information or our privacy practices, please contact us at dataprotection@gsamaras.gr.
2. "Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
3. By using our Services or visiting our website, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Notice, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein.
4. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY NOTICE, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR WEBSITE. If we change our Privacy Notice, we will post those changes or the amended Privacy Notice on our website. We reserve the right to amend this Privacy Notice at any time.

WHEN WILL WE COLLECT PERSONAL DATA?

1. We will/may collect personal data about you:
   • when you use our Services or Site or open an account with us (for Medimote II users);
   • when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
   • when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
   • when you interact with us, such as via telephone calls, letters, fax, face-to-face meetings, social media platforms and emails;
   • when you use our electronic services, or interact with us via our website.
   • when you provide us with feedback or complaints;
   • when you submit your personal data to us for any reason.
   The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

WHAT PERSONAL DATA IS BEING COLLECTED?

1. The personal data that we may collect includes but is not limited to:
   • name;
   • email address;
   • date of birth;
   • billing address;
   • bank account and payment information;
   • telephone number;
   • gender;
   • any other information about the user when the user uses our Services
2. If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying us in writing about it. Further information on opting out can be found in the section below entitled "What are your rights?".

SETTING UP AN ACCOUNT

In order to use certain functionalities of the Services we provide, such as Medimote II, you will have to create a user account. When you register and create an account, we require you to provide us with a user name that you select but we do not ask for further information. Upon activating an account, you will also select a password. Your user name and password will be used so you can securely access and maintain your account.

VIEWING WEB PAGES

As with most websites, your computer sends information which may include personal data about you that gets logged by a web server when you browse our Site. This typically includes without limitation your computer's IP address, operating system, browser name/version, the referring web page, requested page, date/time, to help the site remember your last visit. The information is also included in anonymous statistics to allow us to understand how visitors use our site.

CUSTOMER SUPPORT

We provide customer service support through email and feedback forms. In order to provide customer support, we will ask for your email address. Aside from this information, we do not ask for any personal data to provide customer support. We only use information received from customer support requests, including, without limitation, email addresses, for customer support services and we do not transfer to or share this information with any third parties.

HOW DO WE USE THE INFORMATION YOU PROVIDE US?

1. We collect, process and disclose your personal data for the following purposes:
   • Send you marketing and promotional communications. For example, where you give us your prior consent, we may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. However, you will always be able to opt-out of our marketing at any time.
   • Send administrative information to you. For example, to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
   • Engage in and process transactions. For example, we may use your personal information along with financial, and/or payment information that you provide to us to process your transactions and for billing purposes.
   • Respond to your requests. For example, we may use your personal information to fulfill your request for a quote or customer support, or to provide you with information you have requested.
   • For our business purposes. We may use your information for our business purposes, such as data analysis, audits, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our products, services, marketing, and client relationships.
   • Respond to legal processes. We may use your information to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on us.
   • Any other purposes which we notify you of at the time of obtaining your consent.
   (collectively, the “Purposes”)
2. As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

HOW DO WE PROTECT CUSTOMER INFORMATION?

1. We implement a variety of security measures to ensure the security of your personal data on our systems. These include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymize and anonymize personal data wherever possible. Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.
2. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any legal or business purposes. If you cease using the Site, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Notice and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

1. We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, when you make a purchase with us we will keep the data related to your purchase, so we can perform the specific contract you have entered and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.
2. Your data may also be retained so that we can continue to improve your experience with us. We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
3. We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.

WHAT ARE YOUR RIGHTS?

We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email at any point.

• The 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. Therefore, we’re providing you with the information in this Notice.
• The right to access and rectification. You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.
• The right to data portability. The personal data you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
• The right to be forgotten. Under certain circumstances, you have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
• The right to restrict processing. Under certain circumstances, you have the right to restrict the processing of your personal data.
• The right to object. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).
• The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with any Supervisory Authority about how we process your personal data.
• The right to withdraw consent. If you have given your consent to anything we do with your personal data, 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 personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided in this privacy notice.

Further information and advice about your rights can be obtained from the data protection Regulator in your Country.

INFORMATION ON CHILDREN

The Services are not intended for children under the age of 18. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 18 nor is any part of our Site or other Services directed to children under the age of 18. We will remove and/or delete any personal data we believe was submitted by any child under the age of 18.

INTERNATIONAL DATA TRANSFERS

1. We share personal data internally or with third-parties for purposes described in this Privacy Notice. We will only send personal data collected within the European Economic Area (EEA) to foreign countries in circumstances such as:
   • To follow your instructions;
   • To comply with a legal duty; or
   • To work with our agents and advisers who we use to help run our business and services.
2. If we do transfer personal data to outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of the following safeguards:
   • Transfer to a non-EEA Country whose privacy legislation ensures an adequate level of protection of personal data to the EEA one;
   • Put in place a contract with the foreign third-party that means they must protect personal data to the same standards as the EEA;

QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US

1. If you have any questions or concerns about our privacy practices or your dealings with the Services, please do not hesitate to contact: dataprotection@gsamaras.gr.
2. If you have any complaint or grievance regarding how we are handling your personal data or about how we are complying with Privacy Laws, please contact us through email with your complaint or grievance as follows:
   
   Email: dataprotection@gsamaras.gr
   Indicating in the subject header of the email that you are sending a Privacy Law complaint would assist us in attending to your complaint speedily, by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “Privacy Complaint”.
   We will certainly strive to deal with any complaint or grievance that you may have fairly and as soon as possible.

HOW DO WE KEEP THIS NOTICE UP TO DATE?

We will review and update this Notice periodically. If we make material changes to this Notice, we will notify you either by prominently posting a notice of such changes prior to implementing the changes or by directly sending you a notification. We encourage you to review this Notice frequently to be informed of how we are protecting your information.