GDPR


Privacy Policy

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high
priority for the management of the Arzumanidis Investments, c/o Attica Capital Investments Ltd. The use of
the Internet pages of the Arzumanidis Investments, c/o Attica Capital Investments Ltd is possible without
any indication of personal data; however, if a data subject wants to use special enterprise services via our
website, processing of personal data could become necessary. If the processing of personal data is
necessary and there is no statutory basis for such processing, we generally obtain consent from the data
subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a
data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance
with the country-specific data protection regulations applicable to the Arzumanidis Investments, c/o Attica
Capital Investments Ltd. By means of this data protection declaration, our enterprise would like to inform
the general public of the nature, scope, and purpose of the personal data we collect, use and process.
Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to
which they are entitled.

As the controller, the Arzumanidis Investments, c/o Attica Capital Investments Ltd has implemented
numerous technical and organizational measures to ensure the most complete protection of personal
data processed through this website. However, Internet-based data transmissions may in principle
have security gaps, so absolute protection may not be guaranteed. For this reason, every data
subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of the Arzumanidis Investments, c/o Attica Capital Investments Ltd is
based on the terms used by the European legislator for the adoption of the General Data Protection
Regulation (GDPR). Our data protection declaration should be legible and understandable for the
general public, as well as our customers and business partners. To ensure this, we would like to first
explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data
subject”). An identifiable natural person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification number, location data, an
online identifier or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed
by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure or
destruction.

d) Restriction of processing

 Restriction of processing is the marking of stored personal data with the aim of limiting their
processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of
personal data to evaluate certain personal aspects relating to a natural person, in particular
to analyse or predict aspects concerning that natural person's performance at work, economic
situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data
can no longer be attributed to a specific data subject without the use of additional information,
provided that such additional information is kept separately and is subject to technical and
organisational measures to ensure that the personal data are not attributed to an identified
or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public
authority, agency or other body which, alone or jointly with others, determines the purposes
and means of the processing of personal data; where the purposes and means of such
processing are determined by Union or Member State law, the controller or the specific
criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which
processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which
the personal data are disclosed, whether a third party or not. However, public authorities
which may receive personal data in the framework of a particular inquiry in accordance
with Union or Member State law shall not be regarded as recipients; the processing of
those data by those public authorities shall be in compliance with the applicable data
protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than
the data subject, controller, processor and persons who, under the direct authority
of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous
indication of the data subject's wishes by which he or she, by a statement or by a
clear affirmative action, signifies agreement to the processing of personal data
relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR),
other data protection laws applicable in Member states of the European Union
and other provisions related to data protection is:

Arzumanidis Investments, c/o Attica Capital Investments Ltd

1 Ramsay Court, PE29 6FY Huntingdon

United Kingdom

Phone: +44 20 80 900 984

Email: info@arzumanidis.com

Website: Arzumanidis.com

3. Collection of general data and information

The website of the Arzumanidis Investments, c/o Attica Capital Investments Ltd.
collects a series of general data and information when a data subject or
automated system calls up the website. This general data and information are
stored in the server log files. Collected may be (1) the browser types and versions
used, (2) the operating system used by the accessing system, (3) the website
from which an accessing system reaches our website (so-called referrers), (4)
the sub-websites, (5) the date and time of access to the Internet site, (6) an
Internet protocol address (IP address), (7) the Internet service provider of the
accessing system, and (8) any other similar data and information that may be
used in the event of attacks on our information technology systems.

When using these general data and information, the Arzumanidis Investments,
c/o Attica Capital Investments Ltd does not draw any conclusions about the data
subject. Rather, this information is needed to (1) deliver the content of our
website correctly, (2) optimize the content of our website as well as its
advertisement, (3) ensure the long-term viability of our information technology
systems and website technology, and (4) provide law enforcement authorities
with the information necessary for criminal prosecution in case of a cyber-attack.
Therefore, the Arzumanidis Investments, c/o Attica Capital Investments Ltd
analyzes anonymously collected data and information statistically, with the aim
of increasing the data protection and data security of our enterprise, and to
ensure an optimal level of protection for the personal data we process. The
anonymous data of the server log files are stored separately from all personal
data provided by a data subject.

4. Contact possibility via the website

The website of the Arzumanidis Investments, c/o Attica Capital Investments Ltd.
contains information that enables a quick electronic contact to our enterprise, as
well as direct communication with us, which also includes a general address of
the so-called electronic mail (email address). If a data subject contacts the controller
by email or via a contact form, the personal data transmitted by the data subject are
automatically stored. Such personal data transmitted on a voluntary basis by a
data subject to the data controller are stored for the purpose of processing or
contacting the data subject. There is no transfer of this personal data to third
parties.

5. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject
only for the period necessary to achieve the purpose of storage, or as far as
this is granted by the European legislator or other legislators in laws or regulations
to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the
European legislator or another competent legislator expires, the personal data
are routinely blocked or erased in accordance with legal requirements.

6. Rights of the data subject

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain
from the controller the confirmation as to whether or not personal data concerning
him or her are being processed. If a data subject wishes to avail himself of this right
of confirmation, he or she may, at any time, contact our Data Protection Officer or
another employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain
from the controller free information about his or her personal data stored at any
time and a copy of this information. Furthermore, the European directives and
regulations grant the data subject access to the following information:
the purposes of the processing; the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or
will be disclosed, in particular recipients in third countries or international
organisations; where possible, the envisaged period for which the personal data
will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure
of personal data, or restriction of processing of personal data concerning the data
subject, or to object to such processing; the existence of the right to lodge a
complaint with a supervisory authority; where the personal data are not collected
from the data subject, any available information as to their source; the existence
of automated decision-making, including profiling, referred to in Article 22(1) and
(4) of the GDPR and, at least in those cases, meaningful information about the
logic involved, as well as the significance and envisaged consequences of such
processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether
personal data are transferred to a third country or to an international organisation.
Where this is the case, the data subject shall have the right to be informed of the
appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at
any time contact our Data Protection Officer or another employee of the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain
from the controller without undue delay the rectification of inaccurate personal data
concerning him or her. Taking into account the purposes of the processing, the data
subject shall have the right to have incomplete personal data completed, including
by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any
time, contact our Data Protection Officer or another employee of the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain
from the controller the erasure of personal data concerning him or her without
undue delay, and the controller shall have the obligation to erase personal data
without undue delay where one of the following grounds applies, as long as the
processing is not necessary: The personal data are no longer necessary in relation
to the purposes for which they were collected or otherwise processed.

The data subject withdraws consent to which the processing is based according to
point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and
where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR
and there are no overriding legitimate grounds for the processing, or the data
subject objects to the processing pursuant to Article 21(2) of the GDPR.

The personal data have been unlawfully processed. The personal data must be
erased for compliance with a legal obligation in Union or Member State law to
which the controller is subject. The personal data have been collected in
relation to the offer of information society services referred to in Article 8 (1)
of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to
request the erasure of personal data stored by the Arzumanidis Investments,
c/o Attica Capital Investments Ltd, he or she may at any time contact our Data
Protection Officer or another employee of the controller. The Data Protection
Officer of the Arzumanidis Investments, c/o Attica Capital Investments Ltd or
another employee shall promptly ensure that the erasure request is complied
with immediately.

Where the controller has made personal data public and is obliged pursuant to
Article 17(1) to erase the personal data, the controller, taking account of available
technology and the cost of implementation, shall take reasonable steps, including
technical measures, to inform other controllers processing the personal data that
the data subject has requested erasure by such controllers of any links to, or copy
or replication of, those personal data, as far as processing is not required. The
Data Protection Officer of the Arzumanidis Investments, c/o Attica Capital
Investments Ltd or another employee will arrange the necessary measures in
individual cases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain
from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period
enabling the controller to verify the accuracy of the personal data. The processing
is unlawful and the data subject opposes the erasure of the personal data and
requests instead the restriction of their use instead.

The controller no longer needs the personal data for the purposes of the processing,
but they are required by the data subject for the establishment, exercise or defence
of legal claims.

The data subject has objected to processing pursuant to Article 21(1) of the GDPR
pending the verification whether the legitimate grounds of the controller override
those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request
the restriction of the processing of personal data stored by the Arzumanidis Investments,
c/o Attica Capital Investments Ltd, he or she may at any time contact our Data Protection
Officer or another employee of the controller. The Data Protection Officer of the
Arzumanidis Investments, c/o Attica Capital Investments Ltd. or another employee
will arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the
personal data concerning him or her, which was provided to a controller, in a structured,
commonly used and machine-readable format. He or she shall have the right to transmit
those data to another controller without hindrance from the controller to which the personal
data have been provided, as long as the processing is based on consent pursuant to point
(a) of Article 6 (1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract
pursuant to point (b) of Article 6 (1) of the GDPR, and the processing is carried out by
automated means, as long as the processing is not necessary for the performance of a
task carried out in the public interest or in the exercise of official authority vested in the
controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20 (1) of
the GDPR, the data subject shall have the right to have personal data transmitted directly
from one controller to another, where technically feasible and when doing so does not
adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the
Data Protection Officer designated by the Arzumanidis Investments, c/o Attica Capital
Investments Ltd. or another employee.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on
grounds relating to his or her particular situation, at any time, to processing of personal
data concerning him or her, which is based on point (e) or (f) of Article 6 (1) of the GDPR.
This also applies to profiling based on these provisions.

The Arzumanidis Investments, c/o Attica Capital Investments Ltd shall no longer process
the personal data in the event of the objection, unless we can demonstrate compelling
legitimate grounds for the processing which override the interests, rights and freedoms
of the data subject, or for the establishment, exercise or defence of legal claims.

If the Arzumanidis Investments, c/o Attica Capital Investments Ltd. processes personal
data for direct marketing purposes, the data subject shall have the right to object at any
time to processing of personal data concerning him or her for such marketing. This
applies to profiling to the extent that it is related to such direct marketing. If the data
subject objects to the Arzumanidis Investments, c/o Attica Capital Investments Ltd. to
the processing for direct marketing purposes, the Arzumanidis Investments, c/o Attica
Capital Investments Ltd will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular
situation, to object to processing of personal data concerning him or her by the
Arzumanidis Investments, c/o Attica Capital Investments Ltd. for scientific or historical
research purposes, or for statistical purposes pursuant to Article 89 (1) of the GDPR,
unless the processing is necessary for the performance of a task carried out for
reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the Data
Protection Officer of the Arzumanidis Investments, c/o Attica Capital Investments Ltd.
or another employee. In addition, the data subject is free in the context of the use of
information society services, and notwithstanding Directive 2002/58/EC, to use his
or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be
subject to a decision based solely on automated processing, including profiling, which
produces legal effects concerning him or her, or similarly significantly affects him or
her, as long as the decision (1) is not is necessary for entering into, or the performance
of, a contract between the data subject and a data controller, or (2) is not authorised
by Union or Member State law to which the controller is subject and which also lays
down suitable measures to safeguard the data subject's rights and freedoms and
legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract
between the data subject and a data controller, or (2) it is based on the data subject's
explicit consent, the Arzumanidis Investments, c/o Attica Capital Investments Ltd.
shall implement suitable measures to safeguard the data subject's rights and
freedoms and legitimate interests, at least the right to obtain human intervention
on the part of the controller, to express his or her point of view and contest the
decision.

If the data subject wishes to exercise the rights concerning automated individual
decision-making, he or she may at any time directly contact our Data Protection
Officer of the Arzumanidis Investments, c/o Attica Capital Investments Ltd. or
another employee of the controller.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to
withdraw his or her consent to processing of his or her personal data at any
time. If the data subject wishes to exercise the right to withdraw the consent,
he or she may at any time directly contact our Data Protection Officer of the
Arzumanidis Investments, c/o Attica Capital Investments Ltd. or another
employee of the controller.

7. Data protection for applications and the application procedures

The data controller shall collect and process the personal data of applicants
for the purpose of the processing of the application procedure. The processing
may also be carried out electronically. This is the case, in particular, if an
applicant submits corresponding application documents by e-mail or by means
of a web form on the website to the controller. If the data controller concludes
an employment contract with an applicant, the submitted data will be stored
for the purpose of processing the employment relationship in compliance with
legal requirements. If no employment contract is concluded with the applicant
by the controller, the application documents shall be automatically erased two
months after notification of the refusal decision, provided that no other
legitimate interests of the controller are opposed to the erasure. Other
legitimate interest in this relation is, e.g. a burden of proof in a procedure
under the General Equal Treatment Act (AGG).

8. Legal basis for the processing

Art. 6 (1) lit. a GDPR serves as the legal basis for processing operations for
which we obtain consent for a specific processing purpose. If the processing
of personal data is necessary for the performance of a contract to which the
data subject is party, as is the case, for example, when processing operations
are necessary for the supply of goods or to provide any other service, the
processing is based on Article 6 (1) lit. b GDPR. The same applies to such
processing operations which are necessary for carrying out pre-contractual
measures, for example in the case of inquiries concerning our products or
services. Is our company subject to a legal obligation by which processing
of personal data is required, such as for the fulfillment of tax obligations, the
processing is based on Art. 6 (1) lit. c GDPR. In rare cases, the processing
of personal data may be necessary to protect the vital interests of the data
subject or of another natural person. This would be the case, for example,
if a visitor were injured in our company and his name, age, health insurance
data or other vital information would have to be passed on to a doctor,
hospital or other third party. Then the processing would be based on Art. 6
(1) lit. d GDPR. Finally, processing operations could be based on Article 6
(1) lit. f GDPR. This legal basis is used for processing operations which are
not covered by any of the abovementioned legal grounds, if processing is
necessary for the purposes of the legitimate interests pursued by our
company or by a third party, except where such interests are overridden
by the interests or fundamental rights and freedoms of the data subject
which require protection of personal data. Such processing operations
are particularly permissible because they have been specifically
mentioned by the European legislator. He considered that a legitimate
interest could be assumed if the data subject is a client of the controller
(Recital 47 Sentence 2 GDPR).

9. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR
our legitimate interest is to carry out our business in favor of the well-being
of all our employees and the shareholders.

10. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the
respective statutory retention period. After expiration of that period, the
corresponding data is routinely deleted, as long as it is no longer necessary
for the fulfillment of the contract or the initiation of a contract.

11. Provision of personal data as statutory or contractual requirement;
Requirement necessary to enter into a contract; Obligation of the data
subject to provide the personal data; possible consequences of failure
to provide such data.

We clarify that the provision of personal data is partly required by law
(e.g. tax regulations) or can also result from contractual provisions (e.g.
information on the contractual partner). Sometimes it may be necessary to
conclude a contract that the data subject provides us with personal data,
which must subsequently be processed by us. The data subject is, for
example, obliged to provide us with personal data when our company
signs a contract with him or her. The non-provision of the personal data
would have the consequence that the contract with the data subject could
not be concluded. Before personal data is provided by the data subject,
the data subject must contact our Data Protection Officer.

Our Data Protection Officer clarifies to the data subject whether the
provision of the personal data is required by law or contract or is necessary
for the conclusion of the contract, whether there is an obligation to provide
the personal data and the consequences of non-provision of the personal
data.

12. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or
profiling.

This Privacy Policy has been generated by the Privacy Policy Generator of the
German Association for Data Protection that was developed in cooperation
with Privacy Lawyers from WILDE BEUGER SOLMECKE, Germany.