Legal

1. General Terms of Use

1.1. Identity and activity

Globy+ / GlobyPlus (hereinafter "Globy+", the "Company" or the "Service Provider") is the trading identity under which the services of the business that operates this website are presented.

Business details:

• Person in charge and manager: Christos Batzios
• Professional Chamber of Thessaloniki, registry no.: 141314
• Email address: info@globyplus.gr
• Contact telephone: +30 210 440 4004

Globy+ is active in the fields of insurance intermediation, of advice and intermediation in energy and telecommunications services, and in the provision or support of financial, investment and savings solutions, to the extent permitted by the regulatory framework in force from time to time and by the licences or authorisations held by Globy+ itself or by the bodies it cooperates with.

The exact capacity of Globy+ in each transaction, as well as the identity of the insurer, the energy or telecommunications provider, the financial institution or other contracting organisation, are disclosed to the user before the relevant contract is concluded.

1.2. Purpose of the website

The GlobyPlus website provides information, information tools, means of communication, requests for offers and, where supported, electronic procedures for choosing or obtaining products and services in the following fields:

• Insurance products and protection programs for life, health, property and professional risks.
• Investment, savings and pension products, in accordance with the applicable licences and regulatory requirements.
• Electricity and natural gas programs.
• Fixed and mobile telephony services, internet access and other telecommunications services.
• Advisory services, comparisons of available options and personalised proposals, depending on the activity and the possibilities provided.

Globy+ may cooperate with insurance undertakings, energy providers, telecommunications providers, financial institutions, investment firms and other lawfully operating organisations.

Use of the website is governed by these Terms of Use, the Privacy Policy (including its "Cookies" section) and the special terms of each individual service. The special terms of a contract prevail where the law or the contract itself so provides.

Browsing the website does not in itself entail the conclusion of a contract. Where acceptance of special terms, the giving of consent or the confirmation of a transaction is required, this takes place through a separate procedure.

1.3. Capacity and role of Globy+

Depending on the service, Globy+ may act as an insurance intermediary, as an advisor or intermediary for energy and telecommunications services, as a partner for informing or referring customers, or as another lawfully authorised body.

Its capacity is determined per service and is not presumed to be the same in all fields.

In particular:

Insurance services: Globy+ distributes or intermediates for insurance products only within its lawful professional capacity and its cooperations. The insurance undertakings are responsible for assuming and accepting the insurance risks, for issuing the policies and for fulfilling their obligations under the insurance contracts.

Investment and savings services: The information and proposals provided through the website do not automatically constitute personalised investment advice, portfolio management or any other regulated investment service. Such services are provided only by persons or bodies holding the required licence or authorisation. The exact nature of the service is disclosed before the cooperation.

Energy and telecommunications: Globy+ may inform users, compare available programs, collect requests of interest and intermediate for the conclusion of contracts with cooperating providers. Unless expressly stated otherwise, it is not itself the supplier of electricity or natural gas, nor the provider of telecommunications services.

1.4. Acceptance of the Terms

The user must read these terms carefully before using the services of the website.

Use of the website entails acceptance of the terms that govern browsing and the corresponding functions. Submitting a request, sending details or starting an electronic transaction does not automatically entail acceptance of an offer or the conclusion of a contract with a third-party provider.

The acceptance of special contractual terms, consent to the processing of personal data and the giving of a payment order, where required, are separate procedures.

2. Procedure for the Provision of Services and the Conclusion of Contracts

2.1. Submission of details and requests

The user may fill in electronic forms, submit requests for offers, choose categories of services and provide the information required for the assessment of the available options.

The user must provide accurate, complete and up-to-date details, to the extent that these are required for the service in question. Globy+ is not liable for inaccurate results or unsuitable proposals that are due to incomplete, incorrect or misleading details provided by the user, without prejudice to the obligations imposed by legislation.

Offers and proposals are based on the information available at the time they are drawn up and may change because of changes in the user's details, in pricing or in the terms of the cooperating providers.

2.2. Insurance products

The presentation of insurance products, the comparison of prices and cover and the submission of an insurance request do not in themselves constitute a final insurance contract.

The insurance application or proposal is submitted to the relevant insurance undertaking and is subject to its assessment and acceptance, where required. Insurance cover begins in accordance with the terms of the policy and the applicable provisions, including the conditions for payment of the premium.

Globy+ cannot bind an insurance undertaking beyond the limits of its authorisation, nor guarantee the acceptance of an insurance risk, the issue of a policy or the payment of compensation.

Before the contract is concluded, the user must check the cover, the exclusions, the deductibles, the limits of compensation, the period of validity and the other contractual conditions.

2.3. Investment and savings products

The information provided about investment or savings products is intended to inform the user and does not constitute a guarantee of return or a safeguarding of capital, unless this is expressly and lawfully provided for by the specific product.

Before a contract is concluded, the user must be informed about:

• The nature and characteristics of the product.
• The risks, the charges and the possible costs.
• The duration, the liquidity and the terms of redemption or withdrawal.
• Any tax burdens and restrictions.
• The conditions of capital protection or guarantee, if any.

Past returns are not a reliable indication of future returns. The value of investments may rise or fall and the investor may lose part or all of their capital.

Where regulated investment services are provided, the special rules on information, on the assessment of suitability or appropriateness and on investor protection provided for by legislation apply.

2.4. Energy contracts

Globy+ may inform users about available electricity and natural gas tariffs, compare programs and intermediate for the submission of a request to cooperating suppliers.

The prices, discounts, charges, estimates of savings and terms of the programs may change. Comparisons are based on the consumption details provided by the user, on the available price lists and on the assumptions stated in the offer in question.

The final pricing, the terms of supply, the activation of the supply, the issue of bills and the obligations of the supplier are determined by the contract concluded with the relevant provider.

Globy+ does not guarantee a specific amount of savings, as this depends on actual consumption, changes in prices, regulated charges, taxes and the terms of the chosen program.

2.5. Telecommunications contracts

Globy+ may present and compare programs for fixed and mobile telephony, Internet and other telecommunications services.

The available speeds, the connection technology, the network coverage, the equipment, the charges, the discounts, the commitment period and the conditions of activation are determined by the relevant provider and the contract concluded with it.

The stated speeds or other technical capabilities may depend on the coverage of the area, the technical infrastructure, the equipment and other factors.

Globy+ does not guarantee the activation of a specific service or the achievement of a specific speed, where these depend on the provider or on technical limitations it does not control.

2.6. Finalisation of transactions

The final contract is concluded with the body that undertakes to provide the specific product or service, unless Globy+ is expressly named as a contracting party.

The user must check the final contractual documents before accepting them. If an initial indicative offer differs from the final binding offer, the terms lawfully disclosed before the conclusion of the contract apply, without prejudice to the rights of the consumer.

3. Prices, Payments and Refunds

The prices and charges shown on the website refer to the relevant service and to the point in time at which they are presented. Where required, it is made clear whether taxes, fees or other charges are included.

The payment of premiums, investment contributions, energy bills, telecommunications charges or other amounts is made in accordance with the instructions and terms of the relevant contracting body.

Globy+ collects amounts on behalf of third parties only if it holds the relevant legal or contractual authorisation. In every case, the user is informed about the beneficiary of the payment and the purpose of the transaction.

Any refunds, credits, cancellations of charges and settlements are carried out in accordance with the nature of the transaction, the terms of the relevant contract and the legislation in force.

For insurance policies, investment products and energy or telecommunications contracts, the special terms of cancellation, redemption, exit or refund of the product in question apply, provided that they are lawful and have been disclosed to the customer.

4. Rights of Objection, Withdrawal and Cancellation

The user retains the rights granted by the legislation in force from time to time and by the relevant contract.

4.1. Insurance contracts

The rights of objection and withdrawal from insurance contracts are exercised in accordance with the applicable insurance and consumer legislation and the terms of the policy.

The time limits, the exceptions, the way the declaration is submitted and the consequences of exercising the right depend on the type of insurance contract and the applicable provisions.

The user must address the competent body and follow the procedures provided for. Globy+ may assist in forwarding requests, where this falls within its role, without taking the place of the competent insurer.

4.2. Investment and savings products

Cancellation, redemption, withdrawal of capital or withdrawal from the contract are governed by the terms of the specific product and the applicable legislation.

There may be costs, time restrictions, loss of interest or returns, changes in value or other consequences. The user must be informed about these before investing or submitting a redemption request.

4.3. Energy and telecommunications

Withdrawal, termination, change of provider, interruption of service and any early exit charges are governed by the provider's contract and the applicable law.

Where a right of withdrawal is provided for distance contracts, the user is informed about its time limit, conditions and exceptions. The start of the provision of a service before the end of the withdrawal period may be subject to special terms and legal conditions.

Submitting a request for interruption or change of provider does not release the user from financial obligations that have already lawfully arisen.

4.4. How requests are submitted

Requests for cancellation, withdrawal or objection may be sent to the official contact details of Globy+, provided that the Company is competent to receive or forward them.

To keep legal time limits, the user must confirm the competent recipient and use the prescribed means of submission. Simply contacting Globy+ does not take the place of submitting a declaration to the provider, when this is required by law or by the contract.

5. Renewal, Duration and Expiry of Contracts

The duration, renewal and expiry of each contract are determined by the special terms of the relevant product or service.

The renewal of insurance policies, energy programs, telecommunications contracts or savings products is not taken for granted, unless it is provided for by law and by contract.

Where automatic renewal or recurring payment is available, the user is informed before it is activated about the relevant terms, the frequency, the amount or the way it is calculated, and the procedure for revoking the order.

The expiry, non-renewal or interruption of a contract may bring about the consequences provided for in the contractual terms, without affecting mandatory consumer protection provisions.

6. Customer Service, Complaints and Out-of-Court Dispute Resolution

6.1. Contact

For information, requests and complaints about its services, Globy+ has the following contact details:

• Email: info@globyplus.gr
• Telephone: +30 210 440 4004
• Postal address: Panagias Dexias 1, 54635 Thessaloniki

The days and hours of service are announced on the website. Any emergency services, such as roadside assistance or accident care, are provided in accordance with the terms of the relevant insurance program or of the cooperating provider.

6.2. Complaint handling

Globy+ examines complaints that concern its services and its obligations and makes reasonable efforts to answer them in good time and with reasons.

When a complaint concerns an insurance undertaking, an energy provider, a telecommunications provider or a financial organisation, it may be forwarded to the competent body, in accordance with the role of Globy+ and the legislation in force.

For insurance complaints, the special procedures and time limits provided for by the regulatory framework in force apply. Submitting a complaint to Globy+ does not take the place of exercising a legal right before a competent authority or court and does not automatically suspend legal time limits.

6.3. Competent authorities and out-of-court resolution

Depending on the subject of the dispute, the user may turn to the competent supervisory or consumer authorities, to the bodies provided for alternative dispute resolution or to the competent courts.

For insurance matters, the competent bodies may be, as the case may be, the Bank of Greece and the competent consumer protection bodies.

For telecommunications services, the competent bodies may be the Hellenic Telecommunications and Post Commission and the competent consumer protection authorities.

For energy matters, the competent bodies may be the Regulatory Authority for Waste, Energy and Water and the competent dispute resolution bodies.

For financial or investment services, the competences of the relevant supervisory authorities and of the complaint mechanisms provided for by law apply.

The above references do not exclude other procedures provided for by the legislation in force.

7. Personal Data and Communications

Globy+ processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679, the applicable Greek legislation and the Privacy Policy of the website.

The data that may be collected include identification and contact details, information required for the assessment of requests, details of insurance contracts, energy consumption information, telecommunications service needs and other data necessary for the transaction in question.

The data are used, as the case may be, for:

• Serving requests and providing offers.
• Preparing, concluding and performing contracts.
• Passing necessary information to cooperating providers.
• Complying with legal obligations.
• The security of transactions and the prevention of fraud.
• Communication about requests, contracts and services provided.
• Sending promotional communications, where there is an appropriate legal basis.

The data are passed only to the appropriate recipients and to the extent necessary for the relevant purpose, such as insurance undertakings, energy and telecommunications providers, financial organisations, authorised partners and competent public authorities.

The transfer of data does not entail unlimited access to or use of them by the partners. Each recipient acts in accordance with its role, the applicable provisions and the corresponding data protection obligations.

The data are kept only for as long as is required for the purposes of the processing or is imposed by law.

The user may exercise, as the case may be, the rights of access, rectification, erasure, restriction, objection and portability, and may withdraw consent where the processing is based on it.

Withdrawing consent to promotional communications does not affect the lawfulness of the processing that came before it, nor processing that is based on another legal basis.

More information is provided in the Privacy Policy, which is an integral part of the information given to users.

7.1. Telephone conversations

Telephone conversations are recorded only where this is permitted by the applicable legislation, for a specific and lawful purpose and with the required prior information. Where required, the appropriate consent is obtained.

The period for which recordings are kept is determined on the basis of the purpose, the legal obligations and the Privacy Policy.

7.2. Promotional communications

Globy+ may send updates and promotional communications about insurance, investment, savings, energy and telecommunications services only when the legal conditions are met.

Where consent is required, it is requested separately and is not presumed merely from the acceptance of these Terms of Use. The user may stop promotional communications through the mechanism provided or by contacting Globy+.

8. Intellectual and Industrial Property

All the content of the website, including, by way of example, texts, graphics, photographs, designs, logos, marks, visual elements, applications and other material, is protected by the legislation in force on intellectual and industrial property, unless it belongs to third parties or is stated otherwise.

The name Globy+, the name GlobyPlus and the related distinctive features are protected to the extent provided for by the applicable legislation.

The reproduction, copying, distribution, modification, commercial exploitation or other use of the content without the prior permission of the lawful rightholder is prohibited, unless it is permitted by law.

Any marks, logos, product descriptions and material of third parties remain the property of their respective rightholders and are used in accordance with their terms.

9. Limitation of Liability

Globy+ makes reasonable efforts so that the information on the website is accurate, clear and up to date. However, it does not guarantee that every piece of information is complete, always current or free of technical errors.

The information, comparisons and indicative offers are based on the data available at the time they are presented and may be changed by the respective providers or by changes in legislation and in the market.

Globy+ is not liable for acts or omissions of third-party providers, for the availability or quality of networks, for the acceptance of insurance applications, for the return on investments or for the fulfilment of obligations arising exclusively from third-party contracts, except to the extent that its liability is founded on the law or on its own contractual obligations.

No guarantee is given of a specific investment return, energy saving, connection speed or acceptance of an insurance risk, when these depend on factors outside the control of Globy+.

Globy+ is not liable for temporary inability to access the website because of maintenance, technical problems, network interruptions or circumstances that it cannot reasonably control.

No provision of these terms excludes or limits liability that cannot lawfully be excluded or limited, nor does it affect consumer rights that are protected by mandatory provisions.

10. Obligations of Users and Security

Users must use the website lawfully and in accordance with these terms.

The following in particular are prohibited:

• Providing false or misleading details.
• Using the website for illegal activities.
• Attempting unauthorised access to systems or data.
• Obstructing the smooth operation of the website.
• Reproducing or exploiting content in breach of third-party rights.

Globy+ may take reasonable technical and organisational measures to protect the website, the transactions and the data. In the event of misuse or breach of the terms, it may restrict access to the relevant functions, without prejudice to the legislation in force.

11. Links and Third-Party Services

The website may include links to websites of partners, insurance undertakings, energy providers, telecommunications organisations, financial institutions or other third parties.

External websites operate under the responsibility of the respective bodies and are governed by their own terms of use and privacy policies.

Globy+ does not necessarily control the content, the availability or the practices of these websites and is not liable for matters that arise exclusively from their use, without prejudice to any obligations provided for by law.

12. Amendment of the Terms of Use

Globy+ may amend these terms when this is required by changes in legislation, in the services, in the technological possibilities or in the way it operates.

The version in force from time to time is published on the website with a reference to the date of the last update.

Amendments apply from their publication or from another date that is expressly stated. They do not retroactively affect rights or obligations that have already arisen, nor do they automatically amend existing contracts with third parties.

Where specific information to the user or the user's consent is required, this takes place in accordance with the legislation in force.

13. Language, Applicable Law and Jurisdiction

These Terms of Use are drawn up in the Greek language. If translations into other languages are available, they are provided for the convenience of users. In the event of differences between versions, the Greek version applies, to the extent permitted by law.

The terms are governed by Greek law and the applicable law of the European Union.

Any disputes are resolved by the courts that are competent by law, without prejudice to the special rules of international jurisdiction and the mandatory rights of consumers.

14. Partial Invalidity and Final Provisions

If any provision of these terms is held to be invalid or unenforceable, the remaining provisions remain in force, to the extent that they can be applied on their own.

The non-exercise or delayed exercise of a right by Globy+ is not regarded as a waiver of it.

These terms, together with the applicable policies and the special contractual terms of each service, set the framework for the use of the website and do not take the place of the individual contracts with insurance undertakings, investment bodies or energy and telecommunications providers.

Globy+

Insurance · Investments · Savings · Energy · Telecommunications

For information or clarifications about these terms, you may contact us through the official contact details shown on the website.

1. INTRODUCTION – PURPOSE OF THE PRIVACY POLICY

At GlobyPlus, with the trading name Globy+, we treat the protection of personal data as a fundamental condition for building relationships of trust with the visitors to our website, our prospective customers, our customers and our partners.

This Privacy and Personal Data Protection Policy (hereinafter the "Policy") explains transparently which personal data we collect, for which purposes we process them, to whom we may disclose them, for how long we keep them and which rights you can exercise under the legislation in force.

The Policy applies when you visit or use our website, fill in electronic forms, ask for information or an offer, contact us, take part in promotional activities or receive services through GlobyPlus.

Its scope covers, depending on the service you ask for, insurance intermediation, information and intermediation for investment and savings products, as well as information, comparison, promotion or intermediation for energy and telecommunications services.

The data are processed in accordance with Regulation (EU) 2016/679 ("GDPR"), Law 4624/2019, as in force, and every other applicable national or Union provision.

This Policy is supplemented, where required, by the Terms of Use, the "Cookies" section of this Policy, the specific data protection notices and the contractual terms of the individual products or services.

2. CONTROLLER AND CONTACT

The Controller is the natural or legal person that determines the purposes and means of the processing of personal data.

For the processing carried out in the context of the operation of GlobyPlus, the details of the Controller are the following:

• Distinctive title / trading name: GlobyPlus – Globy+
• Manager / person in charge: Christos Batzios
• Contact telephone: +30 210 440 4004
• Email address: info@globyplus.gr

For questions about this Policy, the processing of your data or the exercise of your rights, you can contact us using the above details and stating "Personal Data Protection" as the subject.

Data protection officer: not appointed.

Depending on the specific service, we may act as an independent Controller, as a joint Controller with another body or, in certain cases, as a Processor on behalf of a partner. The respective role is determined on the basis of the actual relationship and the applicable contractual and legal obligations.

3. WHICH PERSONAL DATA WE COLLECT

We collect and process only the personal data that are appropriate, relevant and necessary for the lawful purpose in question. The type and extent of the data depend on the service you choose and on the information required to examine or complete your request.

3.1. Identification and contact details

We may process:

• Full name and, where required, father's name.
• Home or correspondence address.
• Telephone number and email address.
• Date of birth and other identification details, when necessary.
• Identity card number, passport number, tax identification number (Α.Φ.Μ.) and related tax details, if required for a specific transaction.
• Details of representation or authorisation, where you act on behalf of another person or a legal person.

3.2. Data concerning insurance services

Depending on the type of insurance, we may collect:

• Vehicle details, such as registration number, chassis number, registration certificate, driver details and insurance cover history, where required.
• Information about the insured person, the asset or the insurance risk.
• Details required for the assessment of a request, the issue of an offer or policy, the renewal or the management of the insurance contract.
• Details about an accident, damage, claim for compensation or complaint, if you are involved in such a procedure.
• Medical data or other special category data, only if they are necessary for a specific insurance procedure and there is an appropriate legal basis and condition for processing.

Data concerning health, as well as other special category data under the GDPR, are treated with increased protection and are requested only when their processing is necessary and lawful.

3.3. Data for investment and savings products

When you ask for information or services related to investments, savings, financial products or insurance products with investment features, the following may be required, depending on the service and the applicable framework:

• Identification, contact and tax residence details.
• Information about your investment goals, time horizon and financial situation.
• Details about your professional or financial situation, your income, your experience and your knowledge of investment products.
• Information about your risk tolerance and liquidity needs, when required for an assessment of suitability or appropriateness.
• Details required to fulfil obligations of identification, regulatory compliance or the prevention of money laundering, if they apply to the specific service.

These data are collected only to the extent necessary for the service in question. It is not assumed that every visit to the website or every request for information automatically entails the collection of a financial profile.

3.4. Data for energy services

For information, comparison, an offer or the handling of a request about electricity or natural gas, we may collect:

• The address of the property and the details of the contracting party.
• The electricity supply number or the corresponding natural gas supply details.
• Details of bills, consumption, tariff and current or previous supplier.
• Copies or photographs of bills and supporting documents, if required for the assessment or handling of the request.
• Identification details, tax details and contact details requested by the competent provider.
• Information about the progress of an application to change supplier or to conclude a contract, if we have been entrusted with handling it.

We recommend that you do not send documents containing information that is not necessary for your request. Where possible, you may hide unnecessary details before sending them, provided that the information required to serve you remains available.

3.5. Data for telecommunications services

For requests concerning fixed or mobile telephony, an internet connection, telecommunications packages or related services, we may collect:

• Identification and contact details.
• The installation address and the details of the existing connection.
• Information about the current provider, the program, the usage needs and the characteristics of the connection.
• A telephone number or other connection details, when necessary for number portability or for handling the request.
• Supporting documents and identification details required by the provider for the submission or acceptance of the application.

We do not gain access to the content of your communications, to your messages or to your telecommunications traffic simply because you ask for an offer or information through GlobyPlus.

3.6. Transaction, communication and website usage data

As the case may be, we may process:

• The history of requests, offers, contracts and communication.
• Information you provide through forms, email, telephone or other service channels.
• Payment or transaction details, where these are necessary.
• IP address, technical device identifiers, browser details and security log data.
• The strictly necessary cookies described in section 14.

We do not ask for or seek to collect passwords to bank accounts or other third-party services, unless there is a specific, lawful and strictly necessary procedure provided for by the relevant service. Do not send such passwords through our usual forms or communication channels.

3.7. Applications to work with us (Globy+ advisors)

If you apply through the "Become an advisor" page, we process your full name, phone number, email address and city, and whatever you write to us about yourself.

These data are used solely to evaluate a possible collaboration and to contact you about it, now or in the future, on the legal basis of your request to work with us (Article 6(1)(b) GDPR) and, for contacting you later, our legitimate interest (Article 6(1)(f) GDPR). We do not record you as a client, we do not send you promotional communications and we do not pass your details to the company’s other brands.

The data are kept for up to 24 months from the date the application was received and are then deleted automatically. You can ask us to delete them sooner at any time by email, as described in section 11.

4. WHERE THE DATA COME FROM

Your personal data are collected mainly directly from you, when you visit the website, fill in a form, ask for an offer, contact us or submit a request for a specific product or service.

Depending on the type of service, we may also receive data from:

• Insurance companies and insurance intermediaries.
• Banks, investment firms, insurance undertakings or other financial bodies, where this is lawful and relevant to the service.
• Electricity, natural gas and telecommunications providers.
• Authorised partners, technical providers and persons involved in handling your request.
• Public authorities, registers or other lawful sources, when there is a relevant basis and necessity.

When the data are not collected directly from you, we provide the information required by the GDPR, unless a lawful exception applies.

5. FOR WHICH PURPOSES WE PROCESS THE DATA

We use your personal data exclusively for specific, explicit and lawful purposes, which may include:

5.1. Serving and handling requests

To answer questions, to contact you, to examine your needs, to provide information, to prepare offers and to handle requests you submit through the website or other channels.

5.2. Insurance services

For the preparation and management of insurance applications, the search for offers, the transfer of necessary details to insurance companies or other competent partners, as well as for serving matters related to existing insurance contracts, renewals, requests, complaints or insurance claims, when they fall within our role.

The assessment and final acceptance of the insurance risk, the issue of the policy and the payment of compensation belong to the competent insurer, in accordance with the contract and the legislation.

5.3. Investment and savings products

For providing information, examining requests, communicating with the competent licensed body and, where provided for, handling the required pre-contractual or contractual procedures.

When required by legislation, the data may be used for identification checks, assessment of suitability or appropriateness, regulatory compliance, fraud prevention or other obligations of the competent body.

5.4. Energy and telecommunications services

For understanding your needs, comparing available options, presenting offers, passing details to providers and handling applications to conclude or change a contract, provided that you have given us the required instruction or authorisation.

5.5. Contractual and legal obligations

For fulfilling obligations arising from legislation, keeping accounting and tax records, managing complaints and reports, responding to lawful requests of public or judicial authorities and establishing, exercising or defending legal claims.

5.6. Security, fraud prevention and protection of rights

For protecting the website, the information systems, the transactions and the users, detecting malicious actions and dealing with incidents of fraud or unauthorised access.

5.7. Service improvement and statistical analysis

For assessing the quality of service, improving the operation of the website, analysing the use of the services and producing statistics, preferably with aggregated or anonymised data, where this is possible.

5.8. Updates and commercial communication

For sending updates about requests or services you already use and, when there is an appropriate legal basis, for sending informational or promotional material by email, SMS, telephone or another available means.

Advertising communications are sent in accordance with the legislation in force. Where consent is required, it is requested in advance. You can at any time withdraw your consent or object to direct marketing, free of charge.

6. LEGAL BASES FOR PROCESSING

We process your personal data only when at least one of the legal bases of Article 6 GDPR applies and, where special categories of data are concerned, when the conditions of Article 9 GDPR are also met.

Depending on the service and the purpose, the legal bases may be:

• Performance of a contract or pre-contractual measures: when the processing is necessary to examine your request or to conclude or perform a contract.
• Legal obligation: when the processing is required by tax, accounting, insurance, financial or other applicable legislation.
• Consent: when you have given free, specific, informed and unambiguous consent for a specific purpose, as may be required for certain forms of promotional communication or for non-essential cookies.
• Legitimate interest: when the processing is necessary for a legitimate interest of ours or of a third party, provided that your rights and freedoms do not override it. Such interests may concern the security of systems, the prevention of fraud, the defence of legal claims or the improvement of services.
• Vital or public interests: only in the cases where the special conditions provided for by law are met.

The legal basis is determined per processing activity. Consent is not used as a general or single basis for all the functions of the website and is not a condition for processing that is necessary for the performance of a contract or for compliance with a legal obligation.

When consent is requested, you can withdraw it at any time. The withdrawal does not affect the lawfulness of the processing carried out before it.

7. DISCLOSURE AND TRANSFER OF DATA TO THIRD PARTIES

We do not sell your personal data. We do not disclose them indiscriminately to third parties, nor do we allow them to be used for purposes incompatible with those for which they were collected.

Your data may be disclosed, to the extent that this is necessary and lawful, to the following categories of recipients:

7.1. Insurance companies and insurance service partners

To insurance undertakings, insurance intermediaries, loss adjusters, repair shops, roadside assistance providers, accident care services, doctors or other competent bodies, when this is required for the offer, issue, management or servicing of an insurance contract or a related claim.

Depending on the case, details may be disclosed to reinsurance undertakings, to competent bodies of the insurance sector or to other recipients provided for by the legislation in force.

7.2. Financial and investment bodies

To banks, investment firms, insurance undertakings or other appropriately authorised or licensed bodies, when this is necessary for providing the specific service, handling a request or fulfilling legal obligations.

7.3. Energy and telecommunications providers

To electricity or natural gas suppliers, telecommunications providers and their authorised partners, when you ask for an offer, a change of provider, number portability, the conclusion of a contract or another related service.

The disclosure is limited to the details required to examine or handle the specific request.

7.4. Technical providers and professional partners

To providers of website hosting and support, information systems, email, request management, system security, communication services, accounting, legal or other professional support.

They include Cloudflare, Inc., which hosts the website and our systems and protects the forms from spam (Turnstile), and Proton AG, which provides our email.

When these partners process data on our behalf, they are bound by the appropriate contractual and organisational obligations of confidentiality and data protection.

7.5. Public, supervisory and judicial authorities

When the disclosure is required by law, by a lawful request of a competent authority or when it is necessary for establishing, exercising or defending legal claims.

In every case, we seek to disclose only the data that are necessary for the specific purpose. Third parties acting as independent Controllers are subject to their own obligations of information and data protection.

8. TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

As a rule, we seek to have the data processed within the European Economic Area (EEA).

However, certain technical providers or partners may process data in third countries. If personal data are transferred outside the EEA, this will take place only if the conditions of the GDPR are met, such as the existence of an adequacy decision or of appropriate safeguards and, where required, supplementary protection measures.

You can contact us for more information about the relevant safeguards, if they apply in your case.

9. RETENTION PERIOD OF PERSONAL DATA

We keep personal data only for as long as is necessary for the purposes of the processing, taking into account the nature of the service, our contractual obligations, the applicable limitation periods and the legal obligations to keep records.

The retention period may differ depending on the category of data and the service:

• Simple requests for information or an offer: for the period required for the reply, the follow-up of the request and the documentation of the communication, if justified.
• Insurance services: for the period required for managing the cooperation and keeping the relevant regulatory, contractual and legal obligations.
• Investment or savings products: in accordance with the obligations of the competent body and the applicable requirements of regulatory compliance and record keeping.
• Energy and telecommunications services: for as long as is required to complete the request, manage the related transaction and fulfil the corresponding obligations.
• Accounting, tax and transaction records: for the periods imposed by the legislation in force.
• Consents to promotional communications: for as long as the consent is active or another legal basis for communication exists, and until it is withdrawn or ceases to apply.
• Technical and security logs: for the period required for security, the handling of incidents and the protection of our systems.
• Applications to work with us (Globy+ advisors): up to 24 months from receipt of the application, as described in section 3.7.

After the appropriate period has passed, the data are securely deleted or anonymised, unless their further retention is lawfully required or permitted, for example for establishing or defending legal claims.

Backups of the database and files delete themselves within 90 days.

We do not apply a single, arbitrary retention period to all categories of data. The duration is determined on the basis of the specific purpose and the applicable legal requirements.

10. SECURITY AND CONFIDENTIALITY

We take appropriate technical and organisational measures to protect personal data against unauthorised access, unlawful processing, loss, alteration, destruction or improper disclosure.

The security measures are adapted to the nature of the data, to the risks of the processing and to the technical possibilities and obligations that apply. They may include controlled access, restriction of user rights, procedures for the secure management of information and appropriate contractual obligations for our partners.

Access to the data is allowed only to persons who need to know them in order to carry out their duties and who are bound by obligations of confidentiality.

Despite reasonable and appropriate measures being taken, no information system or means of electronic transmission can be regarded as absolutely secure. In the event of a personal data breach, we apply the procedures provided for by the legislation in force, including informing the competent supervisory authority and the persons affected, where this is required.

11. YOUR RIGHTS UNDER THE GDPR

Subject to the legal conditions and limitations, you have the following rights in relation to your personal data:

11.1. Right to be informed

To be informed in a clear and transparent way about the processing of your personal data.

11.2. Right of access

To ask for confirmation of whether we process data concerning you and, if so, to obtain access to the data and to the information provided for by the GDPR.

11.3. Right to rectification

To ask for the correction of inaccurate data or the completion of incomplete details.

11.4. Right to erasure

To ask for the erasure of your personal data when the legal conditions are met. This right is not absolute and may not apply, for example, when retention is required by law or for establishing, exercising or defending legal claims.

11.5. Right to restriction of processing

To ask, under the conditions of the law, for the restriction of the processing of your data.

11.6. Right to data portability

When the processing is based on consent or on a contract and is carried out by automated means, to receive the data you have provided in a structured, commonly used and machine-readable format and, where technically feasible and the legal conditions are met, to ask for them to be transmitted to another Controller.

11.7. Right to object

To object, on grounds relating to your particular situation, to processing that is based on a public task or a legitimate interest, in accordance with the conditions of the GDPR.

When the data are processed for direct marketing, you have the right to object at any time, including to the related profiling. After your objection, the data will no longer be processed for that purpose.

11.8. Right to withdraw consent

When the processing is based on your consent, you can withdraw it at any time, without affecting the lawfulness of the processing carried out before the withdrawal.

11.9. Rights relating to automated decisions

When the conditions of Article 22 GDPR are met, you have the right not to be subject to a decision that is based solely on automated processing, including profiling, and produces legal effects or similarly significantly affects you, subject to the legal exceptions and safeguards.

11.10. How you exercise your rights

You can submit a request through the official contact details stated in section 2, with the subject "Exercise of a GDPR right".

We may ask for additional information only to the extent necessary to confirm your identity and protect your data.

We answer requests in accordance with the time limits of the GDPR, as a rule within one month of receiving them. The time limit may, under the conditions of the law, be extended, in which case we will inform you.

The exercise of the rights is in principle free of charge. A reasonable fee may be charged or a request may be refused only in the cases permitted by the GDPR, such as manifestly unfounded or excessive requests.

12. AUTOMATED PROCESSING AND PROFILING

For certain services, electronic systems or tools may be used that organise, classify or assess information, such as for presenting available offers, processing requests or analysing needs.

For example, insurance companies or financial bodies may apply automated rules for assessing risk, suitability or appropriateness, depending on the product and the regulatory framework in force.

The existence of automated processing does not necessarily mean that a decision is taken solely by an automated system, nor that every processing operation is profiling under the GDPR.

Where a decision is to be taken solely by automated means that falls within Article 22 GDPR, the required information is provided and the appropriate safeguards are applied, such as the right to human intervention and the possibility to express a point of view and contest the decision, if provided for by law.

For more information about a specific automated procedure, you can contact us.

13. COMMERCIAL COMMUNICATIONS AND PROMOTIONAL MATERIAL

If there is an appropriate legal basis, we may send you updates about services or products of GlobyPlus, offers, news, useful information and promotional material related to insurance, investment, savings, energy or telecommunications services.

The communications may take place by email, SMS, telephone or other lawful channels.

When prior consent is required, communication for promotional purposes will take place only after it has been given. Consent to promotional communications is separate from the acceptance of the Terms of Use or the submission of a request for a service.

You can stop promotional communications at any time, by following the unsubscribe link included in the relevant message, where provided, or by contacting us. This choice does not affect the necessary transactional or legal notices related to an existing cooperation.

We do not pass your data to third parties for their own independent advertising activities without the appropriate legal basis and the required information or consent.

14. COOKIES

The website uses only strictly necessary cookies and similar technologies (local storage), that is, those required for its secure and proper operation. We do not use statistical analysis, advertising or tracking cookies, and we do not track the pages you visit.

Because strictly necessary cookies do not require consent, no cookie choice message is shown. You can delete or block them from your browser settings; in that case certain functions of the website may not work properly.

The cookies and similar technologies (local storage) used:

If in the future we use other cookies, we will update this section and, where required, we will first ask for your consent.

15. DATA OF MINORS

The services of GlobyPlus are not as a rule addressed to minors for the independent provision of financial, insurance or other services that require legal capacity to contract.

However, the processing of a minor's details may be required in the context of a lawful insurance or other transaction carried out by a parent, a person exercising parental responsibility, a legal representative or another authorised person. In these cases, the processing takes place only if there is an appropriate legal basis and the applicable safeguards for the protection of minors are observed.

If we become aware that a minor's data have been submitted without the required legal basis, we will examine the matter and take the appropriate measures, including erasure where this is required or permitted by law.

16. LINKS TO THIRD-PARTY WEBSITES

Our website may include links to websites, platforms or services of third parties, such as insurance companies, financial bodies, energy or telecommunications providers.

These websites operate in accordance with their own privacy policies and their own terms of use. We do not necessarily control the data processing practices of third parties and we recommend that you read the relevant policy before providing personal data to them.

The existence of a link does not automatically mean that GlobyPlus approves all the content or the practices of the linked website.

17. LODGING A COMPLAINT WITH THE DATA PROTECTION AUTHORITY

If you consider that the processing of your personal data infringes the GDPR or the applicable legislation, you can contact us so that we can examine the matter.

You also have the right to lodge a complaint with the competent supervisory authority, in Greece the Hellenic Data Protection Authority (ΑΠΔΠΧ).

Official website: https://www.dpa.gr/

Contact details, instructions and the available ways of lodging a complaint are provided on the official website of the Authority.

18. AMENDMENTS TO THE POLICY

This Policy may be amended when our services, the technologies we use, our processing practices or the applicable legal and regulatory framework change.

The updated version will be posted on the GlobyPlus website, with a reference to the date of the last update. If there is a material change that requires specific information, we will take the appropriate measures to inform you in accordance with the legislation.

We recommend that you check this Policy periodically, so that you stay informed about the way we process your personal data.

19. CONTACT ON PRIVACY MATTERS

For questions, requests or clarifications about this Policy and the protection of your personal data, you can contact GlobyPlus through the official contact details stated in section 2.

Please state your request clearly, so that we can examine it and answer you in accordance with the legislation in force.

Globy+

The protection of your personal data is an integral part of our commitment to responsible, transparent and reliable service.