Data Protection relevant to Expression of Interest

  1. In the context of the evaluation of proposals of Expression of Interest, as described herein, HDBI may process personal data of the interested parties and of management teams/investors or any other individuals included in the Expressions of Interest, taking all the necessary technical and organizational measures to protect the confidentiality and security processing of this data.
  2. For the purposes of the present, as “Personal Data” is any information referred to individuals which is essential and is required and requested in the context of the present and any related documentation, including any additional information which may be requested by HDBI at a later stage, any information which is legitimately collected by HDBI from publicly accessible sources and generally any information which is furnished an interested party with their explicit consent (hereinafter: the “Data”).
  3. Data processing shall be carried out for the purpose of implementing the terms of this procedure and evaluating the submitted proposals and the Financial Intermediaries included in the Expressions of Interest, in accordance with the terms of this procedure; ensuring compliance with HDBI’s statutory obligations; attaining HDBI’s statutory objectives and; ensuring compliance with the applicable laws and the Agreements. HDBI may process Data principally on the basis of consent granted by each interested party in accordance with the terms of this procedure for the conclusion and implementation of the Management Agreement. As far as processing under the consent provided is concerned, each interested party may withdraw that consent at any time in writing (addressing HDBI at dpo@hdbi.gr for the attention of the Data Protection Officer) without affecting the legitimacy of processing based on consent prior to that withdrawal.
  4. Recipients of the data will be HDBI through its authorized representatives and the auditing and supervisory bodies of HDBI (primarily the competent departments of the Ministry of Development and Investments, and in general all persons who have competence to access and control the HDBI’s files pursuant to express provisions of law. HDBI may assign specific data processing tasks to third parties (data processors), bound by confidentiality undertaking, acting accordingly to HDBI’s instructions and may under no circumstances act for their own benefit.
  5. The Data shall be kept and stored by HDBI throughout the investment period as well as after their expiry/termination, for as long as may be necessary to ensure compliance with HDBI’s obligations and with the regulatory procedures applicable under law.
  6. The supply of Data to HDBI by each interested party is an essential requirement in order for HDBI to evaluate and approve each proposal through its Expression of Interest and meet its statutory obligations. Therefore, a refusal or withdrawal of consent of Data processing may result to HDBI’s inability to fulfil its statutory objectives and may cause the rejection of the Expression of Interest or prevent the implementation of the proposal that is included in it.
  7. Each interested party would be entitled to exercise all its rights accorded to it by the applicable law (specifically under Regulation (EU) 2016/679), and in particular the right to be informed of the Data which are to undergo processing by HDBI, the right of access to and rectification or erasure of their personal data, the right to object and the right of restriction of processing, the right of data transfer to another responsible or acting processor, subject to the terms and conditions applicable by law. In case of exercise of any of the above rights, HDBI shall take all necessary measures to satisfy the relevant request within the applicable deadline by law (30 days, which may be extended by two months) and shall notify the specific interested party in writing as to whether their request has been satisfied, or else stating any reasons preventing the enforcement or satisfaction of their rights. The above rights are to be exercised by means of a written request addressed to HDBI (+30-210-3387110 & email dpo@hdbi.gr).
  8. Each interested party reserves the right to file a complaint before the competent regulatory authority (Hellenic Data Protection Authority) against HDBI in relation to the processing of their Data.

For any additional information regarding protection of Data Protection as part of the Expression of Interest process, interested parties may contact Hellenic Development Bank of Investments S.A. +30-210-3387110 or vcfunds@hdbi.gr.