PRIVACY POLICY

“INVAKT PROPERTIES SINGLE MEMBER PC.” (hereinafter referred to as “the Company”), a single-member private limited liability company duly registered under the laws of Greece, operates under the corporate name “INVAKT PROPERTIES P.C.” and the distinctive titles “INVAKT” or “invakt.”, for corporate purposes regarding property management services, either for a fee or pursuant to a contract, with its registered office located at 38 Tsimiski Street, Thessaloniki, P.C. 54624, Greece, and can be contacted via email at info@invakt.com .The Company is the exclusive owner and lawful operator of the real estate consulting services website accessible at www.invakt.com. INVAKT places paramount importance on data protection and privacy compliance. Accordingly, the Company adheres to stringent security measures to safeguard the collection, processing, and storage of any personal data provided by users, ensuring the highest standards of confidentiality and integrity in accordance with applicable legal frameworks.

The processing and protection of personal data belonging to customers and visitors of this website shall be governed by: (i) the provisions set forth in this Privacy Policy; (ii) applicable national legislation; (iii) relevant European Union regulations; and (iv) pertinent international conventions regarding the protection of individuals with regard to the processing of personal data, as may be in force from time to time.

Any potential future legislative regulation on this matter will be incorporated into this Privacy Policy. In any case, the company reserves the right to amend the terms of personal data protection in order to comply with the applicable legal framework.

Therefore, these personal data protection terms may be subject to revision and update at any time. For this reason, we recommend that you periodically review these terms for any changes, as the continued use of the website implies your acceptance of all possible modifications.

By using the website www.invakt.com, providing us with your personal data, and expressly consenting upon your registration as a user, you acknowledge that you have been fully and clearly informed of the terms included herein, that you are aware of your legal rights, and that you consent to the processing of your personal data by the company.

1.What constitutes personal data;

The term “Personal Data” refers to any information relating to an identified or identifiable natural person (“Data Subject”). Such data may directly (e.g., full name, identification number) or indirectly (e.g., phone number, online identifiers, location data) disclose the identity of the Data Subject. Consequently, personal data encompasses, but is not limited to, the following categories of information: email addresses, residential addresses, user credentials, personal preferences, and consumer purchasing patterns.

The Data Subject is defined as the identified or identifiable natural person to whom the Personal Data pertains.

2. What is data processing?

Data processing refers to any operation or set of operations performed on personal data or sets of personal data, whether by automated means or otherwise. Such operations include, but are not limited to, the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, and destruction of personal data.

Any natural or legal person, public authority, agency or other body which, whether in the public or private sector, that determines the purposes and means of processing personal data is referred to as the data controller.

Any natural or legal person, whether in the public or private sector, that processes personal data on behalf of the data controller is referred to as the data processor.

3. What Data Do We Process?

The website www.invakt.com is designed to allow you to visit it without being required to provide your personal data, unless you voluntarily choose to do so.

«INVAKT PROPERTIES P.C», as the data controller, collects the personal data of visitors/users of the aforementioned website only when they voluntarily provide it and solely for the processing purposes stated herein.

Our company collects four types of customer/supplier information:

1. Information provided by the visitorwhen registering as a user.
2. Information provided by the visitor/userwhen subscribing to the company’s newsletter service.
3. Information provided by the visitor/userthrough cookie consent.
4. Information provided by visitors/userswhen completing the special interest form for investment opportunities.

The personal data collected may include the following:

• Full name
• Residential address
• Postal code
• Email address
• Contact telephone number
• IP address

4. What is our cookie policy?

This website uses cookies to enhance the services we offer and to provide you with certain features that may be useful.

Cookies are small text files stored on the hard drive of each visitor/user. They do not access any documents or files on your computer. They are used to facilitate visitor/user access to specific website services or pages, and for statistical purposes. These data may also include the type of browser used, the type of computer, the operating system, internet service providers, and similar information. Additionally, the website’s information system automatically collects details about the locations visited by the user and links to third-party websites accessed through the site.

This website uses four different categories of cookies:

1. Necessary
   These cookies are essential for the proper functioning and security of the website. They are mandatory and cannot be disabled on this site.
2. Statistical
   We use statistical cookies to improve the quality of our online services by analyzing data and statistics (analytics), conducting research via survey pop-ups, and monitoring website performance and availability. These cookies help website owners understand how visitors interact with the pages by collecting and reporting information anonymously. They are optional, and you can opt out of their use by adjusting your preferences in the “cookie settings.”
3. Preference
   These cookies allow the website to store login credentials for future visits. They enable the website to remember information that alters how it behaves or appears, such as your preferred language or location. Additionally, they enhance your user experience by storing specific choices. These cookies are optional, and you can opt out of them in the “cookie settings.”
4. Marketing
   To optimize your browsing experience, these cookies track visited pages and provide personalized content. They may also result in targeted advertisements when visiting other websites beyond invakt.com. Additionally, they enable social media sharing of pages that interest you.

Our site may display content from external providers (e.g., YouTube, Facebook, Twitter). To view such content, you must first accept the terms and conditions set by these providers, including their cookie policies (which are beyond our control). If you do not view embedded content, no third-party cookies will be placed on your device.

If you do not wish to store cookies on your device, you may manage them through your browser settings by deleting existing cookies, selectively accepting or rejecting specific cookies, or blocking all future cookies. Please note that such restrictions may impair the functionality of certain website features. We use only those cookies for which you have provided explicit consent.

For further information on cookies and their applications, please visit www.allaboutcookies.org.

5.How Does the Newsletter Service Work?

Our company provides website users the option to receive a newsletter at their email address, provided they expressly indicate their wish to use this service. The newsletter distribution fully complies with email marketing regulations, and we ensure you that we will not misuse this service.

We use Mailchimp to manage our newsletter distribution. During user registration, you may opt to subscribe to our newsletter. If selected, you will receive a confirmation email to your provided address, requiring your explicit consent for periodic newsletter delivery.

To ensure your data security, we have established a Data Processing Agreement with Rocket Science Group LLC (Mailchimp’s parent company) as the data processor, in accordance with: Mailchimp’s Data Processing Addendum.

The user of the service may, at any time and under any circumstances, request to stop receiving promotional messages, as each message includes an option to withdraw consent. For any issues that may arise, you can contact the company either via email at info@invakt.com or through the customer service line at +30 2310250728.

6. For What Purpose Do We Process Your Data?

We collect and process your personal data exclusively for the following purposes:

1. To establish, maintain, and execute our contractual relationship
   The data you provide will be used for the proper preparation and execution of service agreements and related actions (e.g., sending invoices, customer identification when necessary, payment management, etc.).
2. To promote and advertise investment opportunities
   We may request your consent to use your data to send you targeted material, general advertising messages, and promotional content regarding new projects or special offers from our company (via mail, email, fax, SMS, etc.).
3. To inform and update you about your investment progress and property management. Your data will be processed to provide updates on the status of your investments and the management of properties under your ownership.
4. Statistical Analysis.The personal data for which you have provided your consent enable us to monitor and analyse website traffic, visitor habits and preferences, and demand for available investment opportunities.
5. To comply with legal obligations
   As the data controller, our company processes your personal data to adhere to applicable legal requirements (e.g., issuing receipts, accountability principles, minimum data retention periods, etc.).
6. What is the Legal Basis for Processing Your Data?

The collection and processing of your personal data is conducted to support and monitor your transactional relationship with our company, to prepare and execute our contractual agreement, and to provide you with optimal service. This processing has as its legal basis your prior explicit consent regarding both the specific categories of data and the purposes of processing, in full compliance with all applicable data protection legislation.

8. Who Are the Recipients of Your Data?

The recipients, to whom your personal data are disclosed, include: (a) INVAKT PROPERTIES P.C.’ and its essential personnel bound by confidentiality obligations; (b) partner companies acting as data processors on our behalf and in accordance with our instructions; and (c) public or judicial authorities or independent regulatory bodies when mandated by applicable law, prosecutorial directive, or judicial order.”

9. How Do We Ensure Processors Respect Your Data?

Our data processors are contractually bound to:

• Maintain strict confidentiality;
• Refrain from sharing data with third parties without our explicit authorization;
• Implement appropriate security measures;
• Comply with all applicable data protection legislation; and
• Process data only within the scope and purposes expressly permitted by our company.

All contractual agreements with processors incorporate these binding obligations to ensure full compliance with GDPR requirements and safeguard your personal data.

10. For How Long Do We Retain Your Data?

We collect and retain personal data of our website’s customers and suppliers only for the strictly necessary period required to achieve the specified processing purposes, following which such data is permanently deleted. The retention period is governed by applicable legal requirements, with our company maintaining the data for at least the duration of our contractual relationship plus any subsequent period during which legal claims might arise from said relationship. Where justified by evidentiary needs in judicial proceedings concerning contractual performance or to comply with official directives from regulatory bodies, data retention periods may be extended accordingly.

11. Is Your Data Secure?

Our company is committed to safeguarding your personal data. To protect the personal data of visitors/users of our website, we utilize a secure connection (https://) via SSL (Secure Sockets Layer) technology. Our business employs the SSL protocol for its e-commerce platform to ensure secure online transactions. This ensures that all personal information provided by the visitor/user—including credit card numbers, names, and addresses—is encrypted, preventing unauthorized access or alteration during transmission over the Internet.

The SSL (Secure Sockets Layer) protocol is a globally recognized Internet standard for authenticating websites and encrypting data exchanged between users and web servers. In an SSL-encrypted communication, all transmitted data between a client and a server is encrypted by the sender’s software and decrypted by the recipient’s software, thereby safeguarding personal information during transfer. Additionally, all data transmitted via SSL is protected by an automated mechanism that detects any tampering during transmission.

We further implement all necessary data security measures to mitigate risks of loss, misuse, unauthorized access, or disclosure of personal information. These measures are periodically reviewed and updated as deemed necessary.

The present website, www.invakt.com , is secured with an SSL certificate issued by Let’s Encrypt X3, a freely available, automated certificate authority under the Internet Security Research Group (ISRG).

Processing of visitor/user data is permitted only by authorized personnel, employees, or partners acting on our behalf and strictly for the purposes outlined herein. All employees are bound by confidentiality obligations, and as noted above, our company ensures that any data processors acting on our behalf comply with applicable requirements and provide sufficient guarantees for the protection of visitors’/users’ personal data.

The Company shall not sell, transfer, or otherwise disclose your personal data to any third parties unrelated to its operations without your explicit prior consent, except as mandated by applicable law or to duly authorized regulatory authorities.

12. What Are Your Legal Rights?

Regarding the protection of your personal data, you are entitled to the following rights:

• Right of Access:You are entitled to request and receive full disclosure regarding the personal data we process about you. This includes, but is not limited to: (a) the specific categories of personal data under our custody or control; (b) the lawful purposes and legal basis for such processing; (c) the sources of such data (where obtained indirectly); and (d) any third-party recipients of such data. Upon verification of your identity, we will provide one electronic copy of your personal data free of charge. For any subsequent or excessive requests, we may impose a reasonable administrative fee based on actual costs incurred.
• Right to Rectification: If you identify inaccuracies or incompleteness in your data, you may request that we correct or supplement such data.
• Right to Erasure (“Right to Be Forgotten”): You may request the deletion of your data where it is no longer necessaryfor the purposes for which it was collected. Additionally, you have the right to request erasure if you withdraw your consent to processing, provided no other lawful basis for processing exists.
• Right to Restriction of Processing: You may request the restriction of processing where:
  • The accuracy of the data is contested;
  • Processing is unlawful; or
  • You have objected to processing (pending verification of overriding legitimate grounds).
    If you raise an objection, we will cease processing your data unless compelling legitimate grounds for continued processing are demonstrated. Processing for direct marketing purposes does not constitute a legitimate ground.
• Right to Data Portability: You may request to receive your data in a structured, commonly used, and machine-readable formator to have it transmitted directly to another data controller, where technically feasible.
• Right to Object: You may objectto the processing of your data or withdraw your consent at any time. In such cases, we will immediately cease processing, unless overriding legal or imperative reasons exist.
• Right to Lodge a Complaint:Should you consider that your data protection rights have been infringed, you retain the right to submit a formal complaint to the Hellenic Data Protection Authority (DPA), located at 1-3 Kifisias Avenue, 115 23 Athens, Greece, which may be contacted via telephone at +30 210 6475600, facsimile at +30 210 6475628, or electronically at complaints@dpa.gr.

13. How to Exercise Your Rights

To exercise your rights, you may submit a written request via email to info@invakt.com, clearly indicating in the subject line the specific right you wish to exercise (e.g., “REQUEST TO EXERCISE RIGHT OF ACCESS/RECTIFICATION/ERASURE/RESTRICTION/OBJECTION”) and providing a detailed description of your request. We will review your submission and respond as promptly as possible.

We process all requests free of charge within one (1) month of receipt. However, in cases involving complex or voluminous requests, we may extend this period by an additional two (2) months if strictly necessary, subject to prior notification to you. Our company reserves the right to decline manifestly unfounded or excessive requests, particularly those of a repetitive nature.