Benaki Museum, established in 1930, is the first greek Institute-Private Law Body Corporate. Its main objects are to protect and to make known to the public of its various collections through a communication channel and exhibition, to support the scientific research in the fields of history, archaeology and the study of the material civilization, architecture, photography, plastic and performing arts and literature, to educate the public through permanent, periodic and touring exhibitions, courses, programmes, events, publications and means of open access, as well as to play an active part in the achievement of social cohesion, in the safeguarding of the universal cultural heritage and in the making of an intercultural dialogue.
As a Personal Data Processing Officer, within the General Data Protection (EU) Regulation 2016/679 dated 25.05.2018 (GDPR), the national legislation and the related directives of the Personal Data Protection Authority (PDPA), as each time applicable, Benaki Museum is committed to protecting the personal data of visitors,' service users, employees, workers, partners, volunteers and other natural entities, which are processed by authorised persons of the Museum, for reasons arising from the related dealing relations, legal obligations or legal interest of the Institute according to the circumstances.
Respectful of the privacy of the above natural entities and vigilant with regard to the confidentiality and safety of their personal data, Benaki Museum is hereby providing you with the following information on the personal data processing of visitors/users of its web page (type of personal data gathered by Benaki Museum, the processing way and the protection means thereof) and on your rights as a subject of such data processing.
This information policy addresses all the natural entities dealing with Benaki Museum via its website, including but not limited to the visitors of the Museum's web page, the customers making online purchases via the e-shop and the members of Benaki Museum, subscribed via its web page
In the everyday activities of the Institute, personal data processing is sometimes required as a result of a lawful requirement or is deemed necessary for reasons of lawful interest and improvement of the operational practice and quality of service of the Museum. Personal data processing means gathering, entering, organising, arranging, storing, altering, seeking information, using, transmitting, limiting or erasing personal data that have come or shall come to the knowledge of the Museum, either within your dealing relations with it or within the information furnished to the Museum by a third natural or legal entity or public sector agent in the exercise of the legal right thereof or of the Museum itself.
Benaki Museum acknowledges that in the exercise of its activities it is likely to be in possession of personal data of natural entities. In addition, in compliance with the applicable legislative framework, it has taken all the necessary actions by applying the suitable technical and organisational measures for legal compliance, the processing and the safe keeping of the personal data file, committed to securing and to protecting in every way the processing of your personal data against loss or leak, transmission or illicit processing thereof in any other manner.
To provide transparency in how your personal data are gathered, used and stored, Benaki Museum encourages its web page visitors and any person concerned to read this Information on the Personal Data Processing in order to be aware of the following:
1.What kind of personal data are processed by us and how we use them
Benaki Museum notifies the visitors/users of the web page that via its benaki.org web page it may gather information in relation to you, only if you furnish them and personal data, which are needed for establishing, maintaining and performing your dealings with Benaki Museum, whether currently or in the future, depending on the product or service provided and on the each time applicable procedures and policies of the Museum. In more detail, Benaki Museum gathers and processes at least the personal data below:
• your e-mail address, when input by you, in order to subscribe in the newsletter service and to receive the related updates and marketing actions/activities of Benaki Museum, including but not limited to events, training activities 'and to be kept posted about the news of Benaki Museum and other related activities;
• your e-mail address, name, surname, telephone number and domicile, when input and furnished by you, in order to become a member of Benaki Museum, and enjoy some privileges, depending on the type of your membership;
• your e-mail address, name, surname, telephone number and domicile and the details of your credit or debit card or Paypal account, when input and furnished by you, in order to purchase products or services available for sale on behalf of Benaki Museum through a specially designed e-shop;
in addition, to fulfill the needs of organization and promotion of its actions and activities, Benaki Museum keeps a photographic material and recording archive, the gathering and posting of which on the Museum's web page and in general, the disclosure of which is conditional on the free and explicit consent in advance to the above purposes of the natural entities' (subjects'), which are illustrated;
• lastly, we receive your IP address, whenever you browse on our web page, as well as in how you make use of our web page.
Gathering and processing the above personal data on behalf of Benaki Museum is necessary to establish, perform and maintain our dealing relation with you. Any objection you may express regarding the provision or processmg of your personal data may lead to your failure to establish or maintain/continue your existing dealing relation with the Museum.
2.Processing personal data of special categories («sensitive personal data»)
Benaki Museum shall not process either fundamentally sensitive personal data (special category data), such as data related to your race or ethnic origin, political convictions, religious or philosophical beliefs or participation in a syndicate, genetic or biometric data to identify you as a processing subject, or health data or data about your sexual life or sexual orientation, given that the above data are not needed for the fulfillment of the above purposes, by applying the principle of minimalisation, necessity and proportionality, as these are provided for in the GDPR.
3.Data related to minors
For the purposes hereof, minors mean those who have not reached their 18th year of age. Also, when the personal data processing is based on the consent indicated in art.6 par. 1f a), GDPR, in relation to offering services of communicating information directly to a child, the consent given by a minor and consequently, the processing, is lawful, if the minor is at least 16 years old. If the minor is below 16 years old, such processing is lawful only if and to the extent that said consent is provided or approved by the person that has the parental care of the minor (see art.8, GDPR).
As regards the legal basis of the each time processing of your personal data, Benaki Museum processes legal personal data, which are considered necessary for specific reasons and in particular:
• if you do not maintain a dealing relation with Benaki Museum, it is necessary to provide us with your consent in case you wish to subscribe in the newsletter service of Benaki Museum and to be updated on the activities and the promotions of the Museum. The specific form of your consent shall be provided by you freely and clearly and on the main condition that you have actively chosen to receive respective e-mails - newsletters;
• if the e-mail contact details, which were acquired lawfully, within the sale of products or services or other dealing, Benaki Museum reserves the right, within the exercise of its legal interest, to use them in promoting similar products or services directly or in serving similar purposes, even if the recipients of the respective e-mail have not provided their consent in advance;
• in relation to the purchase of products or services via Benaki Museum e-shops, the legal basis of your personal data processing is the product or service/dealing relation contract made between you and us;
• the personal data provided by you are gathered based on one or several of the legal bases below:
1) when it is necessary to process them in order to serve, support and monitor your dealing relations with Benaki Museum and to properly perform the contracts concluded between you and the Museum,
2) as required for the compliance of Benaki Museum with the legal requirements arising from the law,
3) as required for the pursuit of the legal interests of Benaki Museum ( or third parties), including our interests in providing innovative, individualized, safe and profitable services to the users and the partners of Benaki Museum,
4) where your personal data processing is needed for the fulfillment of the duties of Benaki Museum performed in the public interest, within the each time applicable legislative and regulatory framework,
5) according to a previous explicit consent that you have provided to us, if the processing is not established on some of the legal bases of processing indicated below.
5. Consent withdrawal
You are entitled to withdraw your consent at any time, where it is required, by making a withdrawal statement in writing and sending it to Benaki Museum whether physically or via e-mail, without affecting the legality of the processing based on it until the time of its withdrawal. You are also entitled to be updated on the stage of implementation of your request. Especially as regards the sending of newsletters, in any case, you are entitled to unsubscribe from every newsletter received by Benaki Museum.
6. Data retention time
Benaki Museum retains your personal data for as long as it is prescribed on a case-by-case basis in the each time applicable legislative and regulatory framework and throughout your dealing relation with us, but in any case for a period of twenty (20) years as of the last calendar day of the year of termination of your each time dealing relation between you and Benaki Museum, especially in case of any form of claim and for as long it is in effect. After the end of the above period, they shall be deleted in a safe and unrecoverable way.
• in relation to the information considered necessary at the time of your subscription in our services, such as your e-mail details, it shall be retained throughout the period of your subscription in the newsletter service of the web page or of the dealing relation maintained between you and us;
• as regards your personal data that you input with the purpose of purchasing products or services from Benaki Museum via the e-shop, they shall be retained for at least two (2) years, according to the proper provisions of the national legislation;
• posting photographic material on the Museum's web page and publishing it in general, shall be effected until any possible withdrawal of the consent of the illustrated persons and in any case for a period of two (2) years as of the posting of the respective photographic material or video.
In case of legal dispute, the personal data regarding you shall be retained in any case until the end of the pendency of proceedings even in the case of excess of the above period of twenty (20) years.
7. Who are the recipients of the personal data?
Respectful of the privacy of the visitors/users of its web page, Benaki Museum shall not disclose/transmit their personal data to third parties. The employees of the business and operational office of Benaki Museum shall have access to your personal data, within the proper performance and fulfilment of their contractual, legal and regulatory duties and under the status of absolute secrecy and confidentiality.
Then, Benaki Museuin may disclose/transmit to third legal entities ( domestic and foreign, but whatsoever in principle, within the EU limits), to whom it has assigned fully or partly on its behalf the processing of your personal data (Data Controllers), for specific reasons, such as the provision of mass e-mailing services, within the best possible service offered to you. The Museum duly assures the processing of your personal data by the partners- third companies with contractual clauses of restriction of the purpose of processing and provision of sufficient guarantees for the application of the suitable technical and organisational measures, according to the proper provisions of the GDPR, in order to ensure the proper and safe processing of your personal data.
8. International Transmissions of personal data
Benaki Museum shall not transmit your personal data directly to third (outside the EU) countries or international organisations, unless the transmission is imposed by the applicable regulatory or legislative framework or you have been notified and you consent in advance and explicitly with such transmission (in any of the cases this is required).
9. Subject's rights
In all cases, you have the control of your personal processing. In particular, according to the proper provisions of the GDPR, as a subject of personal data processing, you have the rights below:
1) Right to get transparent information, notice and regulation for the exercise of your rights (art.12, 13, 14, GDPR), regarding your right to be notified of how your personal data are used (as detailed in this Information).
2) Right to access the personal data regarding you and provided these are subject to processing by Benaki Museum, as Processing Officer, to the purposes thereof, the categories of data and the recipients or the categories thereof (art.15, GDPR).
It is noted that the Museum shall provide a copy of the personal data at your request, but for any additional copy it shall reserve the right to charge you with a reasonable fee.
3) Right to correct inaccurate data as well as filling in of insufficient data (art. 16, GDPR).
4) Right to erase your personal data («right to be forgotten»), subject to the obligations and legal rights of the Museum for retaining them based on the each time applicable legislative and regulatory provisions ( art.17, GDPR).
5) Right to limit your personal data processing provided, either the accuracy of which is contested, or the processing is illegal or the purpose of processing ceases to exist and on condition that there is no legal reason for retaining them ( art.18, GDPR).
6) Right to port your personal data to another processing officer, on condition that the processing depends on your consent and is carried out using' automated means. The fulfilment of such· right is subject to the legal rights and obligations of Benaki Museum with regard to the retention of data and the performance of its duty in the public interest (art.20, GDPR).
7) Right to object for reasons related to your special condition in case your personal data undergo processing for the performance of a task carried out in the public interest or in the exercise of power assigned to Benaki Museum or for the purposes of the legal interests sought by the Museum or a third party.
8) Right to withdraw the consent already given by you (art.7, GDPR) regarding the possibility to withdraw your consent anytime, in relation to a processing conducted based on the consent. The legality of your data processing shall not be affected by the withdrawal of your consent up to the point in time in which you have applied for withdrawal.
10. How to exercise your rights and file a termination
Benaki Museum reserves the right, after reviewing your request, to proceed within a reasonable period of thirty (30) days or more, in case of a reasonable delay, to the fulfilment thereof and on condition that this is legal and grounded. Before we provide you with personal data, we may ask you to identify yourself through a legal record and to give us sufficient information about your dealings, to enable us to locate your personal data.
Refusal or unreasonable delay on behalf of Benaki Museum in fulfilling your request in the exercise of your rights, entitles you to have recourse to the Personal Data Protection Authority, which is the lead inspection authority with regards to the application of the GDPR.
In any case, you maintain the right to file a termination to the lead inspection authority, if you believe that your personal data are processed in breach of the each time applicable legislation. For more information, please visit www.dpa.gr
If you wish to unsubscribe from any service or communication, we shall do everything within our power to erase your data as soon as possible, although we may need some time and/or information, before reviewing your request. Benaki Museum reserves the right to retain your personal data where a legal obligation, claim or fulfilment of conventional requirements exists.
11. Technical and organisational measures
Having regard to the safety and protection of your data, Benaki Museum makes sure that it takes sufficient and necessary technical and organisational means to secure both, the technological and the physical safety according to article 32 of GDPR (including but not limited to: encryption and regular testing, restricted access, cameras in special areas, special codes to authorised persons to access the databases, etc) and complies with the principles of processing in accordance with the GDPR, namely the principle of legality, objectiveness and transparency, the principle of restriction of purpose, the principle of data minimalisation, the principle of accuracy, the principle of limitation of storage period and the principle of integrity and confidentiality (art.5, GDPR).
In view to ensure your privacy, we apply the best practices of personal data assurance by implementing the necessary technical and organisational measures defined by the GDPR. Data are assured against loss of availability, integrity and confidentiality of information.
Lastly, Benaki Museum applies to its web page the Secure Socket Layer protocol (SSL) with solid encryption that ensures the confidentiality and the inviolability of the dealings and the personal data of the users.
Benaki Museum informs you about its continuous harmonisation and compliance with the terms of the General Regulation (EU) 2016/679 on the protection of natural entities against the personal data processing and on the free circulation of data and it always does its best to remain in compliance with it.
12. More special statements on behalf of Benaki Museum
• The Museum states that it shall be liable for any damage ( direct, indirect or material damage) that may be caused against visitors on the occasion of the website or use thereof. Visitors have exclusive responsibility for protecting their systems against viruses and malware;
• The Museum shall not take any decision or post any profile, based on your data automatic processing;
• The Museum states that it may, according to the each time applicable policy on data protection and within the each time applicable legislative and regulatory framework, revise or modify this Information, which shall always be updated and available on benaki.org. The Information Policy shall always be considered applicable, as it has been formed since the most recent modification;
• Please be advised that Benaki Museum uses «cookies» on its website aiming at improving your online experience. For details about the cookies, you may get information in the Policy on Cookies below;
• Users/visitors of the web page reading this shall take knowledge of the above processing that is in accordance with the Regulation 2016/679 and its reasoning, exclusively for the foregoing. purposes and for any compatible with those purposes.
13. Useful contact details:
1) Data controller contact details: BENAKI MUSEUM Address: 1, Koumbari street, 106 74 Athens
2) Personal Data Protection Authority details (PDPA, competent national Inspection Authority):
Headquarters: 1-3, Kifissias avenue, P.C. 115 23, Athens
Operator: +30 2106475600
Fax: +30 2106475628
INFORMATION POLICY ON COOKIES
1. Introductory notes
2. Definition of cookies
Cookies are small information files, which are placed from the visitors' /users' browser in the computer or portable device. Cookies' function is to allow a web server to transfer data to a computer or a portable device for keeping files or for other purposes. The information stored in the computer of the users/visitors of the web page may contain elements such as the pages visited by the users, when visited, as well as some random and unique number of users' recognition. Cookies help a website to offer the users a friendlier and more consolidated browsing experience.
3. What kind of cookies do we use?
In more detail, four (4) cookies (_ga, _gat, _gid, & collect) are included regarding the cookies of Google Analytics, an analysis service of Google, Inc. («Google»), which enter a unique ID (control of how any pseudonymisation or anonymisation is handled through Google Tag Manager-G'TM) for statistical reasons, regarding how the website is used by the users and how users' behave as well as the identification of users through multiple devices. The life span of the above cookies is two (2) years for _ga cookie, one (1) day for _gat & _gid cookies and session time for collect cookie.
Google may also transfer that information to third parties, when required by the law, or when the third partiesprocess the information on behalf of Google. Google shall not relate the IP address to other data kept by Google. More information about Google Analytics may be found on pages related to Google Service Terms and Confidentiality Policy.
Moreover, we use marketing cookies, namely cookies used in providing content that matches more to you and to your interests. These cookies may be used in sending targeted advertisements, in restricting the showing of ads or in measuring the effectiveness of some advertising campaign. They may also use the websites you have visited to enable us to specify which online marketing channels are more effective and to ·allow us to reward the external web pages and the partners that forwarded you to us.
4. How to check cookies
For further information about how you can manage cookies, please visit www.allaboutcookies.org/manage-cookies. Benaki Museum informs you that some tools of this website may not function normally, if you refuse using cookies.
5. Your rights
In any case, you have the control of your personal data processing. In particular, according to the proper provisions of the GDPR, as a subject of personal data processing, you have the rights, as reflected above.
7. Changes in the Information Policy on Cookies
Benaki Museum may modify this Information Policy on Cookies anytime, and it shall always be updated and available on benaki.org web page. The Information Policy shall always be considered applicable, as it has been formed since the most recent modification.