INFORMATION POLICY ON PERSONAL DATA PROCESSING

1. Introduction and Data Controller

ERRIZA, functioning as a cultural initiative in the process of incorporation as a Non-Profit Civil Partnership (AMKE) based in Athens, Greece, serves as the Personal Data Processing Officer. In strict compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Greek Law 4624/2019, ERRIZA is committed to the protection of the personal data of its visitors and service users.

This policy applies to all natural entities interacting with ERRIZA via its website, errizaculture.com. Our processing is governed by the principles of legality, transparency, and data minimization.

2. Categories of Data Collected and Purpose of Processing

ERRIZA collects only the data necessary for the optimization of our digital presence and the promotion of our cultural objectives. Specifically:

• Newsletter & Communications: Should you choose to subscribe to our newsletter, we process your e-mail address to keep you informed of ERRIZA’s news, activities, and upcoming cultural programs, exhibitions, and events. This processing is based on your explicit consent.
• Analytics & Site Optimization: We utilize Google Analytics & other tracking programs to receive information regarding the way you navigate our site. This includes your IP address, browser type, and duration of visit. This data is used collectively and anonymously to improve the performance of our webpage.
• Advertising & Promotion: We utilise Google Ads and related tracking technologies to provide you with content that aligns with your interests. This allows us to measure the effectiveness of our communication strategies.
• Direct Communication: If you contact us via email, we process your name and contact details solely to fulfill your request.

3. Legal Basis for Processing

ERRIZA ensures that every processing activity is grounded in a valid legal basis:

1. Consent: For your subscription to the newsletter and the placement of marketing cookies.
2. Legitimate Interest: For the technical maintenance of the website and the statistical analysis of site traffic to improve our services.
3. Compliance: As required for ERRIZA to meet any future legal obligations under Greek and European law.

4. Data Recipients and International Transfers

Respectful of your privacy, ERRIZA does not disclose, sell, or trade your personal data to third parties for their own commercial use.

Data is only accessible to authorized internal personnel and our strictly selected service providers (such as Google, Meta, Microsoft Clarity for analytics and advertising) acting as Data Processors. These partners are bound by contractual clauses to provide sufficient guarantees for the application of suitable technical and organizational measures. Any transfer of data outside the EEA (e.g., to Google servers in the USA) is conducted under the Standard Contractual Clauses approved by the European Commission.

5. Data Retention Period

ERRIZA retains your personal data only for as long as is strictly necessary:

• Newsletter data: Retained until you withdraw your consent (unsubscribe).
• Analytics data: Retained for a period of two (2) years, after which it is deleted or fully anonymized.
• Inquiries: Retained for the duration of our communication, and up to five (5) years thereafter to satisfy potential legal claims.

6. Technical and Organizational Measures

In accordance with Article 32 of the GDPR, ERRIZA implements high-level security protocols. Our website utilizes the Secure Socket Layer (SSL) protocol with robust encryption. We apply restricted access policies to ensure the confidentiality, integrity, and availability of your data against unauthorized access or accidental loss.

7. Your Rights as a Data Subject

Under the GDPR, you maintain full control over your data. You have the right to:

1. Access your data and receive information about its processing.
2. Rectify inaccurate or incomplete data.
3. Erase your data (“Right to be forgotten”) under specific conditions.
4. Restrict or Object to the processing of your data.
5. Withdraw Consent at any time, without affecting the legality of processing based on consent before its withdrawal.

To exercise these rights, please contact the ERRIZA Privacy Team at: info@errizaculture.com.

8. Recourse to Authority

Should you believe your data is being processed in breach of the law, you have the right to file a complaint with the Hellenic Data Protection Authority (HDPA):

• Address: 1-3 Kifissias Avenue, P.C. 115 23, Athens
• Website: www.dpa.gr

INFORMATION POLICY ON COOKIES

ERRIZA uses cookies to improve your online experience.

1. Technical Cookies: Necessary for the website’s basic functionality.
2. Performance/Statistics Cookies: (Google Analytics, Meta Pixel, Microsoft Clarity) These gather anonymous, collective information about how visitors use our site.
3. Marketing Cookies: Used to deliver advertisements that are relevant to your interests and to measure the effectiveness of our campaigns.

Managing Cookies: You may withdraw your consent or modify your preferences through your browser settings. For detailed instructions, please visit www.allaboutcookies.org. Note that disabling certain cookies may affect the functionality of our website.

1. Introductory Statement

ERRIZA, in its commitment to providing a refined and functional digital environment, utilises “cookies” and similar technologies (pixel tags, web beacons) on its website errizaculture.com. This policy is formulated in accordance with the General Data Protection Regulation (EU) 2016/679 and the current national legislative framework, ensuring that visitors remain fully informed and in control of their digital footprint.

2. Definition and Function

Cookies are small text files stored by the browser on your computer or mobile device. They serve as a memory for the website, allowing it to recognize your device upon return and to facilitate a more personalized browsing experience.

3. Classification of Cookies used by ERRIZA

ERRIZA categorizes the cookies utilized into the following distinct groups:

• Strictly Necessary (Technical) Cookies: These are essential for the technical operation of the website. They allow you to navigate the pages and use basic features. Without these, the website cannot function with the required security and efficiency. Legal Basis: Legitimate Interest (Art. 6 par. 1f, GDPR).
• Performance and Statistics Cookies (Google Analytics, Meta Pixel, Microsoft Clarity): ERRIZA utilizes Google Analytics and others to gather collective, anonymous data regarding visitor behavior (e.g., most visited pages, duration of stay, error reports). We use this information exclusively to improve the performance and design of our platform.
  • _ga: Used to distinguish users (Retention: 2 years).
  • _gid: Used to distinguish users (Retention: 24 hours).
  • _gat: Used to throttle request rate (Retention: 1 minute). Legal Basis: Explicit Consent (Art. 6 par. 1a, GDPR).
• Marketing and Targeting Cookies (Google Ads / Tracking Pixels): To support our cultural outreach, we use marketing cookies to deliver content and advertisements that align with your interests. These cookies help us measure the efficacy of our communication campaigns and limit the frequency of displayed advertisements. Legal Basis: Explicit Consent (Art. 6 par. 1a, GDPR).

4. Third-Party Processors

While ERRIZA does not sell or lease your data to third parties, the use of Google Analytics and Google Ads involves the transmission of certain technical identifiers to Google Inc. as a Data Processor. These services are used under strict confidentiality agreements and in compliance with the Standard Contractual Clauses for international data transfers.

5. Control and Withdrawal of Consent

The visitor maintains the absolute right to modify their cookie preferences at any time.

• Consent Management: Upon your first visit, a clear choice is provided to “Accept” or “Decline” non-essential cookies.
• Browser Settings: You may configure your browser to block all cookies or to notify you when a cookie is being set. Detailed instructions for managing cookies can be found at www.allaboutcookies.org.

Please be advised that the rejection of performance or marketing cookies will not affect your access to ERRIZA’s core content, though it may limit the personalisation of your experience.

6. Policy Revisions

ERRIZA reserves the right to amend this Information Policy on Cookies to reflect changes in our operational practices or the legal landscape. The most current version will always be available at errizaculture.com.