Data Protection Policy
Data Protection Policy
Protecting your data is a priority for SBOING. At SBOING, we fully understand the importance of protecting the user’s personal data. That is why in SBOING take all necessary steps to ensure the security and proper management of user’s personal data.
By personal data we mean any information that concerns the user and through which SBOING can identify the user. This recognition can be made either through specific information or through a possible combination of the information available to SBOING.
In addition to other personal data, SBOING’s UltiNavi Application processes the traffic data as set out below. Traffic data means data processed in order to transfer communications to the electronic communications network or billing it. Traffic data is any computer data or other data relating to a communication by means of a computer program, computer, computer system, or network, generated by a computer program, computer, computer system, or network that form a part in the chain of communication, indicating the communication’s origin, destination, route, format, intent, time, date, size, duration, or type of underlying service.
In addition, SBOING’s UltiNavi Application, also processes location data.
Location data is defined as data that is processed on an electronic communications network or by an electronic communications service and indicates the geographical location of the user’s terminal equipment of a publicly available electronic communications service.
Such processing of user’s (individual’s) data is strictly regulated by the new General Regulation on the Protection of Personal Data (GDPR) and by specific legislation regulating their processing in the field of electronic communications (Directive 58/2002), which was incorporated into Greek law by Law 3471/2006.
Apart from SBOING, the user’s personal data may also be processed by SBOING’s business partners or third parties. However, we at SBOING, remain solely responsible for the security of the user’s personal data, taking all necessary measures. SBOING’s business partners are always selected based on the high technological and organizational level of security they offer. Before cooperating with any company, especially if SBOING’s cooperation involves the processing of user’s personal data, SBOING contractually commit them to ensuring a high level of protection of user’s personal data.
SBOING processes user’s data mainly within Greece and the European Union (EU) and/or the European Economic Area (EEA). In the event of SBOING’s work with companies outside the EU/EEA, they will only process user’s data following SBOING’s request and provided that they possess a European Commission’s competence decision or if appropriate clauses ensuring a high level of security with regard to processing user’s personal data exist.
We, at SBOING, work mainly with companies active in advertising and marketing, market research, IT, consulting, customer service and call center, and human resource management (HR) services.
Other recipients of user’s data, in order to promote, support and serve SBOING’s business relationship, may be SBOING’s trading partners, which may mediate the conclusion of a user’s agreement with SBOING, the Financial Institutions (Banks) through which the account of each user is paid as well as other telecommunications providers in the context of SBOING’s interconnection with them for the provision of Portable Navigation Services, based on GPS receivers and using static maps, for the purpose of billing or troubleshooting.
SBOING processes a user’s personal data in order to service that user’s contract with SBOING for the provision of Portable Navigation Services, based on GPS receivers and using static maps that is offered by SBOING’s UltiNavi Application. In order to apply for or sign an agreement for the provision of SBOING’s UltiNavi Application service the user needs to provide SBOING with his/her identity data (name, surname, address, VAT number, ID number, communication details, etc.), which SBOING will process.
When a user becomes a subscriber to the UltiNavi service, it is necessary for the provision of this service to process user’s traffic and location data (e.g., location data, etc.) in order to transfer user’s communication to SBOING network, to proceed with the billing of the navigation services provided, as well as to deal with any problems and to provide the user with customer service. As part of our SBOING network interconnection for the transmission of communication, SBOING may transfer a user’s personal data to other Information and Communication Technology network providers located in or outside the EU/EEA. Therefore such processing is effected in order for SBOING to be able to execute the contract between a user and SBOING and to provide that user with SBOING’s UltiNavi services and/ or even upon a request prior to the signing of the contract.
In the context of serving our contractual relationship, SBOING may contact a user by email or SMS or even by telephone to send updates/newsletters regarding the UltiNavi service of a contract with said user, such as to inform said user of the impending termination of his/her contract with SBOING which may result in changes to said user’s tariff plan. These messages do not contain any advertising content but are sent to serve and improve a user’s contractual relationship with SBOING. Obviously, a user may object to the transmission of these updates/newsletters, as described in each message sent by SBOING. Nevertheless, in such case, a user will not receive any updates from SBOING.
In addition to the execution of an existing agreement between a user and SBOING, SBOING may process a user’s personal data on another legal basis, such as a user’s consent. Specifically, SBOING may, following a user’s consent, process in combination said user’s personal data derived by different services—when they become available from SBOING—provided to said user, in order to create said user’s personal profile based on said user’s personal preferences.
Profiling is a form of processing of personal data by automated means, that SBOING may use to evaluate certain of user’s preferences, so as to predict products and services that a user might be interest to and send said user the relevant updates/newsletters/ads, based on said user’s interests.
Read the text providing consent that is available at:
Read the text providing withdrawal of consent that is available at:
If the user is underaged but above 16 years old, read the text providing parental consent that is available at:
If the user is underaged but above 16 years old, read the text providing withdrawal of parental consent that is available at:
Moreover, a contact details that a user provides to SBOING when said user enters into a contract for the provision of SBOING’s UltiNavi service or when he/she communicates with SBOING, as well as the phone, landline or mobile numbers that said user maintains, may be used by SBOING for the purpose of communication for advertising/promotion of SBOING’s products or services, according to the legislation in force (Law 3471/2006). SBOING can send a user promotional messages (e.g. via SMS, emails, push notifications, etc.) to the contact details that said user has disclosed to SBOING in an earlier transaction. SBOING will always give a user the right to object to the use of user’s contact information for the purpose of advertising or promoting SBOING’s services both during their collection (e.g. when entering into a contract with SBOING) and within each advertising message (email, SMS etc.).
SBOING may transfer a user’s personal data to the police or prosecutors or supervisory authorities, after it has received a legal request to comply under applicable law.
The personal data relating to a user’s identity, resulting from a user’s use of SBOING’s UltiNavi service is maintained for as long as a user is an active subscriber to SBOING’s UltiNavi service. In the event of termination or termination of a user’s contract, said user’s data is retained in SBOING’s systems for a period of five (5) years, subject to regulatory requirement.
Traffic data is retained for one (1) year’s invoicing and service. They may also be retained for other purposes after the termination of a user’s contract, such as in the event of a user’s debt or any pending complaint regarding the provision or pricing of SBOING’s services, and for a period specified by applicable law.
A user’s location data is maintained for three (3) months for the purpose of troubleshooting SBOING’s network and improving the service offered to said user.
Store closed circuit (CCTV) data at SBOING’s premises is stored for 15 days to protect people and goods.
After termination of a user’s contract with SBOING for any reason, and in the event of no outstanding debts or complaints on said user’s part, said user’s personal data may be retained if required by other applicable laws (e.g. for tax reasons) or if said user has given his/her consent to retention. Otherwise, said user’s data will be deleted in a way that is not technically possible to recover or will be anonymized.
Anonymization is the application of practices to personal information that render them anonymous, so that it is no longer possible to identify with this information what a user’s identity is. The use of anonymous data is extremely important to SBOING because it helps development of SBOING UltiNavi service’s understanding of each road section, of the average travelling time for every vehicle type, weather conditions, day of the week and time of day, and thus draw useful conclusions about the use of roads under real day-to-day and hour-to-hour situations and is also a useful tool in making the UltiNavi Application smarter and more useful to all its users.
At SBOING we provide the appropriate technical and organizational measures (TOMs) in business processes and apply them to the IT systems and platforms used to collect, process or use data. These are, indicatively:
- measures to prevent unauthorized persons from accessing data processing systems (access control).
- measures to ensure that data processing systems cannot be used by unauthorized persons (denial of access control).
- measures to ensure that persons authorized to use data processing systems have access only to the data for which they are authorized, and that personal data may not be accessed , during processing, or use, or after their recording, transmission, copying, modification or deletion by unauthorized persons (data access control).
- measures to ensure that personal data cannot be transferred, copied, altered or removed by unauthorized persons during electronic transmission, or during transfer, or recording, and that it can be controlled and controlled by verification of the process performers to whom personal data has been transferred through data transmission equipment (data transmission control).
- measures to ensure that it is possible to retrospectively examine and verify whether and by whom personal data were entered, modified or deleted in data processing systems (data entry control).
- measures to ensure that personal data processed by third parties / contractors are processed only in accordance with our instructions (contractor control).
- measures to ensure that data collected for different purposes can be processed separately (separation rule).
A user (individual) of SBOING’s website and/or SBOING’s UltiNavi Application has the following rights:
- The right to be informed (art.13 & art.14 of GDPR): Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the GDPR.
- The right of access (art.15 of GDPR): Individuals have the right to access their personal data. This is commonly referred to as subject access.
- The right to rectification (art.16 & art.19 of GDPR): The GDPR includes a right for individuals to have inaccurate personal data rectified or completed if it is incomplete.
- The right to erasure (art.17 & art.19 of GDPR): The GDPR introduces a right for individuals to have personal data erased. The right to erasure is also known as ‘the right to be forgotten’.
- The right to restrict processing (art.18 & art.19 of GDPR): Individuals have the right to request the restriction or suppression of their personal data. This is not an absolute right and only applies in certain circumstances. When processing is restricted by the data subject, SBOING is permitted to store the personal data, but not use it.
- The right to data portability (art.20 of GDPR): The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. Doing this enables individuals to take advantage of applications and services that can use this data to find them a better deal or help them understand their spending habits. The right only applies to information an individual has provided SBOING as a controller.
- The right to object (art.21 & art.89 of GDPR): The GDPR gives individuals the right to object to the processing of their personal data in certain circumstances. Individuals have an absolute right to stop their data being used for direct marketing.
- Rights in relation to automated decision making and profiling (art.22 & art.89 of GDPR). The GDPR has provisions on automated individual decision-making (making a decision solely by automated means without any human involvement), and on automated profiling (automated processing of personal data to evaluate certain things about an individual) and protects individuals in case of automated decision-making and profiling that has legal or similarly significant effects on them. Profiling can be part of an automated decision-making process. SBOING can only carry out this type of decision-making and profiling where the decision is necessary for the entry into or performance of a contract or where it is authorized by Union or Member state law applicable or where it is based on the individual’s explicit consent.
A data subject may exert his/her right(s) through proper SBOING’s Forms addressed to SBOING and furnished to it via either one of the following means:
- By post to: SBOING Headquarters’ premises in the address 124 K. Karamanli Street, Diavata, 57008 Thessaloniki, Greece
- By email to: firstname.lastname@example.org
The user also reserves the right to submit a written complaint to the competent supervisory authority, the Hellenic Data Protection Authority located in 1, Kifissias Avenue, PO Box 23 23, Athens +30 210 6475600, contact email email@example.com.
Regarding Data Subject’s Right(s) Form, please download and fill in appropriately said form that is available here:
Regarding Data Subject’s Access Request Form, please download and fill in appropriately said form that is available here:
In the event of a user’s exercising of his/her right(s) SBOING will respond to user’s requests gratis without delay within one month of receiving the request. In exceptional cases this period may be extended by two (2) months if required due to the complexity of the user’s request. In any event SBOING will inform the user of this extension and the reason for the delay. If SBOING considered that a user’s request is manifestly unfounded or excessive, it reserves the right to request a reasonable fee for its satisfaction, taking into account administrative costs for its execution, or even refuse to respond to said user’s unfounded or excessive request.