CONFIDENTIALITY TERMS

1. Confidential Information. This portal gives you access to information about the real estate property(ies) in which you have invested. All content made available through the portal, including construction reports, project and property documents, plans, manuals, images, videos, news and non-public commercial terms, and any details of individual bookings, stays or benefits communicated to you, is confidential information of MERCAN KERANIS RESIDENCES SINGLE MEMBER S.A., with its registered office at  137, Syggrou Avenue, 17121, Greece, GEMI no. 145537101000 ("Mercan") (the “Confidential Information”).

2. Use. You may use Confidential Information only to review and monitor your real property(ies). You may disclose Confidential Information on a need-to-know basisto your professional advisers, provided they are bound by a legal or contractual duty of confidentiality. Except as expressly permitted by these Confidentiality Terms, you must not copy, modify, disclose, reproduce, distribute or otherwise make available any Confidential Information to any other person or to the public. In particular you may not publish, post or share portal content, in whole or in part, on social media, websites, forums, chat groups or groups with any third parties.

3. Exceptions. This confidentiality duty does not apply to information that becomes public without a breach of confidentiality, that you already lawfully knew, or that you lawfully obtained from a third party without a duty of confidentiality, and does not prevent disclosures required by law, regulation, court order or request of a competent authorities.

4. Security. Your access is personal and non-transferable. Keep your credentials confidential, take reasonable measures to prevent unauthorised use of the Confidential Information, and inform Mercan immediately at investor.relations@mercangreece.gr if you become aware or suspect that it has been, or may be, disclosed to unauthorised persons. Mercan may suspend or withdraw access in case of breach of these Confidentiality Terms or where reasonably necessary to protect the security of the portal or its contents.

5. Intellectual property and nature of the content. All reports, documents, images, videos and any other content of the Portal remain the exclusive property of Mercan or its licensors, as applicable. No intellectual property rights are transferred to you by virtue of your access to or use of the portal. Portal content, including construction reports and other property-related content, is provided for information purposes only and reflects the latest approved status of the relevant as of the date of publication. Such content is indicative and subject to change, and does not constitute, and shall not be construed as, an amendment, supplement, representation, warranty or contractual commitment under the Reservation Agreement, the Investor Agreement, the Lease or any other agreement between you and Mercan.

6. Duration. The confidentiality obligations set out in these Confidentiality Terms shall continue to apply for so long as the relevant information remains non-public and confidential.

PRIVACY NOTICE

This Privacy Notice applies specifically to the portal accessible through the Mercan website at investor.mercangreece.gr/en/client/login (the "Portal") and informs you how MERCAN KERANIS RESIDENCES SINGLE MEMBER S.A., with its registered office at  137, Syggrou Avenue, 17121, Greece, GEMI no. 145537101000 ("Mercan", "we", "us" or "our") processes personal data in connection with your access to and use of the Portal. This Notice supplements the Mercan Greece Privacy Policy, available at mercangreece.gr/en/privacy-policy/, which provides further information about the processing of personal data by Mercan. In the event of any inconsistency between this Notice and the general Privacy Policy in relation to the Portal, this Notice shall apply to the Portal-specific processing described here.

1. Data Controller. Mercan is the controller of the personal data you provide and of the data generated when you use this Portal, including account sign-ins and downloads. For questions concerning the processing of your personal data or to exercise your rights, please contact us at legaldep.gr@mercangreece.gr.

2. Personal Data We Process. We may process identification and contact details (including email), account and authentication information, records of your use of the Portal (including sign-ins and downloads), and information contained in requests or forms submitted through the Portal. We may collect personal data directly from you, as well as use information already held by Mercan in connection with our contractual relationship with you.

3. Purposes and Legal Bases. We process and use your data to create, manage and maintain your access to the Portal, provide Portal functionality, maintain the security and integrity of the Portal and prevent unauthorised access or misuse, and to comply with applicable legal and regulatory obligations. Depending on the relevant processing activity, the applicable legal basis may be the performance of our agreement with you, our legitimate interests in operating and securing the Portal, or compliance with a legal obligation, in accordance with Regulation (EU) 2016/679 (GDPR) and Greek Law 4624/2019, as in force.

4. Service Providers and Recipients. Mercan Capital Portugal, S.A., with registered office at Rua Oliveira Monteiro 289, 4050-443 Porto, with tax number 516375660 (Portugal) may process personal data on behalf of Mercan in connection with the operation and administration of the Portal. Mercan may engage other service providers, including technology, and IT providers,web hosting and server infrastructure providers, cloud data hosting providers, web application management providers, customer relationship management (CRM) providers or property operators, and other service providers involved in providing Portal-related services. Such providers will process personal data only as necessary for the provision of their services and, where applicable, in accordance with Article 28 GDPR.

5. International Transfers. Where personal data is transferred outside the European Economic Area (EEA), Mercan will ensure that such transfers are carried out in accordance with Chapter V of the GDPR, including, where applicable, on the basis of an adequacy decision or appropriate safeguards provided for under applicable data protection law.

6. Retention. We retain personal data only for as long as necessary for the purposes for which it is processed, and, where applicable, for periods required by law or reasonably necessary for the establishment, exercise or defence of legal claims. 

7. Your Rights. You may request access to, rectification or erasure of your data, restriction of or objection to processing, and data portability, by writing to legaldep.gr@mercangreece.gr or to 137, Syggrou Avenue, 17121, Greece . You may lodge a complaint with the Hellenic Data Protection Authority (Kifissias 1-3, 115 23 Athens, contact@dpa.gr). 

Full details are in the Mercan Greece Privacy Policy mercangreece.gr/en/privacy-policy/.