Privacy Policy

Implementing the General Data Protection Regulation (GDPR) is a priority for RELEVANCE DIGITAL S.A.

Data Controller

• Official Company Name: RELEVANCE DIGITAL S.A.

• Vat Number: 800478280

• Telephone: +30 2103210577

Η RELEVANCE DIGITAL S.A. accepts as personal data any information relating to an identified or identifiable natural person alive. For example, this information includes name, home address, I.D. number, Internet Protocol (I.P.) code, information about their health and insurance capacity, employment status, and more.

Special categories of data, such as health, racial or ethnic origin, trade union activity, etc., receive special protection.

The rules apply when collecting, using, and storing personal data digitally or in hard copy through a structured filing system.

This policy is in accordance with the E.U. General Data Protection Regulation (GDPR) and opinions/decisions issued by the Hellenic Data Protection Authority.

Terms and Definitions

1. ‘Personal means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. ‘Processing’ means any operation or set of operations which is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. ‘Restriction of processing’ means marking stored personal data to limit their processing in the future.

4. ‘Filing system’ means any structured set of personal data that are accessible according to specific criteria, whether centralized, decentralized, or dispersed on a functional or geographical basis,.

5. ‘Controller’ the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

6. ‘Processor’ means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

7. ‘Recipient’ means a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry by Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.

8. ‘Third party’ means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

9. ‘Consent’ of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

10. ‘Personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

11. ‘Special categories data’ means personal data disclosing racial or ethnic origin, political views, religious or philosophical beliefs, or trade union affiliation, as well as the processing of genetic or biometric data for health or data relating to a person's natural sexual life or sexual orientation.

Categories of Personal Data Collected

In the context of its activities and its regular operation, RELEVANCE DIGITAL S.A. may collect the personal data of its customers or associates, its employees, its associates in general, and other natural persons with whom it trades in the context of its operation. Depending on the form and purpose of processing per service, RELEVANCE DIGITAL S.A. may collect and process personal data, such as the following:

CATEGORIES OF DATA SUBJECTS

CATEGORIES OF DATA

Clients

Client data, whether natural persons or legal representatives of legal persons. These may include:

1. Identity and demographics (e.g., name, patronymic, etc.) 2. Contact information (e.g., postal address, telephone, Email, etc.) 3. Business information

4. Contracts

5. Account balances

6. Bank Accounts

7. CCTV data during their presence in our facilities

8. Personal data collected from clients in the context of their activities 9. Other relevant information

Suppliers / Contractors

The data of the company's suppliers, in the case of private entities or legal representatives of legal entities. These may include:

1. Identity and demographics (e.g., name, patronymic, etc.) 2. Contact information (e.g., postal address, telephone, Email, etc.) 3. Business information

4. Contracts

5. Account balances

6. Bank Accounts

7. CCTV data during their presence in our facilities

8. Other relevant information

CATEGORIES OF DATA SUBJECTS

CATEGORIES OF DATA

Employees (Active or Not) / Candidate Employees

Data of the company’s employees, under any employment relationship, and data of former and prospective employees, which are kept in official files or any other services to operate their employment relationship with the legal entity. These may include:

1. Identity and demographics (e.g., name, patronymic, etc.) 2. Insurance details (e.g., AMKA and other Social Security Authority details if required)

3. Contact details (e.g., postal address, telephone, Email, etc.) 4. CV’s

5. Health data (e.g., medical certificates and opinions, blood donation data, etc.)

6. Financial data (e.g., bank accounts, tax returns, statement of assets, etc.)

7. Marital status details (e.g., certificates and certificates, number and details of children, etc.)

8. CCTV data during their presence in our facilities

Data of other natural persons

The data of other natural persons who happen to visit the company’s facilities or belong to collaborating bodies.

Table 1. The categories of Data Subjects and their data

Purposes and Legal Basis of Processing

RELEVANCE DIGITAL S.A. may collect and process the personal data of the individuals mentioned in the preceding paragraph who use its services and products. In principle, RELEVANCE DIGITAL S.A. may collect and process personal data for the following purposes with the corresponding legal processing bases:

PURPOSE OF PROCESSING

LEGAL BASIS

The collection and processing of the necessary data of employees and/or prospective employees and associates for the proper service of existing employment or cooperation relationships or the consideration of possible future cooperation

1. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [Art. 6 §1 case. b) GDPR] and/or

2. Processing is necessary for compliance with a legal obligation [Art. 6 §1 case. c) GDPR] and/or

3. Processing is necessary for the purposes of the

legitimate interests [Art. 6 §1 case. f) GDPR]

4. Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law [Art. 9 §2 case. b) GDPR]

Provision of products and services

1. Processing is necessary for the performance of a contract [Art. 6 §1 case. b) GDPR] and/or

PURPOSE OF PROCESSING	LEGAL BASIS
	2. Processing is necessary for compliance with a legal obligation [Art. 6 §1 case. c) GDPR] and/or 3. Processing is necessary for the purposes of the legitimate interests [Art. 6 §1 case. f) GDPR]
Conclusion of trade agreements	1. Processing is necessary for the performance of a contract [Art. 6 §1 case. b) GDPR]
Commercial development and protection of the company's legitimate interests	1. Processing is necessary for the purposes of the legitimate interests [Art. 6 §1 case. f) GDPR]
Satisfaction of legal and regulatory obligations of the company	1. Processing is necessary for compliance with a legal obligation [Art. 6 §1 case. c) GDPR]
Operation of a video surveillance system for the protection of people and goods	1. Protection of persons and goods according to Directive 1/2011 of the Hellenic Data Protection Authority 2. Processing is necessary for the purposes of the legitimate interests [Art. 6 §1 case. f) GDPR]
For any other form of processing, RELEVANCE DIGITAL S.A. requests special written, free, and after prior informed consent of the subjects before the start of the processing, if required. Failure to provide personal data in the context of a legal or contractual obligation or requirement to conclude a contract may give rise to legal consequences or even an inability to service the contract. The overriding legitimate interests of the controller prevail over the interests or fundamental rights and freedoms of the data subject in the cases mentioned above and are based on the legal basis of Article 6 §1 par. f) GDPR and only for the cases of protection of persons and property of the company. In particular, in these cases, the company provides specific information to the persons whose personal data will be processed.

Table 2. The purposes and legal bases of processing

The reference to more than one legal basis of processing does not mean that RELEVANCE DIGITAL S.A. changes them (lawful basis swapping), undermining the rights of data subjects. However, there are cases where more than one legal basis is applicable.

Finally, RELEVANCE DIGITAL S.A. does not use the consent of the data subjects (whether it is simple data or special categories) as the main processing base, recognizing the inherent inequality that exists about the data subjects at any time and under the recommendations of its Working Group No. 29 (now European Data Protection Council). However, and exceptionally, for a few cases where additional service is provided to the subjects (beyond the legal ones), the consent is used to a limited extent as a legal basis for processing, and only then.

When the company intends to process personal data for a purpose other than that for which they were collected, it shall, as controller, provide the data subject with information for this purpose and other necessary information prior to such further processing.

Data Transfer to third parties

The personal data collected may be shared or transmitted to third parties as long as it is required to fulfill obligations by law or is necessary to perform our services provided in compliance with the guarantees of the relevant legislation. We may outsource some of our services to individuals or legal entities. Only the personal data necessary for the fulfillment of the assigned services are transmitted to these entities, which are committed to our company in terms of confidentiality and secure processing of personal data. In cases where a transfer of personal data outside the European Economic Area is required in the context of the company's activities, the requirements of the European Union Standard Contractual Clauses are complied with.

Data Retention

RELEVANCE DIGITAL S.A. retains your personal data for as long as the processing purpose lasts and after its completion, for as long as it is required by legal obligations arising from provisions of E.U. or National Law, or for as long as there are contractual obligations and possible legal claims between the parties.

Rights of Data Subjects

RELEVANCE DIGITAL S.A. recognizes individuals' rights concerning protecting their data. Thus, natural persons have the right to:

1. Be informed about the processing of personal data.

2. Gain access to their data subject to Article 33 of Law 4624/2019 restrictions. 3. Request the correction of incorrect, inaccurate, or incomplete personal data under certain conditions.

4. Submit a request for the erasure of personal data when it is no longer necessary or if the processing is unlawful, subject to the limitations of Art. 34 Law 4624/2019. If Article 6 § 1 cases c and e. GDPR and Article 9 § 2 caseς b, g, and j GDPR indent applies as the legal basis for processing, the right to erasure may be limited on a case-by-case basis, by the applicable provisions. According to Recital 4 of the GDPR, the right to protect personal data is not absolute; it must be assessed in terms of its function in society and weighed against other fundamental rights by the principle of proportionality.

5. Object to processing personal data for reasons related to their particular situation, subject to Article 21 § 6 GDPR and Articles 29 and 35 of Law 4624/2019.

6. Submit a request to restrict the processing of personal data without prejudice to Article 29 of Law 4624/2019.

7. Submit a request for portability subject to Article 29 of Law 4624/2019.

8. The user can withdraw his/her consent at any time, provided that the processing of their personal data is based on consent. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. File a complaint with the Personal Data Protection Authority (1-3 Kifissias Avenue, 11523 - Ampelokipoi, tel. 210.647.5600, email: complaint@dpa.gr) or with the supervisory authority of the E.U. Member State where they reside or work or with the supervisory authority of the place of the alleged infringement.

Communication

The above rights, as well as any rights related to personal data, are exercised upon a written request submitted to any point that is accessible to the public or via electronic communication by sending a message to dpo@relevancedigital.com and is also examined by the Data Protection Officer, as appointed by the company.

Processing principles

RELEVANCE DIGITAL S.A. accepts the basic principles governing the processing of personal data. According to Article 5 of GDPR, personal data shall be:

1. Processed lawfully, fairly, and transparently concerning the data subject ('lawfulness, fairness, and transparency').

2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall, by Article 89(1), not be considered to be incompatible with the initial purposes ('purpose limitation').

3. Adequate, relevant, and limited to what is necessary about the purposes for which they are processed ('data minimization').

4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate personal data, regarding the purposes for which they are processed, are erased or rectified without delay ('accuracy').

5. Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for more extended periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes by Article 89(1) subject to the implementation of the appropriate technical and organizational measures required by this Regulation to safeguard the rights and freedoms of the data subject ('storage limitation').

6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organizational measures (integrity and confidentiality) .

Records of processing activities

RELEVANCE DIGITAL S.A. maintains a record of the processing activities for which it is responsible. That record contains all the following information:

1. The name and contact details of the controller and, where applicable, the joint controller, the controller's representative, and the data protection officer.

2. The purposes of the processing.

3. A description of the categories of data subjects and the categories of personal data. 4. The categories of recipients to whom the personal data have been or will be disclosed, including recipients in third countries or international organizations.

5. Where applicable, transfers of personal data to a third country or an international organization, including identifying that third country or international organization and, in the case of transfers referred to in the second subparagraph of Article 49(1), the documentation of suitable safeguards.

6. Where possible, the envisaged time limits for erasure of the different categories of data. 7. Where possible, a general description of the technical and organizational security measures referred to in Article 32(1).

Protection of Personal Data

Considering the nature, scope, context, and purposes of the processing, as well as the risks of the different probability of occurrence and seriousness for the rights and freedoms of natural persons, RELEVANCE DIGITAL S.A. applies appropriate technical and organizational measures to ensure and be able to prove that the processing is carried out under the GDPR, adopting and implementing a holistic personal data security policy.

During RELEVANCE DIGITAL S.A.'s assessment of the appropriate security level, account shall be taken of the risks arising from the processing, particularly from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data transmitted, stored, or otherwise processed.

To prevent personal data breaches, RELEVANCE DIGITAL S.A., as the controller, has adopted and implemented a policy against attacks on the information systems it owns and manages and a specific policy for the management of any cases of personal data breaches.

Staff Training

RELEVANCE DIGITAL S.A. accepts that personal data protection presupposes the awareness of its human resources regarding it. In this regard, it accepts adopting and implementing the principle of proper education guidance using Fair Information Practices (FIP), which condenses a set of standards governing the collection and use of personal data and addresses privacy issues and accuracy. RELEVANCE DIGITAL S.A. seeks to raise awareness of fundamental concepts of personal data protection in its human resources.

Notification Regarding the Processing of personal data through Social Media RELEVANCE DIGITAL S.A. has an account on the following Social Media Platforms: • Facebook

• Instagram

• LinkedIn

• TikTok

• YouTube

We recommend that you consult the personal data protection policy of the Social Media in question before providing any consent. You are responsible for this processing if you upload your photos to our page on the above social network or additional personal data using your actions. Due to the ease of sharing pictures and other personal data on social networks, we recommend using them to assess the possible risks arising from their publication.

Our company does not and cannot exercise influence and control regarding the nature and extent of personal data collected and held by the social networks above as a condition or result of their use, and it bears no responsibility for collecting and processing personal data. For more information on the purposes of collection, further processing, and use of personal data by social networking platforms, as well as on the rights and available settings to protect your privacy and your data, please consult the privacy policy of the respective social networking platform.

Changes to this Privacy Policy

This policy may need to be amended to address the processing of personal data. Suppose the modification of the terms in question is of such nature and extent that the above data processing terms do not cover it. In that case, RELEVANCE DIGITAL S.A. must make the new version of the policy public.