Privacy Policy

Data Controller

• Official Company Name: RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion
  Marketing kai Psifiakou Metaschimatismou
• Vat Number: 800478280
• Telephone: +30 2103210577
• Εmail: [email protected] 

RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou defines personal data αny information relating to an identified or identifiable living natural person. This includes, but is not limited to, name, home address, I.D. number, Internet Protocol (IP) 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.
These rules apply when collecting, using, and storing personal data digitally or in hard copy through a structured filing system.
This policy complies is by the E.U. General Data Protection Regulation (GDPR) and official guidelines/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 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 that 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

As part of its operations, RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou may collect the personal data of its customers or associates, its employees, its associate’s 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou may collect and process personal data, such as the following:

Table 1. The categories of Data Subjects and their data 

Purposes and Legal Basis of Processing

RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou. may collect and process personal data for the following purposes with the corresponding legal processing bases:

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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 they were collected, it shall, as controller, provide the data subject with information for this purpose and other necessary information before 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou retains your 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 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: [email protected]) 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 [email protected] and is also examined by the Data Protection Officer, as appointed by the company.

Processing principles

RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou. 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 is 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou.'s assessment of the appropriate security level, the 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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.

Processing of Data via Artificial Intelligence

As part of its commitment to digital transformation and the optimization of its services, RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou may utilize Artificial Intelligence tools and Machine Learning systems. The use of these technologies is governed by the following principles:

• Transparency and Explainability: We are committed to informing data subjects when decisions affecting them are made or supported by automated AI systems, ensuring that the logic behind such processing is understandable.
• Purpose Limitation: The use of AI is strictly limited to data analysis for improving customer experience, predicting market trends, and automating administrative tasks, without prejudice to the rights and freedoms of natural persons.
• Privacy by Design and by Default: When training or deploying AI models, we implement anonymization, pseudonymization, and data minimization techniques. Personal data is not used to train third-party provider models without explicit consent or ensuring that the data has been rendered fully anonymous.
• Human-in-the-Loop: In cases where AI systems significantly impact data subjects, we guarantee the right of natural persons to obtain human intervention, to express their point of view, and to contest the decision.
• Security and Integrity: We apply advanced technical measures to protect AI systems from potential vulnerabilities or "adversarial attacks" that could lead to the unauthorized disclosure or alteration of personal data.

• Third-Party AI Providers: When utilizing external AI service providers (e.g., cloud-based generative AI or analytics tools), the Company ensures through Data Processing Agreements (DPAs) that these providers comply fully with the GDPR and do not utilize RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou’s data for their own independent purposes.

   

Staff Training

RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou 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.

Recruitment Privacy Policy

As the Controller of your personal data, RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou is committed to protecting and respecting your privacy. This Recruitment Privacy Notice defines the framework for processing the personal data you have provided to our company through your curriculum vitae (in-person submission, email without a prior job advertisement), your social media profile where you submitted your application (e.g., LinkedIn), or through a partner recruitment agency. Any data arising from the evaluation process of your application will be processed exclusively for the purpose of assessing your candidacy and evaluating your suitability for the position you expressed interest in, as well as for other available
positions within our company.

Legal Basis for Processing

The legal basis for the processing carried out in pursuit of the aforementioned purposes is your consent, in accordance with Article 6, Paragraph 1, point (a) of the GDPR (EU) 2016/679 (the data subject has consented to the processing of his or her personal data for one or more specific purposes). Your consent is documented by your positive action of submitting your data. Information we collect from you
Within the framework of the aforementioned process, we may process all or some of the following
types of information from you:

• Information provided during your application: This includes information submitted through job portals, via email, in-person submission of CVs, during interviews, and/or by any other method.
• Personal details: Such as name, email address, postal address, date of birth, as well as information regarding your professional background, qualifications, and experience provided to us.
• Correspondence: If you contact us, we may keep a record of that communication.
• Application Assessment Records: Documentation regarding the evaluation of your application through any recruitment process we may conduct.

Furthermore, please be advised that if you provide letters of recommendation as part of the evaluation process, we will contact the referees at the contact details provided, only upon your prior notification and with your express consent.

Automated Decision-Making

As part of the aforementioned process, we may utilize partner recruitment agencies to select suitable candidates based on criteria explicitly defined by us or deemed essential for the role for which you applied. While the process of identifying potential candidates may be automated, any decision regarding which candidates will be contacted for the position is made exclusively by our authorized personnel.

Data Retention Period

Your data is retained by our company until the decision to fill the respective positions has been finalized.
If you choose to allow us to retain your CV for re-evaluation in the event of another relevant job opening that matches your profile, we will keep it for a period of twelve (12) months upon your authorization.
Should you accept an offer of employment with us, the personal data collected prior to your hiring will become part of your personnel file and will be maintained throughout the duration of your employment.
Immediately thereafter, submitted CVs will be destroyed or deleted in a secure manner, unless the "Data Controller" is legally entitled or obligated to retain them. Furthermore, your data may be deleted at an earlier time upon your request to the following email address: [email protected].

Disclosure of Your Information

Access to your data is restricted exclusively to RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou and partner recruitment agencies (only in the event that you submitted your data through such an agency) within the scope of evaluating your application, at your request, for the purpose of establishing a professional collaboration with Relevance Digital SA.

Additionally, recipients of your data include electronic platform providers through which we manage your candidacy. These companies act as Data Processors for your personal data and are contractually bound to comply with all necessary data protection regulations, ensuring that they process your personal data with full confidentiality and strictly under the instructions and for the purposes of RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou.

Your personal data may be transferred outside the European Economic Area (EEA), specifically to service providers collaborating with the electronic platform provider, who may be headquartered in the USA. For such transfers, appropriate safeguards are implemented, including Standard Contractual Clauses (SCCs) for cross-border data transfers, as well as the EU-U.S. Data Privacy Framework.

Security of Personal Data

Taking into account the nature, scope, context, and purposes of processing, as well as the risks of varying likel hood and severity for the rights and freedoms of natural persons, RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou implements appropriate technical and organizational measures to ensure and be able to demonstrate that processing is performed in accordance with the GDPR, adopting and implementing a holistic personal data security policy.
In assessing the appropriate level of security, RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou takes into particular account the risks presented by processing, specifically from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.
To prevent personal data breaches, RELEVANCE DIGITAL Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou, as the Data Controller, has adopted and implements a policy against attacks on the information systems it owns and manages, as well as a specific procedure for managing potential personal data breach incidents.

Your Rights

If you wish to access the data you have provided to us, to rectify or supplement any of it, to request its erasure, its portability, or to restrict the processing we carry out, you may contact the Data Protection Officer (DPO) of Relevance Digital SA at: [email protected].

In the event that you believe a request of yours has not been sufficiently or lawfully satisfied, or that your right to the protection of your personal data is being infringed by any processing we perform, you have the right to lodge a complaint with the Hellenic Data Protection Authority (1-3 Kifissias Ave., 115 23 Ambelokipi, tel. +30 210 647 5600, www.dpa.gr).

Contact Information

For any further information or requests regarding this Recruitment Privacy Notice, you may contact us at the following address: [email protected]

Changes to 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 Anonymi Etaireia Parochis Ypiresion Marketing kai Psifiakou Metaschimatismou must make the new version of the policy public.