PRIVACY POLICY

AND PROTECTION OF PERSONAL DATA

1. Who is responsible for your data- Where do you go to exercise your rights?

1.1. The Data Controller of your Data is the limited liability company under the name “C. APOSTOLOU – N. KARANIKAS” with the distinctive title FIREPROJECT, located at 370 Vouliagmenis Avenue, 173 42 Ag. Dimitrios Attica (VAT: 801361905) and legally represented, with a telephone center 2114178447 and e-mail contact [email protected] (“the Company”).

1.2. The Data Controller as above Company has appointed a Data Protection Officer with a contact e-mail address [email protected]. To the e-mail address of the Data Protection Officer you can address all requests for exercising your rights (under 3.1 – 3.7) below.

2. General principles observed by the Company regarding transparent information.

2.1. Any information we provide you with this document and any information you may request in the future is provided free of charge, provided that the request is not repeated, excessive or manifestly unjustified (see more in 2.3.)

2.2. For each of the above rights that you exercise, the Company will respond to you within one (1) month from the receipt of the request or in case of objective difficulty, complexity of the request or the number of requests, the Company will respond within a maximum period of a total of three (3) months regarding either the completion of your request or the justified refusal to perform what you have requested for legitimate reasons expressly specified in General Regulation 679/2016.

2.3. In case the Company considers that any of the following rights are manifestly unfounded or the request is excessive or (even more so) repetitive in nature, it is entitled to impose a reasonable fee on you for providing further information (which is in principle free of charge) and to refuse to proceed with the request.

2.4. In case the Company has reasonable doubts about your identity when you submit a request to exercise any of the above rights, it may request additional information necessary to confirm your identity before processing the request.

2.5 In case the Company delays beyond the justified period to respond to your request, as well as in any other case in which you consider that you violate any of your rights or the Company does not comply with its obligations, you are entitled to file a complaint with the supervisory authority. (Personal Data Authority, Athens Kifissias 1-3, P.C. 115 23, Athens, Greece, [email protected], +30-210 6475600).

2.6. Those of you who have provided us with your consent to process your data for the purpose mentioned below under 4.2 (i.e. for the purpose of informing you about the Company’s products and actions), you have the right to withdraw your consent at any time by selecting the relevant “Unsubscribe” command which accompanies each email you receive from the Company. Those of you who have provided us with your consent to process your data for the purpose mentioned under 4.1. below (i.e. to assess the possibility of your recruitment by the Company) have the right to withdraw your consent at any time by sending the declaration of withdrawal of consent to the email address of the Data Protection Officer. In addition, any of you may address the above email address with a written request to exercise your other rights (under 3.1 – 3.7). ( see 1.2.)

3. What are your rights in relation to the Personal Data you have provided to us?

3.1. Right to Information

You have the right to request information about the personal data that we have received from you and that we hold for one or more of the purposes described in clause 4. This document as a whole is a guide to basic information and understanding of the philosophy of the regulatory framework governing the protection of your personal data. Updating, deepening and clarification of this document can be provided to you upon request for the exercise of your right to information. (see how in 1.2)

3.2. Right of Access

You have the right to request from our Company access to your data that we hold and confirmation as to whether they are being processed and, in particular, information on the purposes of processing, the categories of personal data, the recipients or categories of recipients, the period of retention and processing, the existence of a right to complain to the Personal Data Protection Authority, any available information on the origin of the data when they have not been processed, the existence of a right to file a complaint with the Data Protection Authority, any available information on the origin of the data when they have not been processed, and any information on the processing of personal data. (see how in 1.2.)

3.3. Right of rectification

You have the right to request our Company to correct your data if any of the data for which we have the right to process has changed or has been incorrectly recorded. (see how in 1.2.)

3.4. Right of Deletion

You have the right to request from our Company the complete or partial deletion of your data to which we have the right to keep and process, either because they are no longer necessary for the purposes for which they were collected, or because you withdraw your consent, or because the data were collected for a purpose that you consider unlawful. Our Company will respond to you within a reasonable time (not more than one month and under certain circumstances if there is a difficulty not more than three months in total) confirming the total or partial deletion of your data respectively or regarding the impossibility of deleting specific data if a law or the fulfilment of a duty in the public interest, or the right to freedom of expression and information or the exercise or support of a legal claim requires their retention. In this case, you have the possibility to lodge a complaint with the supervisory authority on the one hand and to take legal action on the other hand. (see how in 1.2.)

3.5. Right of Restriction

You have the right to request our Company to restrict the processing of your data, quantitatively, temporally or in relation to the purpose of processing, and more specifically (a) either to restrict the categories of data that we process, (b) or the purposes for which we process them, (c) either because you consider the processing unlawful but do not wish to have them deleted as their retention would serve you for a legal claim, or because the accuracy of the data is disputed by you. (see how in 1.2.)

3.6. Right to Portability

You have the right to receive the personal data you have provided us with in a structured, commonly used and machine-readable format and the right to transmit it further without objection, since your data is processed on the basis of consent. In the context of exercising this right, you have the additional possibility of requesting direct transmission by the Company to the third party without your mediation.

This right is exercised subject to the conditions for deletion as described above (under 3.5.) and its exercise may not adversely affect the rights and freedoms of others. (see how in 1.2.)

3.7. Right of refusal

3.7.1. You have the right to object to the use of your personal data for the purpose of direct marketing, in particular profiling related to such direct marketing. (see how in 1.2.)

3.7.2. There is no relevant right in the case of filling in the data in the CV submission form as these data are not transmitted to the Marketing department and are not treated as such. Their processing is strictly limited to satisfying the purpose of the evaluation by the Human Resources department.

4. Nature and Purpose of the processing of personal data

4.1. The receipt, processing and retention of data on CVs, knowledge, professional training and professional experience, is done to satisfy the exclusive purpose of the evaluation by our Company for the possibility of occupying a job, and are kept only for this purpose, and are processed only by the Company’s Human Resources department.

4.2. The receipt, processing and retention of your data concerning contact details is done to satisfy the exclusive purpose of informing you about the Company’s products and actions. All your data are kept only for this purpose and are processed only by the Company’s marketing department.

5. What is the basis that justifies the processing of your data?

The legal basis for the processing of your data is your consent to the processing of your data in order to fulfil the aforementioned purpose, pursuant to Article 6 par. 1(a) of the Personal Data Protection Regulation.

6. Can your data be forwarded elsewhere?

Your data is not intended (as it is not required by the purpose for which it is collected) to be transferred to any organisation other than the Company itself, with the exception of the providers of services supporting our Company’s electronic systems and networks – and for the sole purpose of their performance of the contract for the support of our Company.

7. For how long will we keep your data?

7.1. In order to fulfil the purpose of the processing, which concerns the investigation of a job vacancy in our company (completion of the CV submission form), we consider a period of twelve (12) months to be a reasonable and necessary period of retention of your relevant data. After twelve (12) months from the time of receipt of your CV, the relevant file with all your data will be deleted.

7.2. For the fulfilment of the above processing purpose (under 4.2), i.e. to inform you about our products and actions, we consider a reasonable and necessary retention period of three (3) years for your relevant data. After three years from the time of obtaining your consent, the relevant data will be deleted unless consent is provided again by you under the above conditions.

8. Why are you providing us with this data and what would be the consequences of not providing it?

8.1. The submission of your basic data is at your choice and their processing is done with your consent for the sole purpose of informing you about our Company’s products and actions. We request and process your information (as you have chosen to provide it to us) so that we can contact you and keep you informed about our products and actions. In case you fill in fields concerning contact details (address, telephone number), your status and your position and give us the relevant consent, you will have the opportunity to receive (if applicable) and printed material and to receive information that we consider to be closer to your needs and interests on the basis of the status you have indicated, which cannot happen if you fill in the minimum of the required fields.

8.2. The provision of your personal data in the context of submitting a CV to find a job in the Company takes place voluntarily as otherwise it would not be possible to assess your employment opportunity.

9. Guarantees

We assure you that the Company will exhaust every technical and organizational measure for the protection of the Data and will only make the optimal, minimal and absolutely necessary use and processing of the Data as required by law and strictly and exclusively for the purpose for which you have made them available to us.