Processing of doValue Greece former employees’ personal data

Former employees for the purposes of the present notice are those who have been employed by doValue Greece under any form of employment which has ended or been terminated for any reason and the employee has left from such employment relationship.

This Νοtice also refers to third parties related to former employees, provided that their personal data are processed for the purposes set out herein.

The personal data that has been collected and processed by doValue Greece belongs mainly to the following categories, and it is explicitly clarified that not all of them necessarily concern you:

a. Identification data: name and surname, father’s name, mother’s name, identity card and identity card number or passport and passport number, tax identification number (T.I.N.), competent tax authority, social security number (in Greek A.M.K.A.), date and place of birth, sex, citizenship, employee registration number, photo etc.

b. Contact data: postal and e-mail address, fixed and mobile telephone number, etc.

c. Data concerning family status and dependent members, collected for the fulfillment of obligations by law or in the context of individual contracts or collective labor agreements, or voluntary benefits.

d. Information included in your CV and in expressing interest applications for a job in doValue Greece as well as information collected in the context of procedures for your placement in the doValue Greece structure: certificates of study, certificate of enlistment, information on previous professional experience and previous jobs, affinity with employees in any company of the doValue Group, professional certifications, including certifications for knowledge of foreign languages and use of PC, work or residence permit as well as other documents and supporting documents that were submitted or collected during your recruitment stage etc.

e. Information that emerged from your employment with previous employers, which you provided to us: evaluations, payroll data, training programs, recommendations of former employers or associates, etc.

f. Special categories of personal data, (health information and medical information and/or data relating to criminal convictions and offenses (e.g. criminal record) collected by you in the context of your employment with doValue Greece in accordance with applicable law and/or data relating to your participation in trade unions for the exercise of your or doValue Greece’s rights or obligations.

g. Data collected from publicly accessible sources, such as the internet, social and / or professional networking media, etc.

h. Data necessary for the purposes of legal interests pursued by doValue Greece or the Group to which doValue Greece belongs or by a third party, such as information collected in the framework of procedures for assessing your financial behavior (such as unredeemed checks, termination of loan contracts, seizures), non-bankruptcy certificate, information regarding the default of your financial obligations that you have submitted in order to prevent fraud and to preserve the reputation of doValue Greece, as provided in the current legislation.

i. Data connected to and/or derive from the use of computer systems, infrastructure and/or media in the workplace or in connection therewith, such as telephony, e-mail or the use of the internet and other electronic media based on the regulations and policies of doValue Greece and as provided by law.

j. Image data from events of doValue Greece and/or the companies of the Group to which doValue Greece belongs.

k. Identification data (indicative name), contact information (indicative home address, e-mail address, email, fixed or mobile telephone numbers) and other, where applicable, third parties’ data that you have indicated in the context of your employment at doValue Greece.

a.    doValue Greece has obtained your personal data directly from you or from persons specially authorized by you (natural or legal), including third-party employment agencies, at your request. doValue Greece is not responsible for any illegal processing of your personal data by these employment agencies and generally third parties as mentioned above.

b.    doValue Greece may also have obtained your personal data from its media and IT and access logging systems.

DoValue Greece processes the above personal data for:

a. The compliance with its legal obligation imposed by the current legal, regulatory and supervisory framework as well as decisions or addressing requests of public, supervisory, prosecutorial, judicial, independent authorities.

b. For purposes overriding your interests or fundamental rights or freedoms which require the protection of your rights, your legitimate interests or those of a third party, in particular for the establishment, support or exercise of legal claims of doValue Greece and the exercise of its rights in the context of labor and social security law.

c. The fulfillment of the rights and obligations of doValue Greece arising from voluntary exit agreements.

d. For reasons of addressing any requests of future employers for provision of recommendations.

e. Any other cases for which you have provided your consent to the processing of your data.

Please note that once your consent has been requested and obtained, the processing of your personal data is based on this consent. In such cases, you have the right to withdraw your consent at any time, as described in section 8 below, without, however, such withdrawal to affect the legality of the processing based on your consent prior to the withdrawal.

The management of doValue Greece and/or the competent employees of the Human Resources Division of doValue Greece within the framework of their responsibilities and if necessary for the fulfillment of the purposes mentioned in this Persona Data processing Notice, as well as the companies affiliated with the doValue Group to which doValue Greece belongs, based in Greece and in other countries of the European Union, if required for the fulfillment of the purposes described herein.

It is noted that doValue Greece has taken additional measures to ensure the security of your personal data, especially those belonging to special categories (e.g. health data), so as to provide access, only to persons who are required to have access for the performance of their duties and only to the absolutely necessary extent on a case by case basis. The transfer of data to recipients other than doValue Greece is done only for what is required and necessary:

a. if required, in the context of the assignment by doValue to third parties (legal or natural persons) for the execution of specific works/activities on its behalf (processors) or

b. in order doValue Greece to meet its lawful obligations or

c. for reasons where doValue Greece’s or a third party’s legitimate interest override your legal interest or

d. with your consent.

In this case, your personal data may for example be transferred to the following recipients:

i. Collaborating with doValue Greece entities and persons who process the personal data on its behalf: Lawyers, law firms, bailiffs, notaries, companies of installation, operating and supporting computer applications, providers of IT products and/or services and/or support of all kinds of information and electronic systems and networks, including online systems and platforms, companies for storage, archiving, management and destruction of files and data, etc., under the condition of the compliance in all cases with the terms of security and confidentiality.

ii. Supervisory, tax, social security, regulatory, control, independent, judicial, prosecutorial, public and/or other authorities or bodies within the framework of their legal responsibilities, duties and powers.

iii. Insurance bodies, insurance companies and health service providers.

iv. Third parties, natural or legal persons, cooperating with doValue Greece in the context of its activities (eg recipients of services, consultants, etc.).

doValue Greece will not transfer your personal data directly to third countries or international organisations, unless such transfer is required by the applicable regulatory or legal framework.

If applicable, doValue Greece may transfer your personal data to third countries under the following circumstances:

i) Where the European Commission has decided that the third country, a territory or one or more specified sectors within that third country or international organisation ensure an adequate level of protection, or

ii) If appropriate safeguards have been provided from the recipient, in accordance with the national and European legislation.

In the absence of the abovementioned circumstances a transfer may take place if:

i) You have provided your express consent to doValue Greece; or

ii) the transfer is necessary for the performance of a contract between you and doValue Greece, such as for the execution of your orders, or

iii) the transfer is necessary for the establishment or exercise or defense of legal claims and rights of doValue Greece, or

iv) there is a relevant obligation arising from a legal provision or an international convention to which doValue Greece is subject. In order to fulfill such obligation, doValue Greece may transfer your personal data to competent national authorities so that such data are delivered through them to the respective authorities of third countries.

doValue Greece may keep your personal data until the completion of the general limitation period for the exercise of legal actions, pursuant to the applicable legal provisions, namely twenty (20) years from the – under any condition – termination of your relationship. Especially your personal data belonging to special categories (namely health data, criminal convictions, participation in trade unions, etc.) will be kept by doValue Greece for a period of five (5) years from the expiration or – under any condition – termination of your employment relationship at doValue Greece.

If, until the expiration of twenty (20) years, legal proceedings are in progress with doValue Greece that directly or indirectly concern you, this time of storage your personal data will be extended until the issuance of an irrevocable court decision.

In case a shorter or longer storage period of your data is provided by law or regulations, the above storage time will be reduced or increased accordingly.

In case of expiration of this period your data will be deleted safely.

Documents that have your signature and contain your personal data may be stored electronically/digitally after a period of five (5) years.

You have the following rights:

a. Know the categories of your personal data kept and processed by doValue Greece, their origin, the purposes of their processing, the categories of their recipients, the time of their storage, as well as your relevant rights (right to access).

b. Request the correction and / or completion of any information about you that is inaccurate or incomplete (right to rectification), providing any necessary documents from which the need for correction or completion arises.

c. Request a restriction on the processing of your data (right to restriction).

d. Object to any further processing of your personal data that we hold (right to object).

e. Request the erasure of your personal data from the files we keep (‘’right to be forgotten’’).

f. Request the transfer of your data from doValue Greece to any other controller (right to data portability).

g. Withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of the processing based on consent prior to the withdrawal thereof and the provision of consent even after its withdrawal is allowed.

Please note the following with regard to your abovementioned rights:

i.  doValue Greece may not satisfy your rights under c, d and e (in part or in full), as long as they relate to data necessary for the preparation and / or continuation of your employment contract or employment relationship.

ii. doValue Greece has in any case the right to refuse your request for restriction of the processing or deletion of your personal data if the processing or storage of the data is necessary for the establishment, exercise or support of its rights or the fulfillment of their obligations.

iii. The right to data portability (point f above) does not include the erasure of the personal data from the records of doValue Greece if they are necessary for the establishment, exercise or support of rights of doValue Greece or the fulfillment of its obligations.

iv. The exercise of the rights above is valid for the future and does not affect the processing already performed on your personal data.

For the exercise of your rights, you may address your relevant requests in writing, to doValue Greece, 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece or via email at [email protected].

doValue Greece shall use its best endeavors to address your request within one (1) month from its submission.

The abovementioned period may be extended by two (2) further months, if deemed necessary at reasonable discretion of doValue Greece, taking into account the complexity and number of requests. doValue Greece shall inform you in case of such extension within one month from the receipt of the request.

The abovementioned service is provided by doValue Greece free of charge. However, where requests are manifestly unfounded, excessive or repetitive, doValue Greece may, after relevant information, either charge a reasonable fee or refuse to act on the request/requests.

You may contact the Data Protection Officer of doValue Greece for any matter regarding the processing of your personal data, in writing at 27 Kyprou & Archimidous Streets, 18346 Moschato, Greece or via email at [email protected].

You have the right to lodge a complaint before the Hellenic Data Protection Authority for any matter regarding the processing of your personal data.

For the respective competence of the Authority and the procedure to be followed for filing a complaint, you may visit the Hellenic Data Protection Authority website: www.dpa.gr (My Rights > Complaint to the Hellenic DPA), where detailed information is available.

doValue Greece implements appropriate all technical and organizational measures for the security of your data, to ensure the confidentiality of their processing as well as to protect them from accidental or unlawful destruction, accidental loss, alteration, prohibited dissemination or access and any other form improper processing.

doValue Greece may in accordance with its applicable policy on the protection of personal data and pursuant to the applicable legal and regulatory framework, modify or amend this Notice, the updated version of which will always be posted on the doValue Greece website at www.dovaluegreece.gr.

Last update of Notice: 10 July 2021