In Creative Pharma & HR Services S.M.S.A. (hereinafter referred to as the “Company” or “we”) we are committed to respecting your privacy and complying with applicable laws on data protection and privacy. We are sharing with you this Data Protection Policy to inform you on the processing of your data in relation to the following purposes:
- Processing of data of the visitors of the website www.creativephs.com (“Website”). You may find relevant information under section “Website Privacy Notice”.
- Processing of data of our Business Partners. You may find relevant information under section “Privacy Notice for Business Partners”.
- The rights you have for the protection of your personal data. You may find relevant information under section “Your Rights”.
Processing of your personal data is governed by these terms, by the relevant provisions of Greek and EU legal framework on data protection, including the General Data Protection Regulation (2016/679) and the relevant decisions, guidelines and regulations.
1. Website Privacy Notice
This Notice explains how we collect, process and/or use information that we receive via our website and the emails we send (collectively, the “Website”) that link to this Notice, as amended from time to time. This Notice also describes how we collect, process, use and share the personal information you provide us with. It also describes your choices regarding use, access, transfer, correction and deletion of your personal information.
1.1. Information we collect
We collect information about you to provide the services you request. In this context, it is essential that we are able to collect and use the information as described in this Policy.
1.2. Information You Give Us
When you submit your data, we collect and retain your data exclusively to communicate with you and fulfil your request. In this context, we collect your name, surname, email, telephone number and Company you are working for, as well as any data you may choose to include in your message.
1.2.2. Submission of CVs
When you submit your CV to the Company by using the email account firstname.lastname@example.org or through any other application of the Website, we collect and retain your email and personal information you include in your CV, such as:
- Identification data (name, surname).
- Contact information (residence address, telephone number, email).
- Information related to your educational attainment and skills.
- Information related to your professional experience.
- The position you are interested in.
The above information is necessary for us to assess your educational and professional skills and be able to communicate with you if we consider that your characteristics are suitable for a specific job offer. The Company shall have no responsibility if you choose to disclose any confidential information or sensitive or special personal data when submitting your CV.
1.3. Information We Collect Automatically
When you use the Website, your device is automatically providing information to us, so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect may also include usage information and statistics about your interaction with the Website. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the platform.
1.4. Why we collect your information
We process your data exclusively for the below purposes:
When you submit your data, we will use them to communicate with you and provide the information and/or services required. Processing of your data is necessary to perform the requested service.
- Submission of CV
When you submit your CV through the Website, we will collect and process your data to assess your professional skills and competencies and to examine the possibility of cooperating with you. Processing of data is based on consent. You may revoke your consent at any time by sending email to email@example.com with subject “REVOKE”. In that case we will not be able to examine the possibility of cooperating with you.
- Improvement of services
We maintain your data and the history of use of our services to produce statistics that allow us to better assess how visitors interact with our website and to improve its content and structure. The processing of data is based on the legitimate interest of the Company in monitoring visitors’ response to its services and improving its services.
- Legal Obligations & Claims
When a legal obligation is in place, we will provide your data to the competent authorities. We will maintain and process your data to the extent necessary to establish, exercise or support legal claims.
With respect to the use of Data collected through Cookies, please see our Cookies Policy.
1.5. Recipients of your data
Access to your data may only be provided to our duly authorized employees or business partners who act on our behalf for the above purposes of processing, by offering us IT services for the registration and storage of your data and/or for the operation of our website. The Company does not transfer or disclose your personal data outside the European Economic Area (EEA).
1.6. Duration of processing
Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When you submit your CV in response to a job announcement published by the Company, we will retain your CV for six (6) months after completion of the hiring process. If you provide your consent or when you submit your CV voluntarily, we will keep your CV for two (2) years.
2. Privacy Notice for Business Partners
2.1. Personal Data that we collect
We collect and process indicatively the following personal data of our Business Partners and other persons with whom we communicate for business purposes:
- Identification data (name, surname, and, where applicable, e.g. contracts, ID/Passport Number, signature).
- Contact information (address, telephone number, email).
- Data necessary to perform payments (including but not limited to tax registration number, bank account number, beneficiary).
- In the case of legal entities, information related to their legal representatives (name, surname, signature).
- Any other information that you disclose to the Company and is necessary for the performance of our business relationship.
2.2. Why do we process your data
We will process your data for the following purposes:
- For business growth and development.
- For the execution of our contractual relationship;
- To comply our statutory obligations, including regulatory requirements and internal policies.
- To organize and execute our business operations, such as to perform payments, communicate and manage our relationship with you.
- For purposes of internal and external audits.
- To reply to official requests from the authorities.
- To establish, exercise and defend legal claims.
The processing is necessary for:
- performing our contractual relationship.
- ensure compliance with our legal obligations, and
- pursue our legitimate interests or the legitimate interests of a third party.
2.3. Recipients of your data
For the above purposes, your data will be processed by Company’s authorized employees. We may transfer your data to other companies or persons related to the Company when this is necessary for the purposes of this processing. In these cases, these parties either act as independent controllers, determining the means and the purposes of the processing, or act as processors on behalf of the Company. In both cases, this privacy statement applies. Data which are necessary for the purposes of each processing are transferred to the following categories of recipients:
- to our third-party suppliers, who offer us IT services, tax and legal advice, and other services.
- to national or international regulatory, tax or other authorities or public bodies or courts or other legal authorities, where required by law or regulation or upon an official order.
- to other business partners when required to execute requested transactions.
- to third parties who carry out audits on the Company in the context of relevant regulatory obligations, customer relationship or obligations under applicable law.
The Company does not transfer or disclose your personal data outside the European Economic Area (EEA).
2.4. Data Retention
Data retention period may vary according to the category of data. Your personal data will be retained for a maximum period of 10 years after termination of our contractual relationship, unless extension of the retention period is required by contract, law or due to pending legal cases. Your data are stored with safety in digital format and/or in hard copy at Company’s premises.
3. Your rights
Our Company ensures your rights with respect to processing of personal data and ensures that you may exercise them.You have the right to request:
- Access to your personal data and information on which data do we process, the purposes of processing, the recipients and the duration of processing.
- Rectification of your personal data if it is inaccurate or incomplete.
- Deletion of your personal data, unless their processing is necessary for the exercise of the legal rights of the Company or of third parties, for the fulfillment of a legal obligation, for public interest reasons or for defending our legal rights before judicial or other Authorities.
- Restriction of processing of your personal data only for specific purposes.
- Ask for the portability of your data, that is to receive the data you have provided in a structured, commonly used format, or ask to send it to a third party designated by you.
- To withdraw at any time your consent to the processing of your personal data, when processing is based on consent.
If you have any request or question regarding this policy, you may email us or send us a written request, using our contact details set out below. If you wish to exercise any of the above rights, we advise you to use our “Data Subject Request Form” (English version / Greek version) and submit it to the following contact details.
Creative Pharma & HR Services S.M.S.A.
286 Kifisias Ave., Halandri 152 32, Athens, Greece
Tel: +30 210 32 59 360
Fax: +30 210 32 59 380
If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr).
4. Cookies Policy
Please visit Cookies Policy page for details.
5. Privacy Notice for the Operation of CCTV
Creative Pharma & HR Services S.M.S.A
5.2. Purpose and lawfulness of data processing
We use a CCTV for the purpose of protecting persons and goods. Processing is necessary for the purposes of our legal interests, as a Controller (article 6 par. 1. f, GDPR).
5.3. Our legal interest for data processing
Our legal interest consists in the need to protect our facilities and goods against illegal acts, such as thefts. The same applies to the safety of life, physical integrity, health, as well as the property of our staff and third parties who are legally in the supervised area. We only collect image data and limit the operation of CCTV only to areas where we have assessed that there is an increased likelihood of committing illegal acts, e.g. theft, as at the entrance, without focusing on areas where the privacy of the persons whose image may be taken may be excessively restricted, including their right to respect their personal data.
5.4. Recipients of your data
The data is accessible only by our competent / authorized staff in charge of the safety of the facilities. The data shall not be transmitted to third parties, except in the following cases: a) to the competent judicial, prosecutorial and police authorities when it includes information necessary to investigate a criminal act involving persons or goods of the controller, b) to the competent judicial, prosecutorial and police authorities when requesting data, legally, in the context of exercising of their duties, and c) to the victim or perpetrator of a criminal act, in the case of data which may constitute evidence of the act.
5.5. How long we keep your personal data
We keep your data for twelve (12) days, after which they are automatically deleted. In case an incident takes place during this period, we will isolate part of the video and keep it for up to one (1) more month, in order to investigate the incident and initiate legal proceedings to defend our legal interests, while if the incident concerns any third party, we will keep the video for up to three (3) more months.
5.6. Rights of Data Subjects
Data subjects have the following rights:
- Right of access: you have the right to be informed if we process your image and, if applicable, receive a copy.
- Right to restriction: you have the right to ask us to restrict the processing of your personal data, such as not deleting personal data that you consider as necessary to establish, exercise or support legal claims.
- Right to objection: you have the right to object to the processing of your personal data
- Right to erasure: you have the right to ask us to delete your personal data
You can exercise your rights by sending an e-mail to firstname.lastname@example.org or a letter to our postal address or by submitting the request to us in person. In order for us to look in a request related to your image, you need to inform us when you were in the range of the cameras and give us a picture of you to make it easier for us to identify your data and mask the data of third parties. Alternatively, we give you the opportunity to visit our facilities to show you the relevant images of you. In addition, please note that the exercise of the right to object or delete your personal data, does not imply the immediate deletion of data or the amendment of the processing. In any case, we will answer you in detail as soon as possible, within the deadlines set by the GDPR.
5.7. Right to lodge a complaint
If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Data Protection Authority, Kifissias 1-3, 115 23, Athens, www.dpa.gr, tel. (+30) 2106475600.
LAST UPDATED: 13-JUN-2022