The companies of the Actionline Group, trading as “ACTION LINE CONSULTING FOR HUMAN RESOURCE DEVELOPMENT AND BUSINESS OPERATIONS MANAGEMENT SOLE SHAREHOLDER LIMITED LIABILITY COMPANY,” with distinctive titles “ACTIONLINE SOLE SHAREHOLDER LTD” and “ACTIONLINE SOLE SHAREHOLDER IKE,” with distinctive title “ACTION 4 EMPLOYMENT,” headquartered at 10 Lykavittou Street, Athens, 10671, tel. 2103637585, ensure the privacy and confidentiality of your personal data and adopt the General Data Protection Regulation 679/2016 of the European Union in all processes and stages of communication with you.

Purpose of this policy

This policy provides every individual and visitor/user of the Companies’ website who is interested in receiving concise and transparent information regarding the practices followed for the management and protection of personal data.

It concerns any act or series of acts carried out with or without the use of automated means, on personal data or sets of personal data, 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.

The Policy is updated periodically and may be modified whenever deemed necessary, without prior notice, always within the applicable legal framework and in accordance with any changes in the prevailing legislation on personal data protection. Therefore, we suggest checking this Policy regularly to stay informed about any changes that may have occurred.

What are personal data?

Personal data is any information relating to an identified or identifiable natural person (e.g., name, identification number, address, etc.). Data relating to health (physical or mental condition, medical treatment, etc.) is included in the general term personal data but constitutes a special category of data.

How are your personal data collected?

Your personal data are collected in the following ways:

(a) when you submit a job application to the Company or send your resume. The provision of your personal data within the framework of submitting a resume for a job position in our Company or through our Company takes place voluntarily by you, as otherwise it would not be possible to evaluate the possibility of your employment.

Processing is necessary to take steps at the request of the data subject prior to entering into a contract, according to Article 6b of the Regulation.

For more information, please refer to the CV processing Policy.

(b) when you provide them to us by completing the Personal Data Usage Confirmation & Consent Form. The submission of your details is at your discretion, and their processing with your consent according to Article 6a of the Regulation is for promotional actions and updates on new job positions.

(c) automatically through the browser or mobile device you use to access our website www.actionline.gr

(d) when you provide them to us by completing forms and documents within the framework of Management Systems Implementation (ISO) in the Company. Data processing is carried out in accordance with Article 6b of the Regulation.

(e) when you complete electronic forms, e.g., “newsletter” or send an email, in order to be informed about job positions and services available on our Company’s website www.actionline.gr The submission of your basic information is at your discretion, and their processing with your consent for the sole purpose of informing you about the services provided and job positions by our Company according to Article 6a of the Regulation.

What kind of personal data is collected and for what purpose?

The personal data collected and further processed include:

Identification details, your demographic information, address, and generally your contact details (including email address and telephone number). The purpose of collection is the execution of our contract according to Article 6b of the Regulation.

Identification data such as resume data, knowledge, your professional training, and your professional experience. The collection, processing, and retention of the above data is done to satisfy the exclusive purpose of selecting and evaluating job candidates by the Company for the possibility of taking up a job position. Your data is kept only for this purpose and is processed by competent personnel of the Accounting Department, Personnel Selection Department, Administration, etc.

Identification, financial, tax, and communication data, such as tax identification number, tax office, contact details, address, etc. The collection, processing, and retention of your data belonging to the above categories, according to Article 6c of the Regulation, is necessary for the Company to comply with its legal obligations.

The Company will not process your personal data without your consent. However, the Company reserves the right, in exceptional cases, to process your personal data to the extent permitted or required by law, and/or by court decisions or prosecutor’s orders/directives.

Are data transferred to third parties?

We may disclose your personal data (in whole or in part, as required each time) to:

a) all authorized persons of our Company, e.g., legal advisors, collaborating consultants, external accountants, etc.,

b) specific persons of our Company, necessary for the process of selecting job candidates, e.g., Accounting Department, Personnel Selection Department, Administration, etc.,

c) providers of data processing systems support,

d) existing or potential clients or clients of these clients, for the purpose of your employment,

e) judicial or other supervisory or regulatory authorities, within their jurisdiction,

f) third parties with a legal interest, for the establishment, exercise, or support of legal claims.

In cases where your consent is required for the disclosure of your data to third parties (where not mandated by law), it will be explicitly requested from you, and you have the right to withdraw it at any time. In such cases, the Company assures you that it is constantly vigilant and takes all necessary security measures to ensure that the transfers of personal data are carried out in the safest possible manner.

The Company commits not to sell your personal data by offering them for sale/rent, giving them/transferring them/disclosing them or sharing them with third parties, or to use them in any other way and for other purposes that may jeopardize your privacy, rights, or freedoms unless required by law, court decision/order, administrative act, or unless it constitutes a contractual obligation necessary for the smooth operation of the Company’s website and the performance of its functions.

Personal data may be transmitted to partners or third parties compliant with the terms of this Policy and committed to confidentiality, who act on behalf of the Company for further processing with the purpose of providing services, managing data, and technical support, only after the user is informed in advance and their consent is obtained.

These third parties have contractually committed with the Company to use the personal data only for the above purposes and not to disclose the personal information to third parties, nor to share them with third parties unless required by law.

For how long are my personal data retained?

The retention period may significantly differ depending on the type of data and their use. The determination of the data retention period is based on criteria such as legal retention deadlines, pending or potential disputes, intellectual property or proprietary rights, contractual requirements, operational guidelines, or archiving needs.

The Company commits to retain your resumes for four (4) years from the time the Company received your resume, or from the last updates of your personal profile in our Database, or from the most recent communication with you (whichever is the most recent).

Tax information is retained in accordance with tax legislation.

What are my rights regarding the processing of my personal data?

You have the right at any time to request: a) access to your personal data, b) correction of your personal data if inaccurate or incomplete, c) deletion of your personal data, unless their processing is necessary for exercising the Company’s or third parties’ legitimate rights, for legal compliance, for reasons of public interest, or for defending our legitimate rights before courts or other authorities, d) restriction of the processing of your personal data only for specific purposes.

In order to exercise any of the above rights, please use the “Request for Exercise of Rights Form” and send it either by letter to the Company’s headquarters (Lykavittou 10, Athens, 10671, tel. 2103637585), or by Email (to the Email account: [email protected]), always providing your full details and the reason for your communication.

In case you believe that the Company is in any way violating the current legislation on personal data, you have the right to lodge a complaint/report with the competent Supervisory Authority for Personal Data Protection: http://www.dpa.gr, Kifisias 1-3, 115 23, Athens, tel. 210 6475600, email: [email protected].

In this case, we would highly appreciate your prior communication with the Data Protection Officer (DPO) of the Company either by letter to the Company’s headquarters (Lykavittou 10, Athens, 10671, tel. 2103637585), or by Email (to the Email account: [email protected]), always providing your full details and the reason for your communication.