Privacy Policy

Greek Companies of LMW Group

Preamble

When you interact (e.g., communication, request, order a service) with any Greek company of LMW Group, such company may collect and process your personal data acting as a Data Controller according to applicable law.

This Privacy Policy complies to General Data Protection Regulation – EU 2016/679 (“GDPR”). Any additional provisions of the national law governing each company shall be referred to in a separate section herein.

This Privacy Policy may be amended from time to time without prior notice. We encourage you to regularly review the present terms.

Terms “we” and/ or “our Company” shall mean any of the following Companies that you may interact with from time to time.

Full Details of Greek Companies of LMW Group

Scope

This Privacy Policy explains how we process your personal data when you contact us or when you use any of our services. Specifically, by reading the Privacy Policy you will be able to understand, among other things:

–              the reason for which we process your personal data;

–              which personal data we collect directly from you and which we collect from third parties;

–              how long they are kept;

–              the categories of recipients – if any – of your personal data;

–              if we intend to transmit said data to a country outside the European Union (EU) or the European Economic Area (EEA);

–              if we perform automated decision-making or profiling; and

–              your rights in relation to the processing of your personal data and how you can exercise such rights.

This Privacy Policy is not the Website Privacy Policy. The Website is owned and managed by LMW S.A.T.E. and is subject to the Website Privacy Policy including the Website’s Cookies Policy .

When & why we collect your personal data

Most of the personal information we process is provided directly by you for one of the following reasons:

–              You directly contact us for whatever reason through any means.

–              You use our services (e.g., for temporary employment of human resources).

–              You subscribe to our newsletter in order to receive information material (e.g. information reports about our services, forthcoming events).

–              You send us an application as potential employee or partner to cover a position in our company, either after we have placed an advertisement/post or on your own initiative. In such case Applicant Privacy Policy applies.

Types & use of personal data

When you contact us and when you order a service, we may collect and process certain categories of your personal data. Our services are not intended for children, and we do not knowingly collect personal data relating to children. Personal data includes any information about you from which you can be, directly or indirectly, identified.

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Data collected directly by you

We may collect some of your personal data for communication purposes, such as to answer your requests for information and in order to better understand your expectations and needs. More specifically, when you contact us, we collect and process information about you that you directly provide to us, which may include: name, email address, phone number, the service you are interested in and the content of the communication that you address to us. We will use this information to communicate with you and provide our services to you.

When you use our services, e.g. temporary employment services of LMW S.A.T.E., consulting services of EF WORK, job search services of LMW RECRUITMENT SOLUTIONS, career consulting services of LMW INTL, we will also process certain identification data about you as our client (e.g., name, address, legal representative name in case of legal entities), in order to provide such services. In the context of our contractual relationship and for our compliance with any legal obligation, we may process other categories of ordinary data about you (e.g., billing information regarding the use of our services).

We may also process certain information about you when you send us your CV and when you apply for a job, e.g. your identification and contact information and information on your education and professional experience. A separate privacy policy applies in this case, which is available here.

When you subscribe to receive our newsletter, we collect and process information you provide about yourself by filling the relevant form of our Website (e.g., communication details, email address).

Aggregated data

We may process aggregated data, such as statistical or demographic data, for any purpose. While aggregated data may be derived from your personal data, these are not considered personal data as such data does not directly or indirectly reveal your identity (e.g. we may aggregate your usage data to calculate the percentage of users accessing a specific website feature); however, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we shall treat the combined data as personal data which will be used in accordance with this policy.

Non- collection & processing of special categories of data

We do not collect and process any special categories of personal data about you through our website, e.g. information about your health, race or ethnicity, religious or philosophical beliefs, sex life, etc.

Legal Basis for the processing

We will only process your personal data when the law allows us to, that is, when we have a legal basis for processing. On a case per case basis, we may carry out the processing of your personal data on the following legal basis:

• You have provided your consent to the processing of your data for one or more specific purposes (e.g., when you contact us, when you send us a job application, when you ask from us to keep your CV for the possibility of a future collaboration).
• The processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (e.g. when you order any of our services).
• The processing is necessary for compliance with a legal obligation to which we are subject to.
• The processing is necessary for the purposes of our pursued legitimate interests, provided that your fundamental rights do not override such interests; such legitimate interests may include the improvement of our services, marketing and customer relationship.

Not providing your personal data may in certain cases result in disadvantages for you, e.g. we may not be able to provide you will a service or respond to your request.

Data Transmission to Third Parties

We reserve the right to disclose your personal data to any member (e.g., affiliate companies) within LMW Group in order to comply with our legal obligations, or for the purposes of our legitimate interests (e.g., for internal administrative purposes of LMW Group) provided that your fundamental rights do not override such interests.

Service Providers

We may engage external service providers, who act as a data processor of our company, to provide certain services to us, such as recruiting service providers (Workable Software Limited), website service providers, marketing service providers or IT support service providers. When providing such services, the external service providers may process your personal data.

Other recipients

We may transfer, in compliance with applicable data protection laws, personal data to law enforcement agencies, governmental authorities, legal counsels or external consultants. In case of a corporate merger or acquisition, personal data may be transferred to the third parties being involved in the merger or acquisition.

International Transfers of Personal Data

We transfer personal data in accordance with applicable laws. To the extent that, in the context of and for the needs of the above-mentioned purposes, your personal data need to be transferred outside the EU/EEA, such data transfer will take place in accordance with applicable law and we will ensure an adequate level of data protection. By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses, which are accessible upon request at our e-mail, or taking other measures to provide an adequate level of data protection, we have established or confirmed that all data recipients will provide an adequate level of protection for your personal data. Any onward transfer will be subject to appropriate onward transfer requirements, as required by applicable law.

Data Retention

Your personal data will be retained for as long as necessary to fulfil the purposes we collected it for, e.g. for as long as necessary to provide you with the functionalities of the website and the services requested. Once the data processing purpose is completed, we will either delete your personal data or anonymize your personal data, unless statutory retention requirements apply. More specifically:

–              When you subscribe to the Newsletter (e.g. e-mail address), we retain your personal data for as long as you remain subscribed to our recipient list and delete them in case of withdrawal of your consent.

–              We retain your personal data that we collect from you for the submission of a question or complaint, when you address us through our Website or any other available means of communication for the necessary period of time until the final resolution of your relevant issue and until any related claims are barred.

–              We retain the personal data, which you provide us within our contractual relationship, for as long as such relationship lasts and after its expiration or termination for the necessary time to comply with legal obligations (e.g., tax law obligations) and until any related claims become statute-barred.

–              In case you send us a job application, your personal data is deleted within one month of such application receive if there is no relevant interest. In case of approval of your application for employment, you will be informed at the stage of assuming your duties about the way that we will process your personal data as “employer” or associate. If, in case of your job application rejection, you ask from us to keep your CV details for the possibility of future collaboration, your personal data are retained for the time period you have given your consent. More detailed information can be found in the Applicant Privacy Statement here.

Data security

Considering the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing.

Your rights

You may have the following rights according to the applicable law:

• the right of access (article 15 GDPR)
• the right to rectification (article 16 GDPR)
• the right to erasure (article 17 GDPR)
• the right to restriction of processing (article 18 GDPR)
• the right to data portability (article 20 GDPR)
• the right to object (article 21 GDPR).
• In addition, when your consent is required for the processing of your personal data, you have the right to withdraw your consent at any time by contacting us by following the instructions below (article 7.3 GDPR).

More specifically your rights are the following:

Right of access

You may ask us whether we are processing your personal data. You may also request a copy of your personal data.

Right to rectification

You have the right to ask us to rectify your personal data, if you think that are inaccurate. You also have the right to ask us to complete your personal data in case you think that is incomplete.

Right to erasure

Under certain circumstances, e.g., the personal data are no longer necessary, you withdraw consent, you have the right to obtain the erasure of personal data.

Right to restriction of processing

Under certain circumstances, e.g., when you challenge the accuracy of data, make an objection to their use, when you think that their retainment is unnecessary, or in case of their unlawful processing, you have the right to obtain the restriction of processing.

Right to object

You have the right to object to processing of your personal data on grounds relating to your particular situation, unless, among other reasons, if there are compelling and legitimate grounds for the processing which override your interests, rights and freedoms. You also have the right to object when a decision concerning you is based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you (the law provides exceptions which apply).

Right to data portability

You have the right to receive the data concerning you in a structured, commonly used and machine-readable format, as well as the right to transmit such data to another entity (controller), indicated by you.

Consent Withdrawal

If you have provided your consent with regard to specific processing of your personal data, you have the right to withdraw such consent at any time. The withdrawal of your consent applies only for the future.

You can find more information regarding your rights in the Hellenic Data Protection Authority’s (HDPA) website here. is seated in Athens (Vasilissis Sofias Avenue, 23, 106 74), Home – IDPC is seated in Malta (AireDesk Business Hub 17 Triq il-Modd, Ibragg Swieqi 2373 ), The Office of Data of the Commissioner for Professional Data Protection is seated in Cyprus (6 Emmanouil Roidi 1095 Nicosia), The Office for Personal Data Protection is seated in Czech Republic (Za Poříčskou bránou 21/365 CZ 186 00 Praha 8), Comissão Nacional de Proteção de Dados is seated (CNPD) in Portugal ( Avenida Eng. Duarte Pacheco, T.2, 8o, S.2) and Information Commissioner’s Office (ICO) is seated in United Kingdom (1-3 Pemberton Row, London, United Kingdom, EC4A 3BG).

Rights Exercise

You can exercise your rights via our email, or by communicating with us via other available means. These rights shall be exercised free. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee considering the administrative costs of the provision of information, communication or action requested.

In case you exercise any of your rights, we will take all appropriate measures to respond and/or satisfy your request within thirty – days deadline, reserving the right to extend such deadline according to the applicable law. We may either inform you on the acceptance of your request or on any objective grounds that hinder its processing.

Right to lodge a complaint with the Authority

You have the right to lodge a complaint with the HDPA for issues regarding the processing of your personal data. HDPA is seated in Athens (Vasilissis Sofias Avenue, 23, 106 74), Home – IDPC is seated in Malta (AireDesk Business Hub 17 Triq il-Modd, Ibragg Swieqi 2373 ), The Office of Data of the Commissioner for Professional Data Protection is seated in Cyprus (6 Emmanouil Roidi 1095 Nicosia), The Office for Personal Data Protection is seated in Czech Republic (Za Poříčskou bránou 21/365 CZ 186 00 Praha 8), Comissão Nacional de Proteção de Dados is seated (CNPD) in Portugal ( Avenida Eng. Duarte Pacheco, T.2, 8o, S.2) and Information Commissioner’s Office (ICO) is seated in United Kingdom (1-3 Pemberton Row, London, United Kingdom, EC4A 3BG). With regard to HDPA’s competency and the submission of a complaint, you may visit HDPA’s webpage.