FOURLIS GROUP DATA PROTECTION - PRIVACY POLICY
1. Introduction
The natural persons visiting the website www.fourlis.gr (hereinafter referred to as “the Webpage” or the “Website”)
may be navigated in its webpages either as simple visitors or as registered users, and for the processing of their personal data, due to this access and the use of its services,
the present Policy shall apply.
Each visitor of the webpage wishing to send his/her curriculum vitae should create a Personal account in the system and proceed as “Registered User”.
The creation of a personal account and the registration of a curriculum vitae is performed under sole and absolute initiative, diligence and
responsibility of the candidate, as regards the information and data included in the account and the CV, which must be true and accurate.
2. Definitions
«General Data Protection Regula-tion»»
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Regulation (EU) 2016/679 issued by the European Parliament and the Council, dated on 27 April 2016, on the protection of natural persons from
the processing of personal data and on the free movement of these data and on the repeal of the directive 95/46/EC (General Data Protection Regulation)
(this text is of relevance to the EEA) (hereinaf-ter referred to as “the Regulation”).
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«Personal Data»
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Any information concerning an identified or an identifiable natural per-son (“data subject”); the identifiable natural person is
the person whose identity may be identified, directly or indirectly, especially through a reference to an identity identifier, such as name,
identity card number, location data, online identifier, or one or more factors applying to the physical, normal, genetic, psychological, financial,
cul-tural or social identity of the said natural person.
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«Special Catego-ries Data» (Sensitive Personal Data)
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The Personal Data which are naturally particularly sensitive in relation to fundamental rights and freedoms of the natural persons
and re-quire special protection, since their processing framework could cre-ate significant risks to the fundamental rights and freedoms
of the natural persons. The said personal data should include personal data disclosing racial or national origin, political views, religious
or philo-sophical views or the participation in a trade union, as well as the pro-cessing of genetic and biometric data aiming at the undoubted
identifi-cation of a person, data concerning the health or data concerning the sexual life of a natural person or the sexual orientation.
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«Processing»
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Any act or series of acts taking place with or without the use of au-tomated means, on personal data or sets of personal data, such as the collection,
the registration, the organisation, the structuring, the storage, the adjustment or the change, the recovery, the search of information, the use, the
communication through transmission, the dissemination or any other form of disposal, the correlation or the combination, the limitation, the erasure or
the destruction.
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«Consent» of the data subject
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Any indication of will, free, specific, explicit, and in full awareness, by which the data subject declares that he/she agrees, by declaration
or through an express and obvious positive act, that the personal data concerning the data subject should constitute an object for processing.
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«Controller»
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The natural person or the legal entity, the public authority, the service or other body, that separately or jointly with other bodies,
specify the purposes and the method of data processing; when the purposes and the method of this processing are specified by the Union law
or the law of the member-state, the controller or the special criteria for his/her appointment could be provided by the Union law or by the
law of the member-state.
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«Processor»
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The natural person or the legal entity, the public authority, the service or other body processing personal data on behalf of the controller.
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3. Purpose of Processing
The FOURLIS Group (FOURLIS Holdings SA) is the Controller for the Personal Data collected and joint controllers are named all the Group’s subsidiaries (HOUSEMARKET SA-IKEA, INTERSPORT ATHLETICS SA, TRADE LOGISTICS SA), even if one specific employment post has been selected in one of them, since it is possible that more than one or all Group compa-nies may have access to the same curriculum vitae, since the database and the system for the management of CVs is shared by all the companies. Purpose of the collection and the processing of these data is the evaluation of candidate and the finding of a suitable job in the Group or in any of the Group’s companies.
The FOURLIS Group and the Companies of the Group shall proceed to the processing of Per-sonal Data of the candidates in accordance with the applicable laws on Personal Data Protec-tion, and with any other relevant law provision, aiming at the assessment, in their view, of the candidates’ abilities and skills for the specific job, for which they have sent their CV, or for any other job managed or controlled by the FOURLIS Group and the Companies, for which (job) it is determined, upon processing, that these candidates have the required abili-ties/skills.
The FOURLIS Group and the Group’s Companies declare that no other use of the personal data of the users shall take place for other purposes than those mentioned in this Policy, without prior notification and, whenever required, express consent of the data subject.
4. Lawfulness of Processing
The processing of the Personal Data of the visitors/registered users for the purposes men-tioned above is required in order that measures are taken, after request of the data subject, prior to the execution of the contract and, more specifically, for examining the possibility of the candidates’ employment in the Group or in the Group’s Companies, (article 6 par.1b of the Regulation).
Furthermore, in specific cases, the processing is required for compliance with the law, when certain information are necessary for the fulfilment of the lawful or regulatory obligations of the FOURLIS Group and of the Group’s Companies.
5. Type of Personal Data
The Personal Data collected directly by the registered user are: identification data and per-sonal data (first name, surname, date of birth/age, gender, country and city of residence), contact details (e-mail, mobile phone number), education and working experience data as well as whether his military service duties have been fulfilled (in case of the candidates to whom this duty applies). Further, each candidate may declare the existence of a relative working in the Group or in a Group’s Company, and any recommendations/references, as well as preferences for his/her employment, which the candidate himself/herself wishes to declare (desirable city/country of employment, desirable position, employment type etc.), and may submit a file with a more detailed curriculum vitae. The candidate, who communi-cates data of third natural persons, shall be obliged to inform these persons about the pre-sent Data Processing and Maintenance Policy and to have obtained their consent.
We do not pursue to obtain and we shall never collect data of special categories in relation to a candidate, unless this is allowed or required by the applicable laws. In extraordinary cases that such data are communicated to us, such as health data, we process these data because you communicate these to us for the support of your nomination. These data shall be sub-mitted for processing only to the extent absolutely required for the assessment of the suita-bility/eligibility of the applicant for the specific job and duties or for compliance with the law-ful obligation.
6. Data Recipients
Recipients of these data are those responsible for each specific processing employees of the Group and of the Group’s Companies.
Further, the FOURLIS Group and the Group’s Companies may assign a part of or the entire processing of data to third parties, natural persons or legal entities, processing the data on their behalf as Processors. Such recipients may be: a) the company providing webpage maintenance services; b)recruitment consultants, in respect of steps required for the as-sessment and cover of each job position or of any other job positions, that may arise and match the experience and the qualifications of the registered users, as well as for communi-cation purposes with them in relation to the said job positions etc.
Upon registration, access or/and processing of the personal data of the visitor and the regis-tered user, the employees and authorised agents of the FOURLIS Group and the Companies of the Group, are committed to fully comply with the provisions of the Regulation as well as with the applicable laws on data protection. The FOURLIS Group and the Group’s Companies shall require from the workers, webpage maintainers, as well as from their third partners to take all necessary technical and organisational measures, including the appropriate policies and procedures, so that the disclosure of personal data processed on their behalf should be prevented.
7. International Transmissions
FOURLIS Group and the Group Companies shall not transmit or store the above data to third countries. The personal data collected shall be submitted for processing to servers located in the EU or in the EEA.
8. Technical and Organisational Protection Measures
FOURLIS Group and the Group Companies, the processors acting on their behalf and its au-thorised agents/servants are contractually committed to apply the appropriate technical and organisational measures for the best possible protection of Personal Data against the random or unlawful damage or loss, alteration, illegal notification or access to them and their illegal processing in general (including the remote access), as well as for the guaranteeing of the availability- and access-recovery option. These measures aim at guaranteeing a safety level corresponding to the risk that might threaten the specific data, taking always into account the type and the importance of the data, the evolution of technology, the implementation cost and the nature, the implementation scope, the framework and the purposes of each specific processing, applying at the same time procedures for the regular testing, estimation and evaluation of the effectiveness of these technical and organisational measures. In any case, they are contractually committed to keep the Personal Data confidential and to abstain from disclosing them or allowing access to them to any third party without prior notification of the data subject, unless in cases explicitly provided by law.
FOURLIS Group and the Group Companies shall take the required technical and organisational measures for data protection, as above exposed, may not however guarantee the safety of the data that will be circulated through the website, nor through connected websites or appli-cations. The candidates shall acknowledge and accept, as users of web services, that the transmission and sending of information via the web, always present risks.
9. Data Maintenance Term - Update
In case of a candidate as registered user (user account) in the system, his/her Personal Data shall be kept in the database for 24 months as of the date of registration, and provided that the candidate does not undergo a hiring procedure. This reasonable period of time has been selected on the basis of the legal interest of the parties and the technical capabilities of the system (article 6 par.1f of the Regulation).
Once per year, FOURLIS Group and the Group Companies shall request from the registered user:
- To confirm that he/she wishes to keep the user account and his/her personal data in the electronic base of the system;
- To check the correctness of the data and records it maintains and to update them provided there are changes.
The registered user may at any time change or correct his/her data by logging in his/her ac-count (login) entering his/her personal e-mail and the password.
Each candidate wishing that his/her data are not kept for the aforementioned period of time, may exercise the right to erase them, as below provided.
10. Rights of the Data Subject
Each visitor or registered user, as data subject, may exercise at any time his/her rights, as these are provided in the Regulation and especially in the articles 12 until 23 of this Regula-tion and the national laws, and more specifically:
i) the right to be informed and have access to the data processed by FOURLIS Group and the Group Companies;
ii) the right to restriction of his/her data processing;
iii) the right to correct or erase part of or his/her entire (right to be forgotten) personal data;
iv) the right to object, that is to raise objections against the processing of his/her personal data; and
v) the right to portability of his/her data.
His/her aforementioned rights may be exercised as follows:
- As regards the right to access, erasure in part or in whole, correc-tion/completion of the Personal Data and objection to processing, FOURLIS Group and the Group Companies grant the option to the registered users to view, correct/complete their personal data through their personal account or request access, erasure in part or in whole, and correction of their data via email correspond-ence to the e-mail address: dpo@fourlis.gr.
- As regards the right to portability of the Personal Data, FOURLIS Group and the Group Companies grant the option to receive their personal data or/and transmit them to another controller in a structured, jointly used and readable by machines form, indicated by the competent supervisory authority, by submitting a relevant request to the e-mail address dpo@fourlis.gr.
In case of exercise of any of the aforementioned rights, FOURLIS Group and the Group Companies shall take any possible step for the satisfaction of the request within one (1) month as of its submission. In this case, the data subject shall be informed that his/her least required personal data shall be kept, for the guaranteeing of legal interests of the Group. It is clarified that in order for the exercise of the aforementioned rights be considered as valid, the identification of the applicant may be required, in order to be ensured that the Personal Data in relation to which some of the aforementioned steps / acts is requested, actually be-long to the natural person applying for the specific act.
11. Transparency Obligation
For any other information related to his/her data as well as their processing and protection, each Data subject may address the Data Protection Officer of the FOURLIS Group to the email dpo@fourlis.gr and to the hotline 0030-2106293011. In case he/she considers that he/she is not satisfied from the response or in general from the method of collection, pro-cessing and management of his/her data, he/she is informed that he/she has a right to file a termination notice to the competent supervisory authority (Data Protection Authority, www.dpa.gr, 1-3 Kifisias str. P.C.11523, Athens, tel.0030-210-6475600, email: com-plaints@dpa.gr)
12. Modifications in the present Policy
FOURLIS Group and the Group Companies may modify the present Policy. This Policy shall apply and be effective as of June 2021.