1. Introduction – Details of the Data Controller
This Policy describes:
-What data we process, for what purposes and what is the legal basis of the processing
– How we keep them, who are the recipients of the data, what are the rights of the data subjects and how you can exercise them.
Through our website, the web, as well as personal interviews, we collect certain information that can lead to your direct or indirect identification. According to the European and national legislation such information (e.g. name, postal address, telephone number, e – mail address, CV, etc.) are considered personal data and can identify you as individuals (hereafter “Personal Data” or “Data” ).
“Processing of Personal Data” means any action or series of operations carried out with or without the use of automated means in personal data such as collection, registration, organization, structure, storage, adaptation or alteration, retrieval, retrieval of information, use, disclosure by transmission, dissemination or any other form of disposal, association or combination, restriction, erasure and destruction.
The Data Controller of your Personal Data is «ALTERNATIVE RESEARCH SOLUTIONS A.E.» a company with registered address at 16 Tzaferi Str. Athens (Gazi) Postal Code 118 54 ΤΙΝ 099935469 GEMI 4028001000, Tel.: 210 6781900, E – mail: firstname.lastname@example.org
ALTERNATIVE – RS is a member of SEDEA (Association of Polling and Research Companies) with Registry number 25.
Our company owns and manages the site www.alternative-rs.gr and other websites.
We process your data in a legal and transparent manner, in accordance with European legislation (General Data Protection Regulation 679/2016 EU) and national legislation esp. Law 4624/2019. We collect and process your data only for explicit, legitimate and specified purposes and only process the amount of data necessary for each purpose.
We maintain the data for as long as necessary, in accordance with the laws, the purposes and the Company’s policy, and we make sure it is as accurate as possible.
We make every effort to ensure that your data is secure and protected from unlawful processing, accidental or malicious loss or destruction as well as from unauthorized access. We have implemented a detailed information security program and we apply security controls based on the sensitivity of the information and the size of the risk of our activity, taking into account the best practices of modern technology and the cost of the implementation. We have adopted and applied appropriate internal policies and security processes, as well as technologies that ensure the security of data. Our executives and staff have been trained on data security issues to ensure data confidentiality and integrity. Our staff as well as third party partners have committed themselves in writing to the confidentiality of the data they have access to.
The site www.alternative-rs.gr uses SSL (Secure Sockets Layer) protocol, which uses encryption methods for exchanging data between two devices (most commonly PCs), establishing a secure connection between them over the Internet, resulting in the protection of your personal data and other sensitive data (e.g. orders or inquiries of the controller). You can recognize that you are in a protected connection by seeing the characters https:// and the lock symbol that appears in your browser’s address bar.
As a rule, we only collect and process the data that you provide directly and voluntarily, through the web or otherwise.
However, this rule cannot be fully applied in two cases within the context of the operation of the Site: (i) certain data that is collected automatically upon your visit to our website; and (ii) data collected through cookies and similar technologies.
When you visit our Site our server collects the so-called server log files, namely:
- Date and time of entering the site.
- The volume of data sent inbytes .
- The browser (browser)and the operating system that you used for your entering the Site.
- InternetProtocol address, when you enter the site. The IP address is personal data, along with the date and time of your visit, although we are not able to identify you by this data alone.
The legal basis for which we collect your IP address and keep it in special files ( log files ) is our legitimate interest in processing this data in order to ensure the security of networks, information and services from accidental events or illegal or malicious actions that compromise the availability, authenticity, integrity and confidentiality of the stored or transmitted data (eg control ddos attacks “denial of service”), as well as our legal obligation to provide a most secure environment for the processing of your personal data (GDPR art. 6 par. 1 case. f and c). The data will not be transferred or used in any other way. However, we reserve the right to check the server logs (server log files) if specific indications of unauthorized use are found.
3.2 Contact Us or E-mail
In the context of communication between us through Contact Us form or E-mail, we collect your name, E-mail address and any other information you provide us. This data is stored and used exclusively to respond to your request. The legal basis for the processing of your personal data is your consent (GDPR, Article 6 (1) (a) ). Your data will be deleted after the final processing of our communication. This will happen after the purpose and scope of our communication is completed, provided that there are no legal claims for the storage of such data.
3.3 Submitting a CV
When you submit to our Company via the Web or to our offices a CV , you provide us with your personal information, which is included in your CV resume, such as your first name and surname, training, experience, expertise, professional skills and preferences, etc., as well and other information that you may wish to disclose to us, such as your photo.
We keep your personal data (CV) for three years to consider recruiting you and the legal basis for the processing of your personal data is your consent (GDPR Article 6 (1), (a) and Article 9 (2), (a) ).
3.4. Data processing after the completion and submission of the Application Form for participation in our Consumer Group.
If you wish to participate and play an active role in the development of new products you may want to be a member of our Consumers Group. This is a large Group of people who are interested in taking part in our surveys, tell us their opinions, evaluate products and to help shape the new trends in the market. With your consent, we are processing the personal data you are providing us when filling in the Consumer Group Application Form, i.e. name, surname, year of birth (optional), E-mail, telephone, marital status, number and age of children in the household, profession, special interests. We process this data in order to make you a member of our large and lively Consumer Group that wishes to take part in the surveys we usually conduct on behalf of our clients , as processors , or our own surveys. The legal basis of the processing is your consent (GDPR Article (6) (1) (a) ). We maintain this data for as long as necessary to achieve the purposes for which it was collected, (exploring your willingness to participate in a survey we carry out as well as in future surveys). We usually keep your data for as long as you ask to be removed from the Consumer Group.
You may always withdraw your consent by contacting us by E-mail or mail at the address listed at the beginning of this policy and ask for your removal from our list.
3.5 Data processing by participating in a survey or research carried out by our company.
When you participate, online or in person, in a survey or research conducted by our company (consumer survey, market research, market, etc.), we process the personal data you give us such as your name and contact information, for the purpose of being accountable to our audit institution (Quality Control of Data Collection, Audit Body of our Collective and Supervisory Body SEDEA, Association of Polling and Market Research Companies). This data, which is held separately from the questionnaires you complete which are processed anonymously, we keep for a time limit of one year to provide efficient proof of the quality of our research services. The legal basis of the processing is your consent and compliance with legal obligation of the controller (GDPR Article 6 (1) (a) and (c) ).
With your consent, which is the legal basis for the processing (GDPR Article 6(1)(a)) we may also process image and recorded audio/video data in order to be used either by our company, as the data controller, or the customer for whom a research or survey is conducted, and only for internal use. This means that it will never be published in the media or disclosed in any other way, and that it will not be used to identify you for other purposes.
We may also process your data to send you a gift for your participation in the survey, possibly by transmission to the donor or the sender of the gift. The legal basis for this processing is your consent (Article 6(1)(a) of the GDPR) and we keep the shipping details until the gift is sent.
- Who has access to your data. Data Transfers.
Your data is accessible to the personnel of the company that is authorized to respond to your requests as well as any other authorized person who has to process your data in the course of his / her work tasks. Additionally, for the functioning of our websites, for the delivery of gifts, for the surveys, etc. we work with third-party service providers, individuals or legal entities, professionals, independent consultant etc. who provide us with commercial, professional or technical services (eg providing IT services , deliveries etc.) for the purposes mentioned above and to support the Company in whole or in part, in connection with its activities. Where applicable, such individuals/legal entities will act as Data Controllers, Data Processors or persons authorized to process personal data for the same purposes as mentioned above, under the same security measures and in accordance with the applicable legal obligations.
Before the third party receives the Personal Data, we: (1) complete the legal privacy test to evaluate the privacy practices and risks associated with these third parties; (2) we obtain warranties by contract from these third parties that will process Personal Data in accordance with our Company’s guidelines and in accordance with this Policy and the applicable law, that they will promptly notify our Company of any Privacy or Security Incident, including any inability to comply with the standards set forth in this Policy and existing law, that they will cooperate towards the remedy of any such Incident, that they will assist us in in responding to the individual’s rights as defined below and that they will allow our company to audit their processing with regard to compliance with these requirements.
Finally, the data may be further forwarded to public authorities and institutions as well as legal assistants, for legitimate purposes.
Except as above, Data will not be disclosed to third parties, individuals or legal entities, and will not be disseminated.
Our company does not transfer Personal Data outside E.U., and if we have to (eg in order to use Cloud services) this this will be done under the terms and conditions provided by Articles 44 et seq. of the GDPR, such as by obtaining your consent, applying standard contractual clauses approved by the European Commission or operating in countries that are considered safe by the European Commission.
If we must process Minor’s Data (e.g., if minors participate in a consumer’s survey), the process will only be done with the written and explicit consent of the persons who have custody of the minor. In any case, we make reasonable efforts to verify that the consent is provided by the person who actually has custody of the child, by any possible means.
- Security of processing
Alternative RS implements Policies, Technical and Organizational Measures for the secure processing of Personal Data:
-Our staff and associates have been trained in personal data protection, information protection and proper use of information systems, as well as have signed a confidentiality and confidentiality commitment.
– A written policy of access, information security and proper use of information systems is implemented. The company’s IT infrastructure is implemented in accordance with ISO27001, authorized access policy for authentication with strong Passwords to information systems, Incident management and data recovery plan, maintenance and upgrade of hardware and software, periodic security checks with specialized software, daily virus detection checks at all terminals, filtering of incoming and outgoing mail with anti-malware and anti-virus detection system. All systems are protected by anti-malware & anti-virus programs
– We have provided for physical protection measures of the facilities from any kind of external or internal threat or incident, the physical record is kept in lockable cabinets and destroyed, when necessary, safely.
– Written Security Incident Response Plan
- Cookies and similar technologies
Cookies are files containing small amounts of information that are stored on your device when you visit a website. They are then sent back to the website on each subsequent visit, or to another website that recognizes those cookies.
We may store cookies on your device if it is strictly necessary for the operation of this website. For all other types of cookies we need your permission, which you can give us in total or for some categories.
Cookies make it easier for you to navigate the various websites, remember your preferences and generally improve the user experience. They also make sure that the promotions and ads you see online are more relevant to your interests. They do not personally identify the user, only the device used, through a randomly generated identifier.
Types of cookies we use
- a) Functionality cookies (strictly necessary)
These cookies are responsible for basic functions of the website. They are necessary for you to be able to browse our website and to access the secure sections of the website. The provision of the main internet services of the website is not possible without these cookies.
- b) Statistical analysis cookies
These cookies collect information about how you use our website, such as the website from which your visit originated, the pages you visit most often, the browser you used, etc. We use them for the purpose of analyzing traffic and improving the performance of our website. They collect aggregated, anonymous statistical information that cannot lead to the identification of the visitor.
About Google Analytics
You may block your data collection altogether through Google Analytics by installing the add-on in your browser:
- c) Advertising (targeting) Cookies These cookies use information about your browsing in order to make advertisements and offers more relevant and targeted, to limit the number of times a promotional activity/advertisement appears on your device and to help measure the effectiveness of an advertising/promotional campaign. In addition to our own cookies, third-party advertising network cookies are placed on your device on our behalf.
When you visit our website, we provide you with the opportunity to choose in an easy and simple way whether or not to install non-necessary cookies (and related technologies), all or by category, by using a simple app. You also have the option to change your relevant preferences at any time, even during the same session.
Additionally, you can set your browser to inform you about the setting of cookies and you can either decide individually or in total to accept them, or block their acceptance in some cases. Each browser differs depending on how it handles the cookie settings. This is described in each browser’s help menu, which explains how you can change your cookie settings. Follow the links below depending on the browser you are using:
Please keep in mind that you need to adjust the settings individually in each browser and each device you use. We also inform you that any restriction of cookies will prevent you from fully using some of our services and will not allow us to improve and personalize your navigation on our website.
Alternatively, you can disable the useof cookiess by third parties through the relevant service of Network Advertising Initiative.
You can contact the Data Protection Officer of our Company by E-mail, mail of telephone as listed in paragraph (1) above at any time, in order to exercise your rights under Articles 15 to 22 of GDPR such as your rights of access , correction, deletion (where permitted), limitation of processing, disclosure, portability , as well as the right to withdraw consent in accordance with Article 7 par. (3), and a complaint to a supervisory authority in accordance with Article 77 of the GDPR .
You can, for example, get an updated list of people who have access to your data, get confirmation of whether or not we process personal data related to you, check their content, source, correctness and location (also in relation to any third country), ask for a copy, ask for their correction and, in the cases provided for in the CPC, requesting the limitation of the processing or their erasure. Similarly, you can always report comments and submit complaints to the Greek Data Protection Authority, Kifissias 1-3, GR 115 23, Athens, Call Center: +30-210 6475600 or at http://www.dpa.gr/
You can withdraw your consent at any time, without however affecting the legitimacy of the processing that has taken place before the withdrawal of the consent. However, we reserve the right to further processing, if we prove compelling reasons or if the process serves to the exercise or the defense of legal claims.
Athens, October 2022