Privacy Policy
PERSONAL DATA PROTECTION AND PRIVACY POLICY
1. NOTIFICATION
Our company under the legal name “HELLENIC ORGANISATION FOR COMPANY SPORT KAI HEALTH” has its registered office in Athens (87, Dinokratous str., Kolonaki) and hereinafter shall be referred to as the “Organisation” or “HOCSH”, and is a non-profit civil partnership that aims, inter alia, to promote, highlight, enhance and develop the physical activity of employees by organizing, coordinating, implementing and generally supporting any form of action, event, sport game and programmes that promote employees’ health, wellness, team spirit and fair play within their working environment.
The Organisation “HOCSH” is the Data Controller of the personal data we collect from you –the visitors of our website– either from our members and participants in our actions or from third parties authorized to that effect, in the context of our operation and the implementation of our statutory objectives and actions, as the latter whenever specified and published both on our website and other social and mass media, in printed and online press.
Personal data is any information that identifies you as a natural person or may identify you directly or indirectly. In addition, the Website “www.hocsh.org”, hereinafter referred to as the “Webpage”, may automatically collect personal data at the time of your visit thereto and it is managed by the Organisation “HOCSH”.
Hereby, we would like to inform you that we take very seriously the private life of our members, personnel and volunteers, and all those who participate in our actions, as well as the private life of our webpage visitors and we shall process their personal data in full respect and pursuant to the applicable legislation of data protection, the General Data Protection Regulation (EU) No 2016/679 (hereinafter referred to as “GDPR”), as well as other European and National Legislation.
We kindly request to read carefully this Personal Data Protection and Privacy Policy in order to be informed of the data we collect about you, our members, personnel and volunteers, as well as the participants in our actions (e.g. sport games, international competitions, etc.), how we collect and process data, the purpose for which we process and use them, as well as to inform you about your rights.
This Policy serves as your awareness according to articles 13-14 of GDPR. If you wish any further clarifications about our processing of your personal data, please address your queries to the following address: info@hocsh.org.
You may also contact with our Data Protection Officer of our Organisation (hereinafter referred to as “DPO”) info@hocsh.org.
This Privacy Policy forms an integral part of the Terms of Use of our Webpage to which you may have access by clicking here, as well as, the Conditions of Participation in each event (e.g. sport competitions), as the latter whenever specified and disclosed to you by posting on this webpage, following the aforementioned provisions.
2. THE PERSONAL DATA WE COLLECT:
A. OUR MEMBERS’ PERSONAL DATA
A.i. In the context of our Organisation’s operation and management, we shall collect and process, both in printed and online form, the personal data of our members (founding members, board members, members of general assembly, cadets, subscribing or honorary members), but also of our candidate members, which are listed in our documents, namely in the application for registration and/or in a member’s assessment, such as: name, surname, father’s surname, contact information (address, fixed and/or mobile phone), tax registration number, tax authority, professional capacity (type of business/profession). These members shall sign such applications which they present us on a voluntary basis. We may also process other data, such as: birth date, grammatical competence/training elements, languages you speak, any experience whatsoever and any other information in the curriculum vitae (CV) which our candidate members provide us, on their own, on a voluntary basis by submitting their application for registration.
It is noted that in the context of implementing the GDPR, we are interested in processing personal data of natural persons. Data of Legal Persons (legal entities) of public or private sector, which are or may be become regular members of HOCSH, shall be consequently excluded from the provisions thereof, given that under the Articles of Association only Legal Persons may become Regular Members. In this case, HOCSH may process, as Data Controller, the data of the legal representative of the Regular Member (Legal Person) and/or their employees (indicatively: name/surname, telephone number, e-mail).
A.ii. By submitting the application and their CV voluntarily, the candidate members give their consent to our Organisation, as Data Controller, for the processing of their data for the purpose of their potential integration in the Members Registry of the Organisation. After the approval of the registration request, the candidate is registered in the Members’ Register of the Organisation with the distinction drawn in the Articles of Association, namely as cadet, regular (if it is a Legal Entity), subscribing or honorary member. As for our members, we also process data and information about any relevant to them applications for waivers/cancellation/member disqualification/reintroduction, and decisions of the BoD/General Assembly, as well as information of payments, rights of memberships, annual subscriptions and extraordinary contributions.
A.iii. In addition to the above, we process the results from the games and, generally, from our actions, which we post on our website, as well as on social and mass media, in printed and online press, where the information of each team of the employees participated is indicatively listed (e.g. .the information of the employer enterprise).
A.iv. Members’ data shall not be shared to third parties nor shall be transferred outside EU.
We may transfer our member’s data to a third party after its explicit consent, such as to European Federation For Company Sport (EFCS) and World Federation For Company Sport (WFCS) of which we are members, in case of calls for expressions of interest in participating our member’s team of employees in an action/event/game etc., organised by these Federations or co-organised by these Federations and us.
B. OUR STAFF AND VOLUNTEERS’ PERSONAL DATA
B.i. For those who apply for a job in our Organisation, we shall collect and process the personal data listed in detail in our printed documents — application for a job signed also by us and presented voluntarily by the candidate. Indicatively, we shall process your surname, name, father's surname, maiden name, birth date, citizenship, marital status, number of children, contact telephones, communication address, grammatical knowledge/training elements, any languages you speak, any experience whatsoever, and any other information provided in the curriculum vitae by our candidates, as well as, the selection of the job position.
With the voluntary submission of the application and the curriculum vitae provided by the candidates, they give their consent to us in order to process their data with the purpose of their potential employment. This consent may be freely withdrawn at any time. The Organisation, in case no recruitment shall be made, will keep data (curriculum vitae) for two (2) years by fully respecting candidate’s privacy. After the expiry of the retention period, the curriculum vitae shall be destroyed in a secure manner. Such data shall not be shared to third parties nor shall be transferred outside EU. We may transfer data to an external partner during the evaluation of the application, who shall be committed for respecting the privacy and the protection of data by a written agreement made be and between us pursuant to the provisions of GDPR.
B.ii. We shall process our personnel’s personal data (such as name, surname, tax registration number, social security number, contact information, photographs, curriculum vitae etc.), according to the procedure, legally disclosed to our employees, either at the time of their recruitment or at the time of their employment in our Organisation, following the current labour, social security and tax legislation, the internal policy of the Organisation and the employment agreement made by and between us.
B.iii. We shall also process personal data (such as name, surname, fixed/mobile phone) of the persons who voluntarily help our work and participate in the organisation of our actions/events/sport competitions.
C. EMPLOYEES’ PERSONAL DATA OF ENTERPRISES PARTICIPATING IN OUR ACTIONS.
C.i. We process the personal data of the employees in undertakings participating in our actions as teams, such as, the personal data of the employees –as well as their accompanying persons, if any– forming companies’ sports teams which take part in sport competitions that we (co-)organise. These data (indicatively: name, surname, telephone, email) shall be completed either by the participating employees themselves or by the legal representative of the employer company/enterprise upon explicit written authorisation in a special form or online statement that we provide for the participation in our actions/games concerned etc., whenever this is notified and published on our website.
The employer company/enterprise shall be exclusively responsible against us and the competent Supervisory Authorities and Bodies, for informing its employees –the members of its team– in relation to the Conditions of Participation in our Action/Game etc., as well as the lawful and truthful completion of the special form/online statement with its team members’ data; at the same time, it shall affirm in the person of its legal representative that it has been informed of the conditions of participation in this action/game, etc. and accepts them, both the company itself and its employees –its team members; the company shall also affirm that all the participants have been explicitly consented for the collection and processing of their personal data by us to that effect and they are aware of their rights according to GDPR, this Privacy Policy and the Conditions of Participation in the Action/Game etc. In the event of a breach of the above conditions and commitments by the employer, the latter will be exclusively liable for compensating any possible loss caused to the Organisation “HOCSH” due to this reason (e.g. a fine imposed by Personal Data Protection Authority due to the lack of the above-mentioned consent of a team member).
C.ii. We shall not process medical data of participants in our actions, but the employer company itself states explicitly that it has received the explicit assurance of its employees –its team members– that they have been recently examined by a doctor and they may participate in the current organisation of events.
D. PICTURES/VIDEO RECORDING
We may also process and file pictures and video taken when the actions of HOCSH are being carried out (indicatively: when carrying out sport games) with the possibility of publishing them on the Webpage of the Organisation, on the Social Media, in printed and the online press in order to inform our members and the public about our actions, as well as for advertising purposes.
E. We shall also process the location, including the geographical position of the computer or device of the user visiting our website in real time via GPS, Bluetooth, or IP address, coming from the users, in case they use features based on location and activate the location service settings of their device and computer.
F. In addition to the above, we shall process the mails you exchange with us or you address to us through letters, e-mails and social networks.
3. PURPOSES/LEGAL BASES FOR PROCESSING DATA
We shall process:
A. For our members:
A.i. The above-mentioned data granted by the candidate members when they were registered voluntarily and by the members at the time of updating their data having the legal obligation under the law applied to the operation of our Organisation, as well as to the taxation/ issuance of tax documents for the collection of subscriptions, etc.;
A.ii. Members’ contact information for the execution and the proper operation of the contractual relationship made by and between us; for the awareness of the members on convening meetings of BoD and General Assembly, on coordinating actions that achieve our statutory purpose and conducting more efficiently the actions of the Organisation, as well as our communication, in general;
A.iii. In addition to the above, we shall process the e-mails of our members in order to inform of various actions, events, services, sport competitions organised by or co-organised with other bodies, such as EFCS and WFCS of which the HOCSH is member;
A.iv. Pictures and videos with the possibility of posting them on our Webpage, as well as on Social Media for the purpose of advertising both our enterprise and our actions based on your explicit consent.
B. For those who apply for a job position in our Organisation:
All the above data upon your request in the context of evaluating your qualifications for the possible conclusion of an employment agreement made by and between us.
C. For our staff:
All data required under the relevant labour, social security, tax and company law, but also based on the employment agreement made by and between us.
D. For our volunteers:
All the above data under our contractual relationship concluded by and between us and for the communication between us in the context of the operation of the Organisation.
E. For the employees of enterprises taking part in our actions — team members (e.g. of sport games):
E.i. All the above data upon the completion of the special form/online statement, either by themselves or by their employer with their consent, which we provide for the participation in our current actions/games and with the purpose to carry out an action/ a game in an orderly, secure and coordinated way.
E.ii. The participants in our actions shall be informed both by this policy and the conditions of participation in each action notified to them, that, when carrying out the actions (e.g. carrying out sport games), pictures shall be taken and a video recording shall be made and it is possible to publish them on the Website of the Organisation, on Social Media, in printed and online press in order to inform our members and the public about our actions and their results. This processing shall be made with the explicit consent of the participants given either directly to the Organization either through their employer enterprises under the terms of their delegated powers. Where relevant for the latter, the employer enterprise, as exclusively responsible for receiving these consents, against both the participants and the data controller of the Organisation, as well as against the competent Authorities, shall state to the Organisation that it has received the relevant consents of the participants for the aforementioned purpose of processing and shall assume responsibility accordingly.
In case you do not wish us to take photos or record videos in which you seem to appear, please inform us by sending this request to the following mailing address: 87 Dinokratous str., Athens - 11521 or via e-mail at the address info@hocsh.org.
4. BROWSING THE WEBPAGE
Each visitor may browse our Webpage without giving any personal information. Personal data, such as name, email, contact phone etc. will be required only in case a visitor wishes to contact with HOCSH or to register in the list of e-mail recipients. HOCSH shall have the ability and reserve the right to save visitor’s IP address and, if necessary, to contact with its Internet Service Provider in the event of any breach of the Terms of Use of the Webpage.
Our Website collects the following personal information:
The location, including the geographical position of the computer or device of the user visiting our website in real time via GPS, Bluetooth, or IP address, coming from the users, in case you use features based on the location and activate the location service settings of your device and computer.
In any case whatsoever, the user/visitor of our Website, after communicating with the relevant department and ascertaining the existence of their personal file, may request its erasure, rectification or modification.
Minors may have access to our Website and to your social media pages only with the consent of their parents/guardians and they shall not be obliged to disclose their personal information. Only persons aged over 16 may give their consent on their own.
5. INTERCONNECTION WITH THIRD-PARTY WEBPAGES
Through our website or before you visit our website, you may access to third-party social networks. When you are registered with your social media account, we will receive the personal data you have selected to share with us through these social media according to their privacy settings in order to improve and customise the use of our website. We may use social media links on our website, like Facebook or Instagram.
As a result, these personal data shall be disclosed to your social media provider and may be presented in the profile you keep in social media and may be accessible to other users in your network. For more information about these practices, consult the privacy statement of such third-party social media providers.
6. COOKIES
The Webpage may use cookies in order to enhance user experience when browsing, but also to improve the overall quality of its services. Cookies are small text files which are sent to the computer of a user when visiting a website. Cookies are stored in visitor’s hard drive, but they do not collect any information of any document or file from your computer. They are used for enabling visitor’s access and for statistical reasons in order to determine the regions in which such services are useful or popular, or for marketing reasons. The visitor of the Webpage may set their browser in a way that prohibits the download of all cookies or informs them when sending a cookie. However, the visitor of the webpage must know that some features or services of this webpage may not function properly without cookies.
7. PERSONAL DATA RETENTION
We retain data for the time period required by the relevant legislation (tax/social security/labour, company law etc.) and for the purpose for which they are processed. In order to determine the appropriate time period of such retention, we shall take into account the amount, the nature and sensitivity of personal data, the purposes for which we process them, as well as the ability to achieve these purposes by other means. Furthermore, we take into consideration the time period for which we may need to retain personal data in order to fulfill our legal obligations or to respond to complaints/control and to protect our legitimate rights in case of raising a claim. In particular for the curriculum vitae of job applicants in our Organisation and when the hiring does not occur after all, the retention of such personal data shall be provided for the period of two (2) years after the submission of candidate’s application. After the expiry of the retention period, the curriculum vitae shall be destroyed in a secure manner.
8. PERSONAL DATA SAFETY
HOCSH shall implement all technical and organisational means for the protection of your data. We shall follow stringent safety procedures when processing your personal data, and for their protection from accidental loss, destruction or damage, such as storage in restricted areas.
We may disclose your data to reliable third parties for the purposes set out in this Privacy Policy. We require all third parties to have suitable measures of technical and operational safety for the protection of your personal data pursuant to Greek and EU legislation on data protection.
9. TRANSFER OF PERSONAL DATA
The above-mentioned data shall remain confidential, be processed by our employees and partners authorised to that effect, and shall not be communicated to third parties other than the competent Public/Supervisory Authorities, Social Security Institutions, the above-mentioned Federations and our associates (of accountant office, IT, doctor, lawyer, if needed, management service provider of our webpage). An external partner may process the communication data with you in order to facilitate our communication (sending SMS/e-mails). Our partners shall ensure data privacy and provide us with the necessary guarantees for their protection and safety. Your data shall not be transferred to third Countries.
10. YOUR RIGHTS
As a personal data subject, you may exercise your rights granted by GDPR, in articles 12 to 22. In particular, you are entitled to be informed of whether we process your personal data and for what purpose, to have access to your personal data and to receive copy of them, to request the rectification of your personal data, to request the erasure of your personal data (In that case, we will erase them only if we are not obliged to retain them based on the relevant legislation or if we retain them based on your consent). You are also entitled to request the restriction of your data processing, as well as the transfer of your personal data to you or other party (known as “data portability”). You have also the right to object to the processing of your personal data and to request your exemption from any automated individual decision-making.
In cases where you might have given your consent to the collection, processing and transfer of your personal data for a specific purpose, you are entitled to withdraw at any time your consent to this processing. After becoming aware of the withdrawal of your consent, we will cease to process your information for the purpose or purposes for which you had initially agreed, unless we have other legal basis to do so lawfully.
If you wish to exercise any of these rights, you may send your request either via e-mail: info@hocsh.org or by post to the above-mentioned address, or you may submit in person this request to our secretariat. In order to render the exercise of your rights a simple and effective procedure, you may use the printed GDPR RIGHTS REQUEST (click here).
You may also withdraw your consent to the use of your personal data for safety reasons about our actions/services/offers etc. by unsubscribing from the Newsletter service of our webpage.
You are also entitled to lodge a complaint with the Personal Data Protection Authority, www.dpa.gr.
In any case, you may contact the Data Controller at the aforementioned e-mail addresses in order to submit any request whatsoever and to exercise any of your lawful rights in relation to the processing of your personal data.
11. MODIFICATIONS TO THIS POLICY
HOCSH shall reserve the right to modify at any time the Personal Data Protection and Privacy Policy. Such modifications, additions or erasures will enter into force immediately, namely by posting them on the Webpage. Our Webpage visitors must read regularly this Personal Data Protection and Privacy Policy in order to get informed about any modification made. Any use of the Webpage, after such change, shall constitute acceptance of the changes, modifications, additions or erasures made on behalf of the visitor.
Last revision date: ...... March 2019
