Terms of Use & Information on the Processing of Personal Data during the use of the ORAMA platform for the submission of job applications

Through the ORAMA platform (hereinafter, the “platform”), prospective employees (hereinafter “candidates” or “users”) may, by accessing the HEDNO S.A. website (hereinafter “HEDNO” or the “Company”), either via a desktop computer or a mobile device (smartphone or tablet), submit an application for a vacant position at HEDNO. They also have the ability to submit and manage the required supporting documents for their application.

1. Terms of Use:

1.1 Platform features

The operation and use of the platform are governed by these Terms of Use (hereinafter, the “Terms”), the Information Notice on the Processing of Personal Data of the platform users, as in force from time to time, as well as any other HEDNO policy related to these Terms and to the operation of the platform.

The use of this platform requires and entails the full understanding and unconditional acceptance of these Terms, as well as the users’ compliance with the applicable legislation, the instructions, and the policies of HEDNO. Users of the platform (hereinafter, the “users”), by accessing the platform or making any use of it, are deemed to have acknowledged, fully understood and confirmed their acceptance of the Terms and their compliance with them and with applicable law. Furthermore, by accessing or using the platform, users declare and warrant that they have the legal capacity to accept and comply with these Terms.

Access to the platform is granted to users at the sole discretion of HEDNO. Users do not acquire any right of access to the platform automatically. HEDNO determines the categories and rights of platform users, as well as the possibility of access and its duration.

HEDNO does not guarantee the uninterrupted operation of the platform, nor the fulfillment of all user applications submitted through the platform. Finally, HEDNO reserves the right to suspend or terminate users’ access to the platform at any time, without liability, in the event of a breach of the Terms or applicable law, or for any other reason at its sole discretion.

1.2 Access to the platform

The purpose of the ORAMA platform is to manage applications submitted by prospective employees for the filling of vacancies at the Company through the publication of relevant job posting(s).

User access to/log-in to the platform is carried out by creating a profile by the prospective employee/user.

Users are required to enter their basic details (full name, telephone number, mobile number, email, region, postal code) and to set their personal login credentials (username and password).

The basic identification details (full name), contact details (telephone number, mobile number, email, region, postal code), CV data, any additional supporting documents required for specific job positions, and the data included in the declarations submitted by the user in relation to HEDNO job postings, are cumulatively required for the submission of a job application and for the verification of the user’s contact details.

1.3 Platform use

The use of the platform is provided free of charge, without any financial cost to the user from HEDNO. HEDNO is not responsible for or connected to the pricing policies of third parties, particularly mobile network providers, regarding any costs associated with connecting users’ devices to the Internet.

1.4 User obligations

Users accept, agree, and acknowledge that they will use the platform lawfully and appropriately.

Users are required to:

  • Enter clear and accurate information on the platform and promptly inform HEDNO in the event that the information provided is or becomes inaccurate, unclear or incorrect, as well as in the event of loss of access to the platform or detection of any breach thereof.
  • Use appropriate devices and equipment for accessing the platform and perform the necessary actions within it.
  • Not use the platform for purposes other than those for which it was created; in particular, not use the platform for unlawful purposes or activities (indicatively, impersonation, alteration or falsification of information in any way, transmission or publication of viruses, malicious software or other malicious code on the platform, and interference with or disabling of its operation are prohibited).
  • Not infringe the rights of third parties through the use of the platform.

Users bear full responsibility for the accuracy of the data they declare when accessing and using the platform. Furthermore, users are responsible for the security of their devices, systems and activities carried out through the platform and are required to duly protect their personal data associated with the platform.

In order to safeguard the integrity and security of the platform and ensure compliance with applicable legislation, HEDNO reserves the right to restrict or deny access to the platform at any time, without cause and without prior notice to the user.

Access to and use of the platform are subject to these Terms.
If the user does not agree with and fully and unconditionally accept the Terms, they may not proceed with using the platform.

1.5 Limitation of Liability – Disclaimer

The platform is provided “as is” and “as available”, without any warranty of any kind, express or implied, from HEDNO, including, indicatively, with respect to its uninterrupted operation or the continuous availability of access for users.
To the extent permitted by applicable law, HEDNO: (a) assumes no liability whatsoever, whether contractual, tortious (including negligence or strict liability), or otherwise, in connection with the platform and its use; and
(b) provides no warranties of any kind, express or implied, including, indicatively, regarding the uninterrupted operation of the platform or the continuous availability of user access. Subject to the above and applicable law, HEDNO shall bear no liability for any technical or other malfunction of the platform, or for any damage caused to the user or their equipment arising from its use. Finally, HEDNO shall bear no liability for any damage resulting from improper use of the platform.

The platform is intended for users aged 18 and over. Persons below this age are not permitted to create an account or otherwise use the platform.

1.6 Amendment of Terms

HEDNO S.A. reserves the right, at any time, to unilaterally amend these Terms without prior notice, by updating the relevant content on the HEDNO website and the platform where the Terms are published. Any such changes shall take effect from the time they are published on the platform. Users are advised to regularly review the Terms of Use for any updates.

1.7 Intellectual and Industrial Property Rights

The intellectual property rights in the content and services of the platform, including, indicatively and not limited to, texts, photographs, designs, software, all types of files, and the platform’s trademarks/logos, are protected under applicable intellectual and industrial property laws and belong exclusively to HEDNO or to third-party providers designated by HEDNO. Any copying, distribution, transmission, modification, resale, creation of derivative works, or misleading the public as to the actual provider of the platform content is strictly prohibited. It is noted that the above actions may constitute an infringement of HEDNO’s or third parties’ intellectual and/or industrial property rights, who are entitled to seek compensation for any damage suffered in accordance with applicable law.
Users are entitled to use the platform solely for the duration of the validity of the Terms and may store individual information for personal use, in accordance with the purpose of the platform and these Terms.

1.8 Applicable Law

These Terms and any future amendments thereto shall be governed exclusively by Greek law. If any provision of the Terms or any future amendment thereof is found to be contrary to law, it shall automatically cease to apply, without in any way affecting the validity of the remaining provisions.
Any dispute arising out of or in connection with the interpretation or application of the Terms, or the use of the website in general, which cannot be settled amicably—such settlement being optional and at the parties’ discretion—shall fall within the exclusive jurisdiction of the courts of Athens.

1.9 Duration and Termination

HEDNO reserves the right to modify or terminate the operation of the platform at any time, for any reason, without prior notice to users. Upon termination of the platform’s operation, all provisions of these Terms which, by their nature, are intended to remain in force shall continue to apply.

INFORMATION ON THE PROCESSING OF PERSONAL DATA

Ι. Introduction

HEDNO S.A. (hereinafter referred to as “HEDNO” or “the Company”) places the protection of personal data it processes, in its capacity as Data Controller, among its top priorities, in full compliance with the applicable personal data protection legislation. Such processing is carried out under the conditions and safeguards, and in general in compliance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”), as in force, as well as the applicable national legislation [Law 4624/2019, and the Guidelines and Decisions of the Hellenic Data Protection Authority (hereinafter the “HDPA”)], and in accordance with this Information Notice and the relevant HEDNO policy.

This Information Notice aims to inform users/prospective employees (hereinafter “users”, “candidates”, or “data subjects”) of the ORAMA platform (hereinafter the “Platform”), which is designed to facilitate the submission of applications for vacant positions and through which users access the Platform to submit such applications, about the personal data collected and processed by the Company in the context of using the Platform, as well as the manner and purposes of the collection, storage and use of such personal data.

IΙ. Categories of Data Collected and Processed during Use of the Platform

The Company collects and processes personal data provided by candidates when creating an account on the Platform, completing the application form via the Platform, data required for logging into the Platform, as well as data necessary for the operation of the Platform. In particular, HEDNO collects and processes the following personal data of data subjects:

  • Full Name
  • Email address
  • Telephone number
  • Mobile phone number
  • Area
  • Postal code
  • CV data (e.g. education, professional experience, foreign languages, professional licence, professional certifications)
  • Information included in the cover letter or in other supporting documents
  • Any other data voluntarily submitted through the application
  • Data contained in the declaration regarding compliance with the job requirements

The above details is required to be completed by users in order to submit a job application.

Additionally, HEDNO may collect and process the following personal data, provided that the data subject chooses, at their discretion, to supply such information:

  • Date of birth
  • Street and number / P.O. Box
  • Country
  • Regional Unit
  • City / Municipality

Furthermore, HEDNO collects and processes the following categories of personal data for the management of Platform users:

  • User authentication data (e.g. username)
  • Digital footprint data (e.g. logs, metadata derived from use of the Platform)

IΙΙ. The purpose of processing your personal data

HEDNO collects and processes the above personal data for the following purposes:

A. Management of applications submitted by prospective employees for the filling of vacant positions, in the context of active or inactive job postings;

B. Management of the Platform and user accounts within it.

The processing of personal data for the above purposes is necessary for HEDNO to collect and manage job applications, communicate with candidates, and ensure the security and proper functioning of the Platform.

In addition, HEDNO may, on a case-by-case basis, process personal data for the management of data subject requests under the GDPR, the investigation of potential personal data and information security breaches, and the handling and resolution of judicial and out-of-court matters.

ΙV. Legal Basis for Processing

HEDNO processes the above personal data as follows:

A. For the purpose of managing applications submitted by prospective employees for vacant positions, processing is carried out upon the request of the data subject prior to the conclusion of a contract (Article 6(1)(b) GDPR), namely for the potential conclusion of an employment contract with HEDNO following the user’s application.

B. For the purpose of managing the Platform and user accounts within it, processing is carried out on the basis of the legitimate interests pursued by HEDNO (Article 6 (1)(f) GDPR), as well as in order to take steps at the request of the data subject (the candidate) prior to the conclusion of a contract (Article 6 (1)(b) GDPR), and to ensure the proper functionality of the Platform and information security.

Furthermore, for the management of data subject requests arising from the GDPR and the investigation of potential personal data and information security incidents, processing is necessary for compliance with a legal obligation to which HEDNO is subject (Article 6 (1)(c) GDPR), specifically compliance with obligations under Articles 12–22 and 33–34 of the GDPR. For the handling and resolution of judicial and out-of-court matters, processing is carried out on the basis of the legitimate interests pursued by HEDNO (Article 6 (1)(f) GDPR), namely for the establishment, exercise, or defense of legal claims before courts and authorities.

HEDNO does not process personal data for the purposes of automated decision-making and/or profiling that produces legal effects or similarly significantly affects individuals.

V. Recipients of personal data

The above data are collected through the aforementioned HEDNO S.A. platform, to which access is granted exclusively to authorized Company personnel responsible for the collection, management and evaluation of job applications and duly trained in the handling of personal data. These employees are bound by confidentiality clauses and are granted specifically authorized access rights to the relevant data.
The Company grants access, on a case-by-case basis and for a specified period, to a third-party service provider acting as a data processor on its behalf (hereinafter the “processor”), for the purposes of providing technical support for the Platform. The processor implements appropriate measures to ensure the confidentiality and security of personal data and has entered into a data processing agreement with HEDNO containing all necessary contractual commitments, in accordance with applicable law. The processor may designate specifically authorized individuals, who are likewise bound by confidentiality clauses and possess authorized access rights to the relevant data.
The Company does not disclose personal data to third parties except where there is a lawful basis for doing so; in particular, where such recipients have been granted specific authorized access rights by HEDNO S.A., or where disclosure is strictly necessary for the establishment, exercise or defense of legal claims, or for compliance with the Company’s legal obligations under applicable law.
Such disclosures may include, by way of example, competent supervisory, auditing, law enforcement, prosecutorial, independent, judicial, public and/or other authorities and bodies, within the scope of their statutory powers, duties and competences, where disclosure is required or permitted by law, following duly submitted lawful requests in the exercise of their functions. Disclosure may also take place pursuant to court orders and/or to lawyers, law firms, bailiffs, notaries, experts or court-appointed experts, in the context of legal proceedings for the protection of the Company’s rights and interests.
It is noted that, with regard to successful candidates, recruitment supporting documents, certificates and any licenses required for the position may be disclosed to the competent authorities for the purpose of verifying their validity.

VI. Transfers of Data to Countries outside the European Economic Area (EEA) or to an International Organization

The Company does not transfer personal data outside the EU/EEA or to any international organization.

VΙΙ. Data security safeguards

In the context of the above processing, and in accordance with the applicable legal framework, all appropriate technical and organizational measures are implemented to ensure the security of personal data, to safeguard the confidentiality of their processing, and to protect them against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, as well as against any other form of unauthorized or unlawful processing. These measures are also intended to prevent, as far as possible, incidents of data breaches caused by malicious actions, accidental loss, or unauthorized access or use. By way of example, personal data are stored securely within the Company’s own infrastructure. Furthermore, with respect to the possibility of a system breach, the Company has established adequate incident management procedures to ensure the proper handling of such cases and the effective mitigation of risks.
It is noted that all persons authorised to access and/or process the above personal data, as well as any persons acting as data processors, comply with the security safeguards set out herein and are bound by confidentiality agreements.

VIIΙ. Data retention period

The period for which personal data are retained is determined in accordance with the principles governing personal data processing, as laid down in Article 5 of the GDPR, taking into account HEDNO S.A.’s competences and role under the applicable legal framework. The above data will be retained by HEDNO for the period required to fulfil each of the purposes for which they were collected and will not be kept longer than is strictly necessary for the achievement of the purposes described above. Once the purpose of processing your personal data has been fulfilled, the data will be deleted, unless their retention is necessary for compliance with a legal obligation or for the protection of the Company’s legitimate interests, always in accordance with the applicable legislation.
More specifically, the data of candidates on the Platform will be retained for a period of six (6) months following the completion of the recruitment process for each position.
Personal data recorded in our server security logs for information security purposes (e.g. IP address, metadata) are retained for one (1) year from the date of collection.

ΙΧ. Your rights as α data subject.

The Company is required, under the General Data Protection Regulation (GDPR), to ensure the fulfilment of data subjects’ rights by facilitating their exercise in a concise, transparent, intelligible and easily accessible form.
With respect to your personal data subject to the processing described above, you have the following rights:

Right to Information and Access (Articles 12–15 GDPR): You have the right to be informed and to obtain access to your personal data, as well as to receive additional information regarding their processing.

Right to Rectification (Article 16 GDPR): You have the right to request the correction, modification, supplementation, or updating of your personal data, where such data are inaccurate, outdated, or incomplete.

Right to Erasure (Article 17 GDPR): You have the right to request the deletion of your personal data, insofar as this right is not subject to limitations under applicable law or other relevant restrictions.

Right to Restriction of Processing (Article 18 GDPR): You have the right to request the restriction of processing of your personal data when: (a) the accuracy of the data is contested, pending verification; (b) the processing is unlawful, and you request restriction of use instead of deletion; (c) the data are no longer necessary for processing purposes, but you require them for the establishment, exercise, or defense of legal claims; or (d) you have objected to the processing, pending verification of whether legitimate grounds exist that override your objection.

Right to Data Portability (Article 20 GDPR): You have the right to receive, free of charge, your personal data in a format that allows you to access, use, and further process them. You also have the right, where technically feasible, to request the direct transmission of your data to another data controller. This right applies to data that you have provided to us and that are processed by automated means, based on your consent or for the performance of a contract.

Right to Object to Processing (Article 21 GDPR): You have the right to object at any time to the processing of your personal data, under specific conditions provided by law.

Right to Object to Automated Individual Decision-Making, Including Profiling (Article 22 GDPR): You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar way. At present, the Company does not engage in automated individual decision-making. However, should it decide to implement such processing in the future, it will inform the Data Subjects in advance and ensure full compliance with all applicable legal requirements.

Right to Withdraw Consent (Article 7 GDPR):You have the right to withdraw your consent at any time, to the extent that processing is based on consent.

Right to Lodge a Complaint with the competent authority: If you believe that: (a) any of your requests has not been adequately and lawfully satisfied, or (b) your right to the protection of your personal data is being infringed by any processing carried out by us, you have the right to lodge a complaint with the Hellenic Data Protection Authority (HDPA) (Submit a complaint to the Authority | Hellenic Data Protection Authority).

X. Contact

For any matter relating to the above, or to exercise your rights as a data subject, you may contact HEDNO’s Data Protection Officer (DPO) at the following addresses: dpo@deddie.gr or 98120 Syngrou Avenue, 117 41 Athens, Greece