Privacy Policy
Last Updated: 23 September 2024
I. GENERAL
1. Respect for your privacy and the management, protection and security of your personal data are a priority for 100mentors Single Member PC (“100mentors”, “we”, “us”, “our”, and our subsidiaries or affiliates), a private company, registered in Greece, whose registered office is situated at Pl. Kornarou 31, Heraklion Crete, (email: support@wiserwork.ai). This Privacy Policy ("Privacy Policy") informs you, as visitors/ users to the website wiserwork.ai (“Website”), mobile application (“Mobile App”), and web application (‘’Web App’’), (together, the “Platform” or ‘’wiserwork.ai’’ ), or in any other capacity using the services or products offered on the Platform (Services) or participating in promotional or other activities by the Company regarding its services, or using social media channels of the Platform or otherwise, ("you") :
of the types of users registered in the Platform,
of the types of data it collects or produces for you,
of the purpose of collecting and processing your data,
about how these data are processed,
about their recipients and the purpose for which they are processed,
About your personal data when you join Collab Meetings or Common Workspaces?
About the security, transfer and retention of your data
about your rights and choices on your personal data,
about how to contact us concerning any matter you may be concerned about in relation to your personal data.
This Policy does not apply to websites or services or practices of companies that 100mentors doesn’t own or control, such as third-party services you might access through links or other features on the Platform. These other services have their own privacy policies and we encourage you to review them before providing them with personal information.
2. CHANGES IN PRIVACY POLICY
We may modify or replace all or / or part of this Policy at our sole discretion. Ιf there are substantial changes to this Policy or our practices regarding your data change in the future, we will notify you by publishing the changes to our Platform. However, if you wish any clarification or information regarding the changes, or you wish to raise a dispute, a reservation or a question about such changes, you may contact us through e-mail at support@wiserwork.ai. Please note that any information/clarification provided to you in connection with any changes to this Policy does not constitute a replacement, substitution or modification of this Policy. In any case, we recommend that you review this Privacy Policy from time to time, taking advantage of the ability to always find it as a permanent information point on our Platform.
3. THE LEGAL FRAMEWORK
Our Privacy Policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our users. To ensure this, we would like to first explain the terminology used. In this Privacy Policy, we use, inter alia, the following terms:
‘’Personal data’’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘’Processing’’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘’Controller’’ means the competent authority which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
‘’Processor’’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
‘’Recipient’’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.
‘’Personal data breach’’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
‘’Third party’’ is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
‘’Consent’’ of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
4. By accessing the Platform and/or registering for an account on the Platform and/or by using the Services, you acknowledge that you have read, accept and agree with this Privacy Policy. If you continue to navigate on our Platform, or to use our Services, this means that you automatically and unreservedly accept the modified terms of this policy.If you do NOT accept and agree with this Privacy Policy or its modifications, as well as with our Terms & Conditions and Cookie Policy, you have no right to use the Platform or the Services and must cease using them immediately, not providing any personal data. In any case, for any information or clarification, you may contact us while retaining your rights with respect to your personal data as outlined and described in Section V below.
5. DATA CONTROLLER
100mentors Single Member PC, a private company, registered in Greece, whose registered office is situated at Pl. Kornarou 31, Heraklion Crete, is the controller and is responsible for the processing of your Personal Data as described in this Privacy Policy, except where we process your personal data because you use our Services as a result of your relationship with a customer who we supply our services to (for example, if you use our services as a result of your being our customer’s employee or client). Where we process your personal data because you use our services as a result of your relationship with a customer who we supply our services to, we are not the data controller as we would be processing personal data on behalf of our customer as a data processor. Where we are processing your personal data on behalf of our customer, the privacy policy that you should be referring to would be our customer’s privacy policy. Our customer’s privacy policy should inform you as to how your personal data will be processed.
6. HOW TO CONTACT US
If you have any questions or concerts not already addressed in this Privacy Policy, send us an email: support@wiserwork.ai.
II. TYPES OF REGISTERED USERS
“You” may be one of these Users:
Organization Owner [The user who initiates the use of Platform on behalf of an organization who is under a paid scheme with our Company for the provision of the Services of the Platform ( Organization)]
Standard User (A user invited by us or an Organization to register to the Platform. Within this category, users that are invited by an organization may hold one of the following roles:
a. Organization Admin: A user appointed by the Organization Owner to manage the Wiserwork platform within the organization. The Admin has authority over team management and can invite other users.
b. Team Manager: A user invited by either the Organization Owner or Organization Admin to oversee one or more teams. The Team Manager is responsible for managing the activities of the designated teams within the platform.
c. Team Member: A user invited by the Organization Owner, Admin, or Team Manager to join the organization as a member of one or more teams. The Team Member has access to team-specific features and functionalities.
Guest User (A user external to the organization who is invited to use the Platform in one or more specific call, solely by its email address)
III. WHAT PERSONAL DATA WE COLLECT AND HOW | THE PURPOSE AND THE WAY OF PROCESS | THE RECIPIENTS | THE SECURITY , TRANSFER, RETENTION
1.WHAT types of data we collect for you
We collect the following personal data:
i. Identity- Registration and Profile Data: that you provide when registering to the Platform or using its Services. For every type of User, when he creates an account on the Services, we request from you the minimal personal information, such as User’s first name, email address and password. In particular for each type of User:
If Organization Owner, it is required from you to fill in your email, full name, your job role , the name of the Organization, the domain (industry of the organization) and your team name. All the other fields , e.g. User photo, are optional .
If Standard User, it is required from you to fill in your email, full name, your job role) and your team name. All the other fields , e.g. User photo, are optional .
If Guest User, it is required from you to fill in your email, full name and your job role. All the other fields , e.g. User photo, are optional .
Inviting other Users: As an Organization Owner or Organization Admin (type of Standard User) , you can invite other Users to join the Services, in accordance with our Terms of Use through an invitation and providing us their email address . We will collect and store the email you provide with these requests, and will also treat this as personal data in accordance with this Privacy Policy.
ii. Contact Data: (landline or mobile phone, email address) that you provide when registering to the Platform us above or using its Services or contacting our customer support team or through our social media or as part of receiving commercial communications from our company.
iii. User Content and Services Use Information: Information associated with the Platform profile of a Οrganization Owner or Standard User who uses Platform Services under an account or that is provided by a Guest as a participant joining a meeting, which may include text or file or images or audio or graphics or music or video or in-meeting messages, messaging content, transcriptions, chat transcript edits and recommendations, responses to a User or feedback requests, as well as related context, such as invitation details, meeting or chat name, or meeting agenda
iv. Data from Social Media or Third Party Websites (e.g., Facebook, Instagram, Viber, Twitter, Google, Linkedin): If you access or connect to a service of the Platform via a social media service or link a Platform service to a social media service, the data we collect may also include your user ID and/or the username associated with that social media service, information or content you have allowed the social media service to share with us, as well as your profile picture, email address, or your friends' lists, as well as personal data you have publicly disclosed in connection with that specific social media service. When you access the Platform services through social media services or other providers or when you link a Platform service with social media services, you authorize the Company to collect, store, and use such personal data and content in accordance with this Privacy Policy. This category also includes data collected from third-party providers who offer their services on the platform and have their own privacy policies.
v. Public Data and Posts consisting, for example, of comments or content you post in the Platform services but also in message boards, discussion groups, blogs, and other public user forums. Your personal data accompanying such content, which may include a pseudonym, username, comments, likes, status, profile information, and photograph, becomes public information. Public information and posts are always public, meaning they are available to everyone and may appear in search results on external search engines.
vi. Activity Data and Other Data We May Collect Automatically. When you access and interact with the Platform’s services, we may automatically collect specific information about these visits (log-in information, device information, network information, usage information, etc.). For example:
Login Information: We record information regarding your use of the Services, including your Internet Protocol (IP) address, the type of browser you use, frequency of access, pages viewed, number of clicks, and the page you visited before navigating to our Services.
Device Information: We collect information about the electronic computer or mobile device you use to access our Services, including hardware model, operating system, version, unique device identifiers, and mobile network information.
Network Information: We may gather details about your network, such as information related to devices, nodes, settings, connection speeds, and network and application performance.
Usage Information: We can collect data about the usage of our Services and certain tools, such as which pages on the Platform you have visited, how frequently tools are used, duration and quality of usage, test data, task configuration data, and central data.
vii. Data Collected by Cookies and Other Tracking Technologies. We may also collect cookies and other tracking technologies (such as browser cookies, pixels, beacons) to enhance your experience, allowing us to personalize our content based on your interests. These technologies can be utilized to gather and store activity data related to your use of the Platform's services, such as the pages you have visited, the videos and other content you have viewed, the search queries you have submitted, and the advertisements you have encountered. For more information, please refer to our Cookie Policy.
Please note that the types and amounts of personal data collected will vary depending on the type of the User as described above and how they use the Platform. We need certain types of personal data so that we can provide the Services to you. If you do not provide us with such data, or ask us to delete it, you may no longer be able to access or use our Services.
Special category personal data
We do not collect data and we kindly request that you do not send or disclose data which is, by its nature, particularly sensitive [e.g. genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership,data that may facilitate identity theft or payment fraud (like social security files, financial account numbers, credit card details and government identification numbers)] unless it is volunteered by you. Ιn any case, and if you disclose this data to us voluntarily, it is at our disposal to erase them from the Platform.
2. HOW do we collect your Personal Data
2.1.We collect DIRECTLY BY YOU the personal information and data mentioned in the Section ΙΙΙ, cases 1.i, 1.ii, 1.iii.
2.2. We collect with AUTO AUTOMATIC MEANS the personal information and data mentioned in Section III. 1, cases vi-vii
2.3. We collect from third parties the following data and information about you:
Data from Social Media and Third Party Websites (III. 1 Case iv.)
Your personal data may be shared with us by independent third parties when there is a legal basis for processing, and they have the relevant right to do so. In such cases, you are obligated to be informed about the processing of your personal data by the respective Data Protection Statement of these third parties. These organizations may include social media platforms.
Public Data and Publications (III. 1 Case v.)
3. Personal Data from Children
In relation to the offer of online services directly to a child, GDPR indicates that the processing of the personal data of a child shall be lawful where the child is at least 16 years old. Where the child is below the age of 16 and above the age of 13 years old, such processing shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child and can be verified with the available technology. Thus, if a child is entitled to gain access to the Platform, consent may be obtained by 100mentors: i. From the educator of the child if the child is a student and the Educator is an Organization Owner or Admin(Educator Consent). We require that the educator has obtained, directly from the parents, prior parental consent for their child to use the Platform and its Services for education purposes at the school; ii.Directly from the parent (Parent Consent). We may obtain parental consent directly from a parent if a child between the ages of 13-16 years old is entitled to register to the Platform by creating his or her own account. 100mentors does not permit children under the age of 13 to create an account and does not knowingly collect personally identifying information from children under the age of 13.
4. HOW do we use your personal data
The primary reason we collect data related to you is to inform you and provide you with the Services of the Platform, allowing you to interact with these services and participate in any feature of the Platform. The use of the services provided by the Platform, requires ensuring the ability to communicate with you. We are allowed to process your personal data to provide personalized services, in accordance with the law (Article 6(1)(b) of Regulation (EU) 2016/679). We also collect data for the following purposes:
-To measure, analyze, and enhance the Services and functions of the Platform.
-To provide and deliver the Services and the User Content you request through the Platform and the Third Party Providers
-To resolve technical issues related to the Services and the Platform and send you technical warnings, updates, security notifications, and support messages and processes.
-To enhance your experience through the Company's Services (both online and offline) by providing content that may be relevant and interesting.
-To communicate with you, including to send you information or marketing about our Services and events.
-To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our systems and Services.
-To respond to your comments, questions, and requests, and provide customer support services.
-For the purpose of compliance with applicable laws or legal processes and/or to respond to requests from relevant governmental authorities.
-To complete a corporate transaction such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of the Company's business (including any bankruptcy or similar proceedings). For example, if the Company is involved in a merger or transfer of all or a substantial part of its operations, the Company may disclose and transfer your personal data to the parties participating in the transaction as part of that transaction.
-To personalize and improve the Services and offer advertisements, content, or features that match user profiles or interests.
-To link or combine with information we receive from third parties for better understanding of your needs and improvement of our services.
-To satisfy your rights regarding your personal data.
-For other purposes, we will notify you or specify on a case-by-case basis at the point where information about you is initially collected.
-Aggregated or De-Identified Information. We aggregate or anonymize Personal Data to ensure it can no longer be linked to you, and utilize this data to assess the performance of our Services, enhance and introduce new features, carry out research, and for other similar objectives. Additionally, we may occasionally share or publish aggregated information, such as general user statistics, with third parties. This information is collected through our Services, cookies, and other methods outlined in this Privacy Policy. We will handle and use de-identified information in an anonymous or de-identified format and will not attempt to re-identify it, except as required by law.
Existence of automated decision-making
Our Platform is primarily focused on helping people collaborate or offering recommendations while still relying on human involvement for key decisions. So as a Company we do not use automated decision-making on the Platform .
5. ON WHAT LEGAL BASIS do we use your personal data
The Legal basis on which we make use of your information is either one of the following:
i. Performance of a contract to which you are a party.
ii. Legitimate Business Interest
iii. Compliance with Legal Obligations to Which We Are Bound
iv. Consent
For Students, please read additionally the Section III case 3 of this Privacy Policy.
For Users who access the Platform and/or register to create an account on the Platform and/or use the Services under the force of a separate agreement between 100mentors and an Organization, please read additionally the Section III case 6.1. of this Privacy Policy.
In particular :
| Purpose of Processing | Data we process for this purpose | Legitimate Processing Basis |
|---|---|---|
| To provide and deliver the Services and the User Content you request through the Platform and the Third Party Providers |
Identity- Registration and Profile Data User Content and Service Use Information Data from Social Media or Third Party Websites Activity Data and Other Data We May Collect Automatically Public Data and Posts Data Collected by Cookies and Other Tracking Technologies and/or any combination of the above. |
(a) performance of the contractual obligations (b) compliance with its legal obligations. (c) legitimate interest (d) consent in cases of data provided by you on a voluntary basis. (e) consent in cases of a child between 16 and 13 years old |
Customer Service and Handling including:
|
Processing for this purpose includes A) the absolutely necessary details you give us when submitting your request, that is
|
(a) compliance with the Company's legal obligation to adopt pre/post-sale customer service tools/means to respond to your queries related to the exercise of your rights. (b) the legitimate interest of the company to respond to your requests through various communication channels, optimize customer service and management, and provide our customers with the ability to communicate with them and address any of their issues in the best possible way based on their needs and always to the benefit of the subject and which is reasonably expected by the subjects. (c) performance of a contract if you contact us specifically to raise any issues related to your order. (d) user’s consent to receive communication from the Company for this purpose when they ask the Company to contact them. |
Advertising & Marketing
|
For the purpose of advertising & marketing, the company may process: Identity- Registration and Profile Data Contact Data Activity Data and Other Data We May Collect Automatically Public Data and Posts Data Collected by Cookies and Other Tracking Technologies and/or any combination of the above. |
(a) a legitimate interest of the Company in processing the data of its users, for the purpose of direct commercial communication regarding related products or purposes (b) Consent in cases where you voluntarily provide us with your data, authorizing us to send you updates when accepting both the respective Cookies and email correspondence. |
Business analyzes and improvements
|
Identity- Registration and Profile Data User Content and Service Use Information Data from Social Media or Third Party Websites Activity Data and Other Data We May Collect Automatically Public Data and Posts Data Collected by Cookies and Other Tracking Technologies and/or any combination of the above. |
(a) compliance with a legal obligation for information security and confidentiality (b) a legitimate interest for network security and to prevent fraud and unauthorized access to data, for our business continuity, upgrading our systems and partners, developing our business and managing and optimizing our technical systems, our commercial processes, operations that override the rights and freedoms of subjects that they reasonably expect that such processing may be performed for this purpose. (c) Performance of contract with you in order to provide uninterrupted provision of Services |
Statistical analysis to evaluate and improve Platform Services and procedures that includes:
|
All the data we collect in the context of the previous processing purposes as aggregated and statistical data only, taking all the necessary safeguards not to reveal the identity of the subjects. Moreover, data collected from the corresponding cookies that perform such processing will also be used. |
(a) for the further processing of aggregated data for the purpose of statistical analysis to improve its products and services, taking all the necessary safeguards to collect and process data that do not identify a particular subject and do not affect the rights and freedoms of the data subjects. (b) to market our products, analyze the usability and functionality of the Platform, to verify our customers’ satisfaction, to identify our customers’ preferences for our products, to improve our business performance, to improve our partnerships, always with respect for your rights, freedoms and interests concerning your personal data. (c) Performance of Contract with you if this process is part of an agreement with an Organization who gives access to a User |
Where the legal basis for us processing your personal data is that you have provided your consent, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make processing which we undertook before you withdraw your consent unlawful. You can withdraw your consent by contacting us in our contact support@wiserwork.ai.
6. How and Where We Share Your Personal Data
6.1. The Company may disclose your personal data for the purposes of this Privacy Policy in the following categories:
In the context of the operation of our Platform, the provision of Services and your best service, our Company reserves the right to cooperate with third-party service providers that provide us with support and access only to your data that are absolutely needed in order to provide their services to us , including providers of hosting services, ai technology providers, customer service vendors, cloud services, content delivery services, data warehouse services, support and safety monitoring services, email communication software, web analytics services, payment and transaction providers, and other information technology services providers. Pursuant to our instructions, these parties will access, process, or store Personal Data only in the course of performing their duties to us. Review also our Terms of Use for the Third Party Providers
Advertising and marketing companies.
Data analysis and research companies.
Information system supply and support companies.
Accountants and lawyers.
Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Data and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
Government and Competent Authorities or Other Third Parties: We may share your Personal Data, including information about your interaction with our Services, with government authorities, industry peers, or other third parties in compliance with the law (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.
Affiliated companies in their capacity as data controllers or data processors.
Organization Owners and Organization Administrators: When you join our Platform via an Organization account or your right to access, register and use the Platform and its Services is under a separate contract agreement between 100mentors and an institution(educational or not) and/or a company and/or a business unit and/or other legal entity, we may share some of your data with the organization or the contractual party or the administrator of that account/ organization may access and control your account. In addition, if you create an account using an email address belonging to your employer or Organization, we may share the fact that you have an account and certain account information, such as your email address, with your employer or organization to, for example, enable you to be added to their Organization account.Upon your registration to the Platform under the force of such conditions, you consent our right to share this data with all the above.
With third parties under a contract: If your right to access, register and use the Platform and its Services is under a separate contract agreement between 100mentors and an institution(educational or not) and/or a company and/or a business unit and/or other legal entity ( herein Contractual Party), we may share some of your data with the Contractual Party who gave you the right to access, register and use the Platform, such as your email, name, your usability data. Upon your registration to the Platform under the force of such an agreement, you consent to our right to share this data with the Contractual Party.
Other Users and Third Parties You Share Information With: Certain features allow you to display or share information with other Users. Please keep in mind that information (including personal Information) or content that you voluntarily disclose to others - including to other users you interact with through the Services - can be viewed, copied, stored, and used by the people you share it with without our liability. We cannot control the actions of people with whom you choose to share information and we are not responsible for the collection, use or disclosure of such information or content by others. Please check Section III, case 7.
In courts, judicial authorities, and other government bodies if required by law or legal procedures or if we believe that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with the investigation of suspected or actual unlawful activities.
If you have agreed to receive direct marketing from us and our affiliated companies, we may also share your data for this purpose.
Aggregated Information and Non-Identifying Information: Notwithstanding the above, we may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified or non-personally identifiable information (such as statistics about visitors, traffic and usage patterns), including with users, partners or the press in order to, for example, demonstrate how the Platform is used, spot industry trends, or to provide marketing materials for US. Any aggregated information and non-personalized information shared this way will not contain any personal information.
Social Media Platforms: Where permissible according to applicable law, we may share certain limited personal information with social media platforms (such as Google or Facebook) and other Platforms, applications or partners, to generate leads, drive traffic to our Platforms or otherwise market and advertise our products or services on those Platforms or applications.
With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Policy. 100mentors does not sell User personal data.
7. Who Can See, Share, and Process My Personal Data When I Join Collab Meetings or Common Workspaces?
When you join colab calls or use the common workspaces feature of the Platform, your User Content and personal data and information may be visible to other participants and collaborators, including third parties outside the call. Here’s a breakdown of who can access your data and how:
All types of Users except Guests can invite additional users (including Guests) as collaborators to collab calls and workflows.
The calls are recorded or stored or edited for AI-generated content but recording are not accessible for replay or download or sharing to any User. The Organization Owners and Organization Admins can access personal data for participants in the collab calls.
Other Users and Guests as Participants and Invitees may see your display name, and profile pictures. During the call, participants cannot record but they may share content such as audio, video, notes created by AI during the call, and any messages exchanged with the group or directly with individuals.
Call Recordings and Transcripts:The calls are recorded by the Platform and AI-generated notes can be stored for review. Transcripts created from these recordings may use AI to distinguish between different speakers to ensure accuracy.
Guests: If you are invited to a call as a guest, your participation may be limited, but the Organization Owner and Organization Admins may still have access to your name, and other details provided for the call. Guests may also be able to access recordings or AI-generated notes if permissions are granted by the Organization Admins
In-Meeting/Workspaces Messages and Content: All the collaborators in a workspace or collab call can see sender and receiver name.
8. Data Transfers
In principle, we transfer and store the personal data that we collect about you in the countries of the European Economic Area (“EEA”). However, for service efficiency purposes, since for example some of our service providers or our users are based in countries outside of the EEA (“third countries”), we may also transfer some of your data to third countries, including the United States. The third countries may not have the same data protection laws as the EEA countries. In that case, we will protect the data as described in this Privacy Policy and ensure that the third parties agree to comply with applicable legal requirements providing adequate protection for the transfer of data and ensuring that appropriate safeguards have been put in place (especially standard contractual clauses based on the EU Model Clauses). By using the Platform and the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to countries outside of the EEA.
9. Data Security
100mentors takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. We also require our Third Party Providers and other service providers to comply with strict requirements regarding the protection and security of personal data. The Company, through its respective contractual commitments and partners, takes all necessary security measures to protect and ensure the confidentiality and integrity of personal data. In any case, the security of these data within the Platform's environment is subject to reservation due to reasons beyond its sphere of influence, as well as reasons due to technical or other network failures that are not controlled by the Company, or reasons of force majeure or fortuitous events. It is also your responsibility to ensure that the equipment (e.g., personal computer), software, and telecommunications equipment you use are adequately secure and protected from malicious software (e.g., viruses). You should be aware that without sufficient security measures, there is a risk that the data and passwords you use may be disclosed to unauthorized third parties
10. Data Retention
We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Some of the Personal Data that we have collected may become anonymous after their deletion in order to develop the Services. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
IV. YOUR PERSONAL DATA RIGHTS
1.With regard to your personal data we collect and process, you have the following rights under European Data Protection Regulation (EU) 2016/679 on personal data protection:
- Right of confirmation. You have the right to obtain from us the confirmation as to whether or not personal data concerning you are being processed.
- Right of access. You have the right to obtain from us free information about your personal data stored at any time and a copy of this information.
- Right to rectification. You have the right to obtain from us the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the ability to change or alter any incomplete or inaccurate data we hold about you. In any case, please take into account that, by actively making your personal data available to us through any procedure, such data should be true and accurate and you should notify us any change or modification of your data. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy Policy.
- Right to erasure (Right to be forgotten). You have the right to obtain from us the erasure of personal data concerning you where one of the following grounds applies:
as long as your personal data are no longer necessary for the purpose for which we need to keep processing them
You withdraw consent to which the processing is based, and where there is no other legal ground for the processing.
You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
- Right of restriction of processing. You have the right to obtain from us restriction of processing where one of the following applies:
The accuracy of the personal data is contested by you for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead.
We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
- Right to data portability.You have the right to receive the personal data concerning you which was provided to us in a structured, commonly used and machine-readable format. You have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
- Right to object.You have the right granted to object, on grounds relating to you particular situation, at any time, to processing of personal data concerning you , which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. If we process personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you by the the company for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- Automated individual decision-making, including profiling.You have the right notto be subject to a decision based solely on automated processing, including profiling,which produces legal effects concerning you or similarly significantly affects you a slong as the decision (1) is not is necessary for entering into, or the performance of, a contract between us or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on yours explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the company shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of us to express our point of view and contest the decision.
- Right to withdraw data protection consent. You have the right to withdraw your consent to processing your personal data at any time.
- You have the right to make a complaint to the relevant data protection supervisory authority in Greece or to seek a remedy through the courts if you believe that your rights have been breached.
2. If you wish to exercise any of your rights or if you have any complaints, please contact us using the contact details provided in Section I.6. In the case of submitting a request to exercise your rights, the Company will respond to your request within one (1) month from the date of submission. This deadline may be extended by an additional two (2) months following your prior notification, taking into account the complexity of the request and the number of pending requests. The data subject should include in their request their name, email address, the nature, and the date of the request. The Company must: (a) ensure that the subject matter of the request for the exercise of rights is sufficiently clear. If it is not clear, the individual responding from the Company must contact the requesting party to request further information, and (b) verify the identity of the requesting party. This must include both proof of identity and proof of address
Once the Company receives any additional information required for the subject matter of the request and the appropriate identity verification documents from the data subject, the Company acknowledges the proper receipt of the request for the exercise of rights through communication with the data subject. Subsequently, the Company must confirm whether the request for the exercise of rights is valid. If the request for the exercise of rights is not valid, the Company must communicate with the data subject and explain the reasons for the invalidity of the request. However, if the request for the exercise of rights is valid, the Company must take appropriate action and respond to the request for the exercise of rights. All requests for the exercise of rights will be completed within one calendar month from the receipt of the request for the exercise of rights.
In some cases, the examination, investigation, and resolution of a request for the exercise of rights may require third parties to take certain actions, such as modifying their records in response to a request for correction of personal information or deleting personal information they hold in response to a deletion request. Therefore, in this case, the Company communicates with all third parties that have personal data related to the data subject and asks them to take all necessary actions and ultimately confirm to the Company that they have done so. Copies of all correspondence and other materials received by the Company in relation to any request for the exercise of rights will be retained in the Company's records for 2 years.
If you believe that your rights are in any way infringed, you can also file a complaint with the local Supervisory Authority:
Hellenic Data Protection Authority (www.dpa.gr).
Postal address: 1-3, Kifissias Avenue, PC 115 23, Athens
Call Center: +30 210 6475600
Fax: +30 210 6475628
E-mail: contact@dpa.gr