Data Privacy Policy
PERSONAL DATA PROTECTION POLICY

Introduction

GAIN CONSULTING S.A. (or “Company”) recognizes that the protection of customer personal data is of the utmost importance. For this reason, appropriate measures are taken to protect processed personal data and to guarantee that personal data processing is conducted, in all cases, in conformance with the legally specified obligations by both the Company and the third parties who process personal data on behalf of the Company.

Communication Responsible for Personal Data Protection Issues

GAIN CONSULTING S.A., headquartered in Athens, Greece, at the address Evrimedontos 4 (e-mail: [email protected]; tel. no.: +30 210 9947100; fax: +30 210 99447111; website: https://www.gainconsulting.ai) states that, in the course of performing its business activities, it conducts processing of customer personal data, by the domestic legislation in effect and the EU Regulation 2016/679 on Personal Data Protection regulating the processing and free movement of personal data (General Regulation for Data Protection, to be referred to in the future as the Regulation) in effect.
Concerning any issue arising from processing personal data, the persons involved may send a message to the e-mail address [email protected] or call the telephone number 210 9947100.

Classification of personal data to be processed

GAIN CONSULTING S.A. shall collect and process only the necessary and appropriate personal data to attain the stated Company goals. The personal data we collect for the attainment of these goals are divided into two categories:

1. Personal data supplied by you, such as:
Identification data (full name, date of birth, I.D. card or passport numbers, tax I.D. no., Public Finance Service, etc.). Communication data (mailing address, home/ mobile phone numbers, e-mail addresses). Other data include professional specialization, job post description, etc.

The data used for your identification and/or legitimacy, including any communication data, are necessary for any transactional or contractual relations with the Company. Insofar as the remaining data to be processed are concerned, such data shall, in all cases, be based on the contractual relation with the Company, present or future, and/or the service on offer.
We inform you that you are to notify GAIN CONSULTING S.A. on time concerning any change in any data, as mentioned earlier, you may have submitted on your own initiative, and to respond to any of the Company’s requests to update such data.

2. Personal data involving you collected by GAIN CONSULTING S.A. from other sources, such as:

Data from the use of Company electronic and/or digital goods and services, such as identification cookies, I.P. protocols, or other identifying personal data, is governed by the special terms of use of the Company applications.

Data involving you that are publicly accessible either through electronic means or other media.
GAIN CONSULTING S.A. does not collect or process special categories of personal data, such as data relating to racial or ethnic origin, political views, religious or philosophical beliefs, trade union affiliation, genetics or biometrics, or the health or sexual orientation of natural people.

The personal data processed by GAIN CONSULTING S.A. are stored in written form and/or electronic or magnetic media.

The purpose of processing and manner of use of personal data

The data collected is necessary for:
The provision of products and services, the execution and general fulfillment of our obligations to you.
We collect your data to provide you with our products and services. Identification and contact information are required to draw up the contract between us and to provide you with our products and services. We process your information to manage your customer record, confirm the status of your order, and/or facilitate your participation in a corporate event or training.
Our communication with you and the management of our relationship with you.
We may need to contact you by email or telephone for administrative purposes, such as handling your requests and complaints and generally serving you. We may also use your contact information to participate in a customer preference or satisfaction survey or to inform you of the progress of your participation in a corporate event.
Improving our services and protecting our business interests.
We may use your data to improve the services we provide by responding more effectively to your expectations.
Keeping you updated on our news.
If you have consented, we will send you informational material about our products and services and corporate events by email, telephone, or post.
Compliance with legal obligations.
We process your data in the context of our compliance with legal obligations and in particular with the provisions of labor, insurance, and tax legislation, with court decisions, with obligations towards government authorities, and in the context of investigating complaints, preventing and detecting fraud, checking accuracy billing and situations involving potential threats to the safety of any person or violations of our Company policies.
The safeguarding of our legal interests and the protection of persons and property.
We process personal data in the context of using closed-circuit security cameras (CCTV) to protect the safety of individuals, materials, and facilities.

Legal reasons for personal data processing

Personal data supplied to GAIN CONSULTING S.A. are subject to processing on condition of occurrence of legal reasons.

Legal reasons for processing your data may include:
(a) Need for processing your data within the framework of fulfillment of any contractual or pre-agreement stage obligations, subject to your request for the procurement of Company goods and services to you, including the management of your customer list, confirmation of the status of customer orders, and the execution of your orders.
(b) Safeguarding and protecting your legal interests that may include personal and installation security, Company network security and informatics systems, protection from malicious software, legal claim support, exercise and substantiation, overall organization and development of Company business activities, and the promotion of Company goods and services.
(c) Conformance to any legal obligation may consist of obligations resulting from labor, taxation, or insurance legislation provisions.
(d) Securing consent is subject to preconditions specified in the legal framework, such as receiving updates on goods, services, and business events.

Who is notified of your personal data

GAIN CONSULTING S.A. may indicatively notify your data to the following categories of recipients:
Affiliated subsidiaries of our Company Group
The Company may communicate data to the companies in the GAIN CONSULTING Group for management and service to customers, suppliers, and associates or for reasons of conformity with legal obligations.
The Company shall legally guarantee that any third party executing data processing on its behalf shall fulfill the preconditions and provide sufficient assurance in applying the appropriate technical and organizational measures so that processing your data abides by the protections of such third-party interests.
Company employees
These Company employees are in charge of the evaluation and completion of your requests, the management and execution of your present agreement, and the fulfillment of the obligations stemming from such agreement, including any relevant obligations specified by law. Your data are treated with the utmost confidentiality and privacy as any employees processing your data possess sufficient and competent knowledge in data protection and are bound by a confidentiality clause and/or the due regulatory obligation of conformance to the confidentiality clause.
State authorities, law enforcement agencies in the capacity of exercising their duties
The Company may have to share your data with the competent authorities, law enforcement agencies, or any other third parties to the extent specified by the law, within the context of prevention or commitment of criminal acts, illegal activities, or any situation that may involve possible threats against the security of any person, or violations of our policies.
During project assignments to legal consultants, accountants, auditors, insurers, etc.
The Company, when managing court cases or substantiating, exercising, and supporting legal claims against third parties, may communicate your data to external associates-lawyers in case their cooperation is deemed necessary for the handling of any case and the defense of the Company’s rights. Furthermore, GAIN CONSULTING S.A. shall cooperate with accountants, auditors, insurers, or any third party assigned to process personal data on behalf of the Company.
In such cases, GAIN CONSULTING S.A. shall be responsible for the processing of your data, determine the separate elements of the processing, and sign a particular contract with third parties assigned by the Company with processing activities to ensure that the processing is to be conducted by the legal framework in effect, so that any natural persons may freely and unrestrictedly exercise the rights specified by the legal framework.

Communication of your personal data to third countries

Your data may be communicated to and stored in locations beyond the European Union (EU) or the European Economic Zone (EEZ), including any countries operating with differing levels of personal data protection. Reasons for such communication of personal data may include guarantees on a case-by-case basis, depending on the recipient, such as European Commission resolutions on competence or formal contractual clauses approved by the European Commission in effect at any time. In case of the absence of such clauses, the communication, as mentioned above, is based on the concrete exceptions specified in Regulation requirements, such as the need for communication to execute the contract between the Company and the person involved in the data or the consent of such person.
Additionally, the communication may, on a case-by-case basis, be conducted to substantiate, exercise, or support legal claims or as an exception in cases in which such communication may be required according to a court judgment, administrative authority requirements, international agreement, or the Company’s legal interests. In any case, guarantees shall be in place to secure proper protection and legitimacy of the communication.
If your personal data is to be transferred to any of the above referred third countries, you will be informed in advance, by email. This notification will include details about the recipient of the data, the purpose of the transfer, and the Company’s rights under applicable PII laws.

Data storage time

The time for data storage shall be specified based on the following special criteria depending on the case:
In case the processing is required as an obligation stemming from the provisions of the legal framework in effect, your personal data shall be stored for the time specified by the relevant legal provisions.
If the processing is conducted pursuant to a contract, your personal data shall be stored for the period required for the execution of the contract and for the substantiation, exercise, and/or support of legal claims supported by the contract.
Your personal data shall be stored until you revoke your consent to promote goods and services. You may revoke your consent at any time at your own discretion. The revocation of your consent shall in no way affect the legitimacy of the processing provided by consent at a time prior to its revocation.
In order to revoke your consent, you are advised to contact GAIN CONSULTING S.A. by sending a message to the email address [email protected] or by calling the phone number 210 9947100. You may also use the unsubscribe options by following the respective link listed in our electronic communications information.

Your rights in relation to your personal data

Any natural person whose data is processed by GAIN CONSULTING A.E. enjoys the following rights:
Right of access
You have the right to know and verify the lawfulness of the processing. Therefore, you have the right to access the data and receive additional information about its processing.
Right of rectification
You can study, correct, update, or modify your data by contacting the Contact Officer for Personal Data Protection Matters at the contact details above.
Right to erasure
You have the right to request the erasure of your personal data when we process it based on your consent or to protect our legitimate interests. In all other cases, such as when there is a contract, an obligation to process personal data imposed by law or the public interest, the right in question is subject to specific limitations or does not exist, as the case may be.
Right to restriction of processing
You have the right to request the restriction of the processing of your data in the following cases: (a) when you dispute the accuracy of the personal data collected by the Company and until verification is made, (b) when you object to the deletion of personal data and request instead of deletion restriction of their use, (c) when the personal data are not needed for processing, but are nevertheless necessary for the establishment, exercise, support of legal claims, and (d) when you object to the processing and until it is verified that there are legitimate reasons that they concern us and take precedence over the reasons for which you object to the processing.
Right to object to processing.
You have the right to object at any time to processing your data in cases where, as described above, this is necessary for legitimate interests pursued by us as controllers, as well as to processing for direct marketing and consumer profiling.
Right to portability
You have the right to receive your data free of charge in a form that will allow you to access it, use it, and process it with commonly used processing methods. You also have the right to ask us, if technically possible, to transfer the data directly to another data controller. This right of yours exists for the data you provided us, the processing of which is automated based on your consent or in executing a relevant contract.
Right to withdraw consent
If the processing is based on your consent, you have the right to withdraw it freely, without prejudice to the lawfulness of the processing based on your consent until you withdraw it.
Capability of complaint to the HDPA
You can submit a complaint to the Hellenic Data Protection Authority electronically through its web portal by filling in the corresponding electronic form depending on the type of complaint, as detailed on its website: https://www.dpa.gr/el/polites/katagelia_stin_arxi.
To exercise your rights above, email [email protected] or phone 210 9947100.

Personal Data Security

GAIN CONSULTING S.A. applies the appropriate technical and organizational measures to secure personal data processing and prevent any random use, destruction, or unauthorized and/or illegal access, use, modification, or disclosure of such data. However, the operations of online communications and the freedom of access to every one shall in no case justify the institution of guarantees preventing unauthorized third parties from acquiring capabilities to violate the applied technical and organizational measures by acquiring access and subsequently embarking on unauthorized and/or illicit use of personal data.

Links to other websites

The Company websites may be linked to other websites beyond the Company’s control since third-party websites are beyond the Company’s jurisdiction as they can link to the Company website. Despite our attempts to secure, in all cases, the linkage of our website exclusively to websites sharing our privacy and security standards, the Company shall not be held accountable for privacy practices or the content of other websites.

Amendments to the Data Privacy Policy

Any information related to the Data Privacy Policy of GAIN CONSULTING S.A., posted on the Company website, reflects the current state of data processing. In case of modifications in data processing, such information shall be accordingly updated so that the Company website shall post, in all cases, the latest version of the information concerning data protection in order to keep you updated on the extent of data protection. It would be best to remain posted on how the Company processes and protects your personal information. All future changes concerning this Privacy Policy shall be posted on time before the institution of such modifications.
The foregoing update applies Regulation (EU) 2016/679 of the European Parliament and the Committee and the provisions of the domestic legislation concerning personal data protection adopted and applied within the legal framework presently in effect.

Registration Number: 182318601000