Privacy Policy

Introduction

This Data Protection and Privacy Policy (“Policy” “Privacy Policy”) is applied by our Company "Ogram Single Member P.C." (“Ogram” "Company" “We”) which is based in Thessaloniki, at 26th Octovriou str. no 26, P.C. 54627, as to the processing of your personal data that is carried out when you use our application (“Ogram application”) in order to provide you with our services.

Except as otherwise explicitly stated in the present Policy, our Company acts as a Controller with reference to the processing of your personal Data.

The protection of your personal data is of major significance to us and therefore our Company acts in accordance with the applicable relevant legislation and in particular according to the requirements of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data ("General Data Protection Regulation or GDPR").

Our Company respects and protects your privacy and your personal data and makes sure that the processing of your personal data is made with clarity, is limited to the absolutely necessary extent and is carried out exclusively for the purposes and on the legal basis which applies to each category of processing.

The present policy aims to give you clear and comprehensive information about who we are, why and for which purposes we collect your personal data, how we process them including when and to whom we disclose or transfer them, and which are your rights with reference to your data. We advise you to read carefully the present Privacy Policy which we make sure to update from time to time.

1. Which data are considered as personal?

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’). Such information is usually a name, a telephone number, location data, an on-line identifier, a postal and electronic address etc. Subjects of the said data may only be individuals.

2. What does Personal Data Processing mean?

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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. Which of your Personal Data do we collect, for which purposes and on what legal basis?

When you use our application, we will need to collect and process certain information which are each time necessary for the purposes explained to you below in this section. Therefore, for your convenience and for clarity purposes, we have categorized the specific cases of processing accompanied by the corresponding purposes and legal basis of processing as follows:

3.1 Subscription to Ogram’s waiting list

Once you install the Ogram application to your mobile device you may be asked to subscribe to our waiting list. At this point we collect the following information:

- first and last name
- email address
- telephone (mobile) number
- date of birth
- gender
- nationality
- the languages that you speak
- working and educational experience (if any)
- the location where you want to work

During this process we will ask you to set a password for entering your Ogram account and verify your email through a link sent to your email address.

3.1.2 Purpose of data processing and legal basis

We need the personal information that you provide us with during your subscription to the waiting list for the following purposes and based on the corresponding legal basis:

3.1.3 Retention Period

We keep your data collected under this section 3.1 for a period of one year. After such period and provided that you have not completed the full on-boarding process to our application, your data are erased from our system and your account will be deleted.

3.2 Candidate/ temporary employee information

Following your subscription to our waiting list, you will receive a notification via email, phone call or push notification when a job opening matching your provided information, is available. After this notification we will ask you to provide us with additional information and if needed update the information which you have already included to your account during your subscription to the waiting list. The reason we require from you additional personal details is in order for you to complete your profile in our application and if you are eligible, to be able to express your interest for any available job opening and proceed with the conclusion of the respective temporary employment agreement with us. We will also need these data in order to complete the hiring process required by the applicable labor law, including registration of your employment to the ‘Ergani’ system.

The data included in this section may also be freely provided by any user of our application at any point regardless of the receipt of any notice for an available job opening. In this case we will process these data for the purposes included in 3.2.1 and we will keep them for the period described in 3.2.2.

During the process of your profile completion we may have to process some of the following information:

-Information relating to your identity and contact information: name, surname, father’s and mother’s name and surname, name of spouse (if any), gender, address, email and telephone number, nationality/citizenship, ID or passport number, date of issuance and issuance authority, date of birth, place of birth, residence address, working location, digital signature, residence and/ or working permit, family status.

-Financial information: banking account (IBAN) and banking institution, holder name of the banking account.

-Salary or provisions information: information regarding your current or required salary, benefits or other provisions and bonus payments.

-Tax or insurance information: VAT number, tax office, AMKA number, AMA number, I.K.A. registry number, Registry number in any other insurance fund, hiring date and health certificate.

-Information relating to your insurance status and background: year of first insurance and if you are entitled to an unemployment benefit or card.

-Information relating to your family status: family status (married/ unmarried/ divorced/ widower/ unmarried entitled to a benefit/ if you have concluded a civil partnership), number, name, gender, date of birth and educational level of children (if any), child’s level of disability (if any).

-The profile photo that you upload to our application.

-Copies of official documents: identity card, passport, proof of AMKA/VAT/AMA, residence and/ or working permit, health certificate.

-Information relating to your skills: the languages that you speak, capacity to use a PC or if you are a holder of a relevant degree, information of your diplomas or qualifications including the diploma degree and title, driving license, other required by law professional licenses.

-Information relating to your educational and professional experience: previous working experience including working position and location, any information included in your resume, type of employment (traineeship, full or part time), educational background including information relating to your graduation from the Primary School, Secondary School and relating to any university degree or professional school degree, learning programs or other similar academic certificates and the state of their issuance.

-Information relating to your assessment made by your indirect employer including any complaints made by third parties such as clients regarding your performance, information relating to your previous working experience through the application such as the hours of your previous employment (number of shifts), the type of your previous working experience, and your previous indirect employer.

-Information relating to your health: in case of injuries or other work accidents caused during your work shift, or in case of illness and sick leave.

- Any other information you freely choose to disclose to us.

3.2.1 Purpose of data processing and legal basis

3.2.2 Retention Period

Ogram maintains your data only for the term that is required for us to fulfill the purpose for which they were given, i.e. for the term for which you are an active user of the Ogram application and you make use of our services. In case of inactivity we will erase your data two years after your last application use. We inform you, however, that based on our regulatory obligations, and in particular based on our tax obligations, maintenance of your data will in any case (if required) last for as long as our statutory obligations require.

3.3 Τracking technologies data- User behavior analysis

When you choοse to download and use the Ogram application we collect through the use of tracking technologies information about your interaction with our application such as:

-your preferences when using the application

-the IP address of your mobile device

-the IP address of your internet provider

-your geographical location

-the selected country

-your login credentials

-the system language

-the frequency of your visits as well as the time and date of your visits

-the app content which you choose to see

-the number of ‘clicks’ and scroll

-the version of your mobile operating system and mobile device type

Some of the above information such as the country and language selection or the retention of your login information is technically necessary for the operation of our application as it enables it’s functionality (‘essential trackers’). Without the processing of these data, the use of the application would be problematic and eventually non-functional and therefore you cannot opt out from their implementation.

Other information is used by us or third parties for statistical analysis purposes or for profiling user categorization purposes aiming to help us provide you with a much smoother app experience without errors for the user (‘non-essential trackers or performance trackers’). Such data include mainly information about your preferences when you use our application, information referring to your IP, or mobile device as well as feedback concerning any app errors. The processing of these data might include processing by third parties based outside the EU, however, we make sure that these third parties involved apply all the necessary measures for your data protection according to the GDPR requirements. Provided that processing of the above data is not necessary for the technical operation of our application, we process such data only under the condition that you have consented to the use of the relevant tracking technologies as in detail described in this section. Hence, your consent covers the following third- party tracking technologies and their providers:

Segment tool

We use Segment tool powered by Twilio Inc., a Delaware corporation, with a place of business at 101 Spear Street, 1st Floor, San Francisco, California, 94105, USA “Twilio”. The Segment tool captures and collects user’s interactions within the app such as their preferences and IP address. Then it transforms the collected data to formats able to be processed by other servicers for statistical purposes. The servicers which receive the collected data are: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for the provision of Google Analytics and Amplitude, Amplitude Inc., located at 201 Third Street, Suite 200, San Francisco, CA 94103. These data are used for the production of anonymized statistical reviews in order for us to learn more about our users’ app experience and enhance our application’s functionality.

Sentry tool

We also cooperate with the company Functional Software, Inc. ‘Sentry’ based at 45 Fremont Street 8th Floor San Francisco, CA 94105, in order to take advantage of the Sentry tool which provides real-time error tracking for our mobile app giving our developers the insight needed to reproduce and fix crashes. Sentry is in fact a bug-tracking tool which collects app errors arising during app sessions, as well as information relating to the user’s behavior prior to such error. The findings of such processing enables us to detect and fix any technical deficiencies of our application.

3.3.1 Purpose of data processing and legal basis

The processing of your personal data relating to the use of tracking technologies: (a) with reference to essential tracking technologies (‘essential trackers’) is based on our legitimate interest to maintain our application functional, and (b) with reference to non-essential tracking technologies (non-essential trackers), is based on your consent which is provided when you create your account and which can be easily revoked at any time simply by visiting our settings section on our application.

3.4 Location/ Google Maps Data

When you use our application you have the option to activate your location through the use of the relevant map application which is installed to your device. Activation of your location is strongly recommended as it will help you to have more easily access to job opportunities near your place of residence. Data Controllers of your location data are the providers of the relevant application meaning for Google Maps: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and for Apple Maps: Apple Inc., One Apple Park Way, Cupertino, California. You can find more information as to the privacy policy of each Data Controller, in the relevant section included in their official website.

We may store your location in order to be able to match your profile to the available job opportunities near your location. Also, we may store your location in case there is no alternative to prove to any of our clients that an employee was actually present at work on time and equally was dismissed with no delay. In this case, and provided that the following requirements are met, your location may be stored at your check in and check out of work. The requirements for such processing which will apply at all times are : (a) use of your location will be made strictly for the above purpose, within your working timeline and provided that there is no alternative solution for the proof of fulfilment of your employment obligations, (b) such processing will at no circumstances be considered for your working efficiency/evaluation, (c) your location data will not be stored longer than your employment from the certain employer, (d) you have been thoroughly informed in advance and in written as to such processing, (e) we take all the safety and organizational measures for the protection of your data including that access to such data is limited to the competent employees of Ogram.

The legal basis for such processing is (a) our pre-contractual obligation to find jobs matching your profile including matching your place of business and (b) The processing of your personal data is necessary for the purposes of the legitimate interests pursued by our Company, which don’t conflict to your interests, but on the contrary such processing is able to confirm any doubtful but actually provided service by you

3.5 Newsletter/ push notifications

If you have registered to receive newsletters, we will collect and store your email and if provided your name, in order to send you informative or marketing material relating to our services. Equally, we will process the IP address of your mobile device and of your internet provider in order to send you push notifications with informative material provided you have consented to receive such notifications. The legal basis for such processing is your consent. You can easily revoke your consent anytime either by clicking on the relevant link contained in any newsletter, or by turning off the receipt of the relevant push notifications in your Phone settings.

3.6 Personal data collected through questionnaires

Your opinion and remarks are significant to us. Therefore, during our cooperation, we might ask you to provide us your feedback as to your working experience with us through the use of questionnaires. Although you may fill in our questionnaire anonymously, if you choose to provide us with your personal information (name, address, contact details and working position) such processing will be based on our legitimate interest to improve our services and detect any problems concerning your working experience with the aim to solve them.

3.7 Links to third-party websites

Our application may host third- party links redirecting you to other websites. Ogram is not responsible for the content of the websites where these links lead to, as these websites fall under the sole responsibility and management of the concerned third party. Therefore, we strongly recommend that you read carefully the privacy policies applicable to these websites as these websites don’t necessarily apply the same level of protection for your personal data. In case you realize that the content of any website where a third-party link leads to is misleading or fraudulent, we urge you to contact us in order to remove such link from our application.

4. Do we use automated decision making / including profiling when processing your data?

Our Company uses automated decision-making processes including profiling, in order to determine if your profile is likely to match to any job opening and to notify you accordingly. In particular, when you initially submit your personal information in our application, our algorithm assesses the provided personal data in order to determine whether your profile would match to the requirements of any available job opening. If yes, then you will be notified by Ogram and you will be able to either express your interest for the suggested job or not. Following your positive response, our client company will be able either to choose among top candidates or require that the Ogram algorithm will choose the most suitable candidate instead. We also use automated decision-making processes during ordinary use of the application. In particular, when you have already expressed your interest in an available job opening, following your preference, your profile is evaluated in order to form the list with the most suitable candidates for this specific job, or in order to be evaluated as the most suitable candidate employee profile for the said available job (depending on the client’s preference to pick among many candidate profiles or not)

The implemented automated decision making process is necessary for us in order to be able to provide our services to you (as it would not be feasible to otherwise assess effectively the volume of the received CVs) and then proceed with recommendations which might lead to the conclusion of your employment agreement. In other words, this processing is necessary for the conclusion of your intended temporary employment agreement with our company. Our Company takes all necessary technical and organizational measures to protect your data and makes sure that your rights are respected. In any case, we inform you that you are entitled to human intervention as to the processing of your data, so please don’t hesitate to contact us for any relevant information.

5. Who has access to your personal data?

Our Company ensures that your personal data are kept and processed with safety. More specifically, we make sure that access to your data will be allowed only to our competent employees, who in accordance with their contractual obligations as to the confidentiality and protection of your data are responsible to protect your personal data and keep them confidential, who also will not allow their unlawful processing and who will process your data only up to the necessary extent, within the context of our instructions and in accordance with the purposes of this policy.

In addition, our Company will not transmit or disclose your data to third parties, unless:

a) it is necessary for us in order to be able to provide our services for the purposes included in this privacy policy

b) it is mandatory based on our legal obligations (eg in accordance with our tax or other legal obligations),

c) it concerns processing carried out by the companies that cooperate with us/ or by our clients which act as processors of your data on our behalf.

However, we ensure a) that our partners/clients who will be acting as processors are contractually bound by confidentiality and data protection agreements, b) that they apply the appropriate technical and organizational measures and that they demonstrate at least the same level of care as to the protection of your data, c) that they will not transmit your data to third parties without our prior consent and d) that in any case processing of your data will be made up to the absolutely necessary extent.

As a result and according to the above rules, access to your personal data may be allowed by:

.Other Companies of our Group for the purposes included in this policy

1. Counterparty colleagues/clients of our company for the purposes of fulfilling our contractual obligations or in order to fulfill other imperative purposes which make disclosing of your data necessary, such as in particular our pre-contractual obligation towards you to provide you with our services, i.e. to proceed with your hiring on behalf of our customers. In particular, our clients who wish to find staff through our company in accordance with what is analyzed in the terms of use of our application, will be able to have access to the following information, so that they can express their interest in your possible hiring by our company on their behalf: Name, nationality, age, languages ​​that you speak, professional experience, academic education, for how many hours you have previously been employed through our application (shifts), and any assessments made by other clients.
2. Public Authorities (tax authorities, health authorities, police etc) based on our legal obligations
3. The accounting company that undertakes on our behalf: all your hiring formalities, including submission of your hiring to “Ergani”, bookkeeping and compliance with our accounting obligations.
4. Other Companies which provide us relevant services such as IT or technical services, legal or advisory services, banking services and transactions support etc.

6. Are your data transmitted to third countries?

If needed, we will transmit your personal data to a third county, apart from the EU, only provided that one of the following two conditions is met:

• There is an adequacy decision issued by the Commission concerning the country where transmission is to be made or
• Certain safeguards have been adopted regarding the data processing as provided in article 46 of the GDPR.

If none of the above conditions is met, we will refrain from transmitting your personal data to any third country except for certain circumstances which are provided in article 49 of the Regulation such as when there is your explicit consent to the proposed transfer, after having been informed of the possible risks of such transfers, or when the transfer is necessary for the performance of a contract between the data subject and the controller, or when the transfer is necessary for important reasons of public interest etc.

7. What rights do you have with reference to your personal data?

• Right to access your personal data:

You have the right to be informed by us accurately and clearly if we collect and process your personal data. You may be informed inter alia and in particular, of the purpose of the data processing, of the data categories that we collect, of your data sources and of their recipients, if any, of their maintenance period or, when this is not possible, of the maintenance criteria, of your ability to exercise the right to rectification, to erasure, to restriction and right to object to their processing, of the existence of an automated decision-making process, including profiling and of the existence of any relevant protection guarantees.

• Right to data rectification

If you realize that your provided data are inaccurate and need to be corrected, you may ask us to rectify such data by contacting us in any of the available contact details.

• Right to data erasure or ‘right to be forgotten’

You have the right to ask us to erase your data. We will proceed with their immediate erasure provided that their maintenance is not necessary for the fulfillment of our legal obligations. In particular, if you wish to revoke your consent and provided that your consent is the only legal basis for the collection and processing of your data, we will delete your data as soon as we receive your request.

• Right to data portability

You have the right to ask us to deliver the provided data in an easily readable form or to ask us to transmit them to another controller.

• Right to restriction of processing

You have the right to request the restriction on the processing of your personal data in case a) their accuracy is questioned and for the required term to verify the accuracy of your data, b) the processing is illegal, c) we no longer need your data, d) you have objections as to their automated processing.

• Right to object

You have the right to object to the processing of your data at any time when processing is made for the performance of a task carried out by our Company in the public interest or when processing is made for the purposes of the legitimate interests pursued by our Company.

If your personal data are used for direct marketing purposes concerning our services, you have the right to object at any time to such processing, including profiling, if related to such direct marketing.

You have the right at any time to revoke your consent to process your data when processing of your data is based solely on your consent. In the event of your objection, termination of your data processing will be made immediately unless there are other compelling and lawful reasons that prevail over your right.

8. How can you exercise your rights?

You can exercise any of your rights by contacting the appointed Data Protection Officer of our Company to the following contact details:

Ogram Single Member PC
Thessaloniki, Pylaia, at 2 Gianni Kranidioti str., PC 55535
Εmail address: greece@ogram.co.

Our Company will make sure to respond to you as soon as possible regarding the progress of your request and in any case not later than (1) one month from the date of your request receipt.

In any case that you consider that our Company has violated your rights in relation to the processing of your personal data, you have the right to file a complaint to the Personal Data Protection Authority (www.dpa.gr).

9. Are your data safe?

Our Company, recognizing the importance of your data security, has ensured to take all the appropriate technical and organizational measures in order to keep your data secured. Although internet can never be a completely safe place, we have taken care to implement the security measures required to prevent, up to the possible extent, any unlawful or illegal processing of your data, any accidental or unlawful loss, alteration, prohibited transmission or access to your data by third parties.

10. Applicable law and dispute resolution

In order to resolve any dispute that may arise in connection with this Privacy Policy, we will make every effort to resolve it out of court in accordance with good faith and business ethics. If such an attempt does not succeed, Greek law will be applicable for the settlement of such dispute and the competent courts of Thessaloniki will have exclusive jurisdiction.

This policy is reviewed and updated when deemed necessary. We encourage you to visit frequently the relevant section of our application where our updated privacy policy is posted. This Privacy Policy was last updated on March 05, 2023.