Personal Data Processing Notice
With this Personal Data Processing Notice (the “Policy”), CAPA informs the users/visitors of its website or, more generally, the natural persons who are data subjects (the “users/visitors”, “you”, or any other reference in the second person plural) that, in the context of its operations, CAPA may collect and process personal data concerning them, provided that such users/visitors voluntarily provide such data to the Association.
- Contact Details
The association under the name “Union of Corporate Affairs Professionals”, with the distinctive title “CAPA”, is based in Athens, at 119 Kerkyras Street, Postal Code 11362, Athens (hereinafter “CAPA”).
Email: capa@capaorg.gr
Website: www.capaorg.gr
- Legal Framework of Processing
This processing shall be carried out in accordance with this Policy and the applicable Greek and European legal framework on the protection of personal data, including the General Data Protection Regulation (EU) 2016/679 (GDPR) and Law 4624/2019 implementing the GDPR in Greece.
Users/visitors are invited to read this Policy carefully before continuing to use/browse CAPA’s website. By continuing to use/browse the Site, users/visitors are deemed to have read, understood, and fully and unreservedly accepted its content.
Please note that the headings used in this Policy are for reference only and are intended solely to assist users/visitors.
- Purpose and Legal Basis of Processing
Personal data will be processed exclusively for the purposes listed below and in accordance with Article 6(1) of the GDPR, namely:
- for communication purposes;
- in the context of submitting proposals following CAPA’s invitation for the provision of services/projects and evaluating such proposals;
- in the context of submitting résumés for specific positions and evaluating them;
- as otherwise indicated on CAPA’s website;
- for the satisfaction of CAPA’s or third parties’ legitimate interests (e.g., the protection of legal rights and interests, fraud prevention, etc.);
- for CAPA’s compliance with its legal obligations;
- or for any other lawful purpose listed in Article 6(1) of the GDPR (e.g., when processing is necessary for the performance of a contract or for taking steps at your request prior to entering into such a contract).
- Categories of Data
CAPA will collect and process only personal data that are adequate, relevant, and limited to what is necessary for the respective purpose of processing, which may include, depending on the case:
- identification data (e.g., name, date and place of birth, ID card or passport details);
- contact details (e.g., address, telephone number, email address);
- education/professional experience information;
- any other information you may voluntarily provide;
- and, in special cases, other relevant information as required.
CAPA will not process your data for any purpose other than that for which they were collected.
Users/visitors are requested to provide CAPA only with the information/data specifically requested (e.g., in a call for interest, membership registration, etc.). Failure to provide such data may render it impossible for CAPA to carry out or complete the related action.
CAPA generally does not request users/visitors to provide personal data concerning other individuals. Should such data be required, users/visitors must ensure beforehand that:
(a) they have informed the individual concerned about the content of this Policy, and
(b) they have obtained that individual’s explicit consent to share their data with CAPA, where such consent is required by applicable law.
CAPA’s website is intended for an adult audience.
- Data Retention Period
We take all necessary measures to ensure that the personal data we collect and process under this Policy are retained only for as long as is strictly necessary for the purposes for which they were collected, as well as to comply with our legal obligations, internal procedures, or for as long as required to safeguard our legal rights and interests, taking into account applicable limitation periods.
- Disclosure / Transfer of Data to Third Parties
Access to personal data collected and processed under this Policy is granted only to authorized members of CAPA’s personnel and governing bodies, strictly to the extent required for the purposes described above.
Furthermore, CAPA may, where necessary, transfer such data to third parties, to the extent required for the fulfilment of the respective purpose of processing, as well as to any authorities, agencies, bodies, or organizations, as required by law.
Where CAPA engages third parties to process personal data on its behalf (data processors), such parties must comply with both national and EU data protection legislation and must enter into a data processing agreement with CAPA that meets the requirements of the applicable legal framework.
- Potential Transfer of Data to Third Countries
Where required for the purposes of processing described above, CAPA may transfer your personal data to recipients located in third countries outside the EU. In such cases, CAPA will ensure that all legal conditions for lawful international data transfers are met.
- Your Rights
Under Articles 13–22 of the GDPR and Law 4624/2019, you have the following rights regarding your personal data that we collect and process under this Policy:
(a) Right of access – to obtain confirmation as to whether or not your personal data are being processed and, if so, access to the data and certain information regarding their processing.
(b) Right to rectification – to request the correction of inaccurate data or completion of incomplete data.
(c) Right to erasure (“right to be forgotten”) – to request deletion of your data under certain conditions. Please note that in some cases, where processing is necessary for compliance with a legal obligation or for the establishment, exercise, or defence of legal claims, CAPA may not be able to fulfil a deletion request.
(d) Right to restriction of processing – to request that processing be restricted under specific conditions. CAPA may continue to process restricted data for reasons permitted by law, including legal claims or matters of public interest.
(e) Right to object – to object, at any time and for reasons related to your particular situation, to the processing of your data, in which case CAPA will cease such processing unless there are compelling legitimate grounds or for the establishment, exercise, or defence of legal claims.
(f) Right to data portability – under certain conditions, to receive your data in a structured, commonly used, and machine-readable format or to have it transmitted to another controller.
(g) Right to withdraw consent – where processing is based on your consent, you may withdraw it at any time. Such withdrawal shall not affect the lawfulness of processing carried out before the withdrawal.
- Contacting and Complaints to the Authority
In any case, you may contact the Hellenic Data Protection Authority (HDPA) (www.dpa.gr), where you also have the right to lodge a complaint, depending on the circumstances.
- Links to Other Websites
CAPA’s website may contain links to other websites operated by third parties. CAPA bears no responsibility for the terms of data protection and management applied by such websites.
- Amendments
CAPA regularly reviews the content of its website and this Policy. CAPA reserves the right to modify the website’s content or this Policy at any time it deems necessary, without prior notice, by posting the updated content on this website. For this reason, you are advised to check this Policy periodically for possible changes.
- Governing Law and Jurisdiction
This Policy, as well as the use of this website in general, shall be governed by Greek law. Any disputes arising from or in connection with it shall fall under the jurisdiction of the Courts of Athens.
- Contacting CAPA
For the exercise of any of your rights or for any matter arising from or related to this Policy, you may contact CAPA at capa@capaorg.gr.
Please note the following:
(a) If we have reasonable doubts about your identity, we may request additional information to confirm it.
(b) We will make every effort to respond to your requests without undue delay and in any case within one (1) month from receipt. If necessary, this period may be extended by two (2) additional months, taking into account the complexity and number of requests. You will be informed of any extension and the reasons for the delay within one (1) month of your request.
(c) Responses to your requests are provided free of charge. However, if your requests are manifestly unfounded or excessive, especially due to their repetitive nature, CAPA may charge a reasonable fee or refuse to act on your request.