1. INTRODUCTION

Whenever you contact SMARTCV  or use any of our products and services, you disclose personal information (PERSONAL data).

The purpose of this Privacy Policy (hereinafter referred to as "Policy") �is to inform you (as a natural person) about what personal data w e collect, why we collect it, what is the legal framework that allows us to process it, how we store it, as well as to inform you how you can exercise your rights.

It also shows our compliance with the legislation and in particular the EU 679/2016 regulation on the protection of Personal data, and our respect for the protection of the privacy and security of your Personal data.

This privacy policy applies to the personal data that you provide to us when you visit our website https://smartcv.co/ and SMARTCV is the Controller ,as well as in the course of our activities asProcessor.

This privacy policy was posted on our website on 14/12/2020 and replaces any previous version. It is addressed to any natural person who has or intends to have any kind of relationship with us.

The privacy policy may be modified from time to time, we recommend you read it before using the website.

For any questions do not hesitate to contact us at info@smartcv.co .

2. WHO WE ARE?

smartcv.co  is the property of the company SMARTCV  Private Company  (Company), which is based in Greece, in the municipality of Athens, Attica and on  Zisiou  5 Street.

SMARTCV  is an applicant tracking system dedicated to companies.

3. WHAT KIND OF PERSONAL DATA DO A WE PROCESS?

Personal Data is any information through which you can ascertain, directly or indirectly, your identity as a specific natural person.

SMARTCV, is a Controller regarding the processing of the personal data we collect through our website.

We, obligatorily, process (i.e.: we collect, manage, store, delete) Personal data in the context of our operational functions and, often, in the context of our compliance with the laws and regulations.

You (as a natural person) are not obligated to provide us with the Personal data that we may ask you to, but, in the case of your refusal, we may not be able to provide you with products or services or respond to your requests consistently, quickly and Quality.

When you contact us via our website contact form, we process the following data:

�          Full name

�          Business information (name, range of employees)

�          Any information you include in your message

When you visit our website, we collect the following data by cookies:

�          IP address

�          Geographical data (Country)

�          System data (Operating system, Device, Screen resolution)

�          Navigation data (Time of stay on the site, Navigation pages)

When you register to our servicesand purchase our services, we collect the following data:

�          Full name

�          Business information (name, country, post address, phone)

�          Contact details (e-mail)

�          Invoice data (VAT number)

SMARTCV, is a Processor regarding the processing of personal data of Clients� candidate employees, processed at SMARTCV�s application.

When candidate employees apply for a client�s vacancy in SMARTCV application, the following data are being processed:

�          Full name

�          Contact details (e.g. e-mail, telephone, address)

�          Curriculum Vitae data (e.g. studies, skill certifications, working experience, etc.)

�          Any further information disclosed by Client�s candidate employees voluntarily

When candidate employees apply for a client�s video interviews in SMARTCV application, the following data are being processed:

�          Full name

�          Contact details (e.g. e-mail, telephone)

�          Video data

4. HOW WE COLLECT YOUR DATA?

The personal data collected by:

�          Filling the website�s contact form

�          Singing in the application

�          Purchase features in the application (e.g. video interviews)

�          Managing cookies panel

�          Communication via e-mail

5. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?

We use (process) the information you provide to us and we collect, as described above, for a specific purpose only. In addition, we use your data when there is a legal basis for processing them, and in the context of the following purposes:

�          Contact you based on your request

�          CV management for Clients

�          Video interviews management for Clients

�          Study the use of the website in order to provide more improved services

�          To develop and improve the products, services, communication methods and functionality of our websites.

�          Contact with you to inform you about new services or products that may be of interest to you.

�          Process your payment or prevent or detect potential scams.

�          Registration, management, and maintenance of user accounts on the website.

�          To respond to complaints or questions you have asked us.

�          To develop and improve the products, services, communication methods and functionality of our websites.

We do not use your personal data for advertising purposes in any way.

Our legal basis for collecting and using the personal data described above depends on the personal data and the specific context in which we collect it. We process your personal data, as controller, based on the legal bases of legitimate interest, consent and performance of contracts.

When SMARTCV act as a processor, we process candidate�s personal data exactly as instructed by our Clients and we shall not use the data for any other purpose and we rely on our Clients to ensure that personal data are collected on the basis of one of the GDPR lawful grounds for processing.

6. HOW LONG HAVE WE KEPT YOUR PERSONAL DATA ?

We, as Controllers retain your personal data only for as long as necessary to provide our services, depending on the purpose of their processing and this privacy policy.

We, as Processors retain Clients� candidate data, based on the instructions of our Clients, as well as our legal obligations.

7. WHO WE SHARE YOUR PERSONAL DATA WITH?

Access to your Personal data has exclusively the necessary personnel of SMARTCV, who is committed to confidentiality and has received the required information for the safe process of your personal data.

Moreover, access to your personal data have the companies that cooperate with us (processors/Subprocessors) in case the process has been designated to them by Us. The process of the personal data by the processors is made under our explicit instructions and after it is guaranteed that all the necessary technical and organizational measures have been received

Third parties that might have access to your data are official government and supervising bodies (e.g. prosecution authorities and official supervising authorities), in case we are asked to comply with legal obligations, when the transmission is necessary for purposes of public interest, as well as for supporting and exercising legal claims.

Transfers of the Personal data we process are stored on servers located on cloud servers established within the European Union.
 
8. DO WE TRANSFER YOUR DATA ABROAD?

Transfers of the Personal data we process are stored on servers located on cloud servers established within the European Union.
We do not transfer your data to countries outside the EEA.

9. ARE YOUR DATA SAFE AND SECURE?

We commit to safeguard your Personal data. We have taken all the appropriate organizational and technical measures to secure and protect your Personal data from any form of accidental or fraudulent processing. These measures are reviewed and amended when deemed necessary.

10. WHAT ARE YOUR RIGHTS ?

�          You have the right to access your Personal data

This means you have the right to be informed from us about whether we process your data. If we process your data you can request to be informed about the purpose of processing, the type of Information we keep, the recipients, the retention periods, whether we do automated decision making, as well as about your other rights, such as rectification, erasure, restriction of processing and to lodge a complaint with the relevant Data Protection Supervisory Authority.

�          You have the right to rectify your inaccurate Personal data

You have the right to obtain from us without undue delay the rectification of your inaccurate personal data (correct a wrong or previous e-mail etc.). Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

�          You have the right to erase your Information / right to be forgotten

You can request from us to delete your Personal data if it is not necessary for the above-mentioned purposes or if you wish to withdraw your consent in case this is the only lawful basis for processing.

�          You have the right to data portability

You can request form us to receive in a readable format your Personal data that you have provided us or request from us to transfer your Information to another data controller.

�          You have the right to restrict the processing of your Personal data

You can request from us to restrict the processing of your Personal data for as long as the examination of your objections is pending.

�          You have the right to object to the processing of your Personal data

You can object to the processing of your Personal data or withdraw your consent and we will stop the processing if there are no other imperative and legitimate reasons that override your right.

11. HOW CAN YOU EXERCISE YOUR RIGHTS?

If you wish to receive further information or exercise your rights, concerning the process of your personal data, you can communicate with us via e-mail at the address info@smartcv.co.

We will reply to your request without delay, within (1) one month after receiving it and without any cost for you. The above time-period might be extended for two (2) more months, due to the complexity or the number of the requests. In such a case you will be informed for the time extension and the reasons for it, as soon as possible and in any case within (1) one month since receiving your request.

If your requests are obviously unfounded or excessive particularly because of their recurring nature, the Company may impose a reasonable fee, taking into account the administrative costs for providing information or performing the requested action, or refuse to respond to the request justifying the answer to you.

In case you believe that: a. your request has not been satisfied sufficiently and legally or b. your right in protecting your personal data has been violated� by our process, you have the right to lodge a complaint with the relevant supervisory authority of your residence. In order to obtain more information on how to file a complaint, you can visit Hellenic Authority�s website ( http://www.dpa.gr/ ), where detailed information is available.

12. A FEW MORE INFORMATION

We do not make automated individual decision-making.

Our website is not intended for minors under 16 years of age.

13. LINKS TO OTHER NETWORKS

In the event that we provide links to websites of other organizations, this privacy policy does not cover how the other organization processes personal data. We encourage you to read the privacy policy of the other website you are visiting.

14. CHANGE OF OUR POLICY

We will update this Policy whenever deemed to be necessary. If there are any significant changes to the Policy or the way we use your personal data, we will notify you either by posting those changes on a visible place to our website, before the changes come into force, or in any other appropriate manner. We encourage you to read this Policy on a regular basis in order for you to be aware on the way your Information is protected. Last change in our policy was made at 14/12/2020.

15. CONTACT US

SMARTCV PC

GEMI Number: 152534301000

Ziriou 5, 111 45  Athens
Tel.: +30 210 2208711

email:  info@smartcv.co
web:   www.smartcv.co