Privacy Policy

Effective Date

November, 1st 2024

For prior version, please click here.

1. WHO IS THE DATA CONTROLLER?

The Website and our Services are made available by our main office (“Company”). Where this Privacy Notice refers to “Dirigo”, “we”, “us”, “our”, this means one or more of the Company that provides the particular Website, Mobile Application, Newsletter or Services to you, recruits you, uses testimonials from you, sends marketing communications to you, hosts an event you visit, or organizes a program in which you participate.

For the purposes of the GDPR, the following Company acts as a data controller when the processing of your Personal Data is governed by the requirements of the GDPR.

Location: Greece

Dirigo PC (company no: 800738776) is a company established under the laws of Greece with its registered office at 2nd Floor, No 10, Menexedon, 14564, Kifissia, Attica, Athens, Greece.

Find the office location here.

2. WHAT PERSONAL DATA DOES DIRIGO COLLECT, HOW DO WE USE YOUR PERSONAL DATA AND WHAT LEGAL BASIS DO WE RELY ON?

A) Personal Data we collect directly from you (“Collected Data”)

1. Purpose: providing you with the Services. We may use, retain and process your Personal Data for the following purposes when providing our Services:

to provide the Services.
to administer your account (including when you subscribe and sign-up to any of our Services).
to assess the needs of your business to suggest suitable Services and respond to service requests, questions or concerns.
to facilitate your transactions with other users when you use our Services.
to prevent or respond to any misuse of our Services or Applications or any violations of our Terms and any applicable laws.
to collect subscription fees.

The data processed includes:

contact information such as name, e-mail address, mailing address, IP address, geographic location, or phone number of the Account admin
If you attend any user conferences hosted by us at a physical location where we serve food and other refreshments, we collect information about your food preferences and allergies.

When you register for any of our programs through a registration form on our Site, we may collect information such as your name, e-mail address, company name, designation, company website URL, IP address, location and contact information.

2. Purpose: Recruitment, Dirigo Careers. When you apply for an open position by either populating the application form, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf, we will use such data to evaluate you for the open position that you have applied for or any position that we consider you suitable for at the time you submit your resume ("application") or at any later date. For the purposes of evaluating you for an open position, you understand that we may internally rate you based on parts of your resume ("application") and your information. If you do not wish to be rated by us, please do not provide us your information. The data processed includes:

contact information, such as name, email address, mailing address, phone number, and (subject to local laws) links to your social networking profiles;
any other information you volunteer, including during any interview or your interactions with us and contained in the resume that you submit to us;
personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation (and subject to local laws), recruitment agencies, background check providers, credit reference agencies and your referees; and
details of your education, qualifications and employment history, any other personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences (only if that information is relevant to the role you are applying for and subject to local laws).

Subject to local laws, we may also use your personal data for the purpose of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit. We will retain data from applications for a limited period for record keeping and legal (or, subject to local law, regulatory) purposes. We may (subject to the laws in your jurisdiction) also retain your data in order to contact you if a role arises for which we think you would be suitable. Further information about this will be provided during the application process and we will ask for consent where necessary according to local law.

3. Purpose: Advertising and marketing to our Customers and prospective leads - advertising to you on social media and other platforms. We share your email address and other identifiers such as your phone number or device ID (usually in an encrypted or ‘hashed’ form) with third-party providers of social media platforms and other services, such as Facebook, LinkedIn and other similar platforms (“Social Platforms”), so that the third party providers can try to “match” your data with the data of their registered users of their Social Platforms. Where there is a successful match, we will display our advertising to you when you use the relevant Social Platform (e.g. on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customize” the audience that we want to reach on the relevant service. Some of the advertising that you see may be personalized to you.

The data that we use to personalize our advertising will include:

data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies;
information about when your current or previous sessions started;
details about any products you viewed through the Site; and,
IP address; browser type and operating system; geolocation; any other unique numbers assigned to a device.

B) Information that we collect from third parties.

From time to time, we may receive Personal Data about you from third party sources like databases and social media but only where we have checked that these third parties either have your consent to or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we obtain from such third parties include your name, e-mail address, postal address, location, designation, telephone number and we use the information we receive from these third parties to maintain and improve customer support experience, improve the accuracy of the records we hold about you and for our sales and marketing purposes.

3. WITH WHOM DO WE SHARE PERSONAL DATA?

We process Personal Data in Greece, where we are established [European Economic Area (“EEA”)].

When processing your Personal Data, we may need to share it with other third parties, as set out below. This list is non-exhaustive and there may be circumstances where we need to share Personal Data with other third parties:

With third party service providers providing us with services, such as research and analytics, anti-spamming and anti-phishing services, marketing and data enrichment or for them to reach out to you on our behalf;
With third party payment processors who process your credit card and other payment information for Dirigo but who are otherwise not permitted to store, retain or use such information;
With third party partners for the purpose of assisting us in onboarding you and providing any further support needed to use our Services;
With third-party social media networks, advertising networks and websites;
With external recruiters, and related organizations such as third-party providers that undertake employee background checks on our behalf and on behalf of other entities within our Company;
With auditors, lawyers, accountants and other professional advisers who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in;
Law enforcement or other government and regulatory agencies and bodies or other third parties as required by, and in accordance with, applicable law or regulation;
Other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of Personal Data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for Personal Data where we are permitted to do so in accordance with applicable law or regulation.

Where necessary (such as when we transfer data to service providers) we put in place appropriate contractual arrangements and security mechanisms to protect the Personal Data shared and to comply with our data protection, confidentiality and security standards and obligations. Further details can be provided upon request.

4. EEA, UK AND SWISS SPECIFIC RIGHTS

A) Collected Data (excluding Hosted Data).

If you are an individual resident in EEA, UK or Switzerland, you have the following data protection rights regarding Collected Data:

If you wish to exercise any of the following rights in relation to your Personal Data (hereinafter referred to as a “Request”), you can do so at any time by contacting us using the details in section 5:

Right	Description
Your right of access	If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification	If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your Personal Data with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your Personal Data with so that you can contact them.
Your right to erasure	You can ask us to delete or remove your Personal Data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your Personal Data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal Data with so that you can contact them directly.
Your right to restrict processing	You can ask us to “block” or suppress the processing of your Personal Data in certain circumstances such as where you contest the accuracy of that Personal Data, or you object to us processing it for a particular purpose. This may not mean that we will stop storing your Personal Data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your Personal Data to stop us processing it further. If we have shared your Personal Data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal Data with so that you can contact them directly.
Your right to data portability	You have the right, in certain circumstances, to obtain Personal Data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
Your right to object	You can ask us to stop processing your Personal Data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your Personal Data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your Personal Data for direct marketing purposes.
Your rights in relation to automated decision-making and profiling	You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent	If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
Your right to opt out of marketing communications	You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the details in section 18.
Your right to lodge a complaint with the supervisory authority	If you have a concern about any aspect of our privacy practices, including the way we have handled your Personal Data, please contact us using the details in section 18. You also have the right to complain to a data protection authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at EU Supervisory Authorities. The UK data protection regulator is the Information Commissioner’s Office and contact details can be found at ICO.
If you are residing in France: your right to give instructions regarding the processing of your data after your death	You have the right to give instructions regarding the retention, deletion and disclosure of your Personal Data after your death. You may designate a person to carry out these instructions. This person is then entitled to be informed of the directives and to request their implementation from us.

We respond to all requests we receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws. We can only process requests after we have verified your identity, which may mean requesting further information from you.

B) Hosted Data

As explained above, some of our Services include processing data on behalf of our customers in relation to Applications, tools or software that we provide. Save for the limited circumstances set out in this Notice, we are not the Data Controller of this Hosted Data as we do not determine the purposes or the means of the processing.

If you wish to access, correct, update, modify or delete Hosted Data or if you would no longer like to be contacted by one of our Customers you should direct your query to the Customer, who is the Data Controller of your data. If requested by the Customer to action a Request, we will respond within a reasonable timeframe.

If you are a Customer of our Services and wish to raise a Request on behalf of data subjects in connection with Hosted Data, you may raise a ticket on the support portal of the relevant Service. Please note that if a Customer has subscribed to more than one Service, a Request on a particular Service support portal is specific to that Service only and separate Requests need to be raised across other relevant Service support portals.

C) General Compliance

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Dirigo commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

If you have a question or complaint related to participation by Dirigo in the DPF Frameworks, we encourage you to contact us via info@dirigo.gr For any complaints related to the DPF Dirigo that Dirigo cannot resolve directly, we have chosen to co-operate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals, the UK Information Commissioner (for UK individuals) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving disputes with Swiss individuals. As further explained in Annex I of DPF Principles, binding arbitration is available to address residual complaints not resolved by other means.

5. CONTACTING DIRIGO

Under applicable data protection law, we must ensure that your data is accurate and up to date. Therefore please advise us of any changes to your information. You are entitled to request details of the information we hold about you and to have it rectified or deleted as required by applicable data protection legislation. To exercise these rights or for any other information, or If you have any questions about this Privacy Notice or our privacy practices, you can contact us at info@dirigo.gr or via postal mail at Dirigo PC, No 10, Menexedon, 14564, Kifissia, Attica, Athens, Greece at the attention of the Data Protection Officer with a copy to info@dirigo.gr.