Privacy Policy

PERSONAL DATA PROTECTION POLICY

(Annexes: Level B – Notice on the Processing of Personal Data Obtained Through Video Surveillance Systems, CV Policy).

Purpose of this Policy
The protection of personal data is a priority for HCN. This policy sets out how personal data is collected, processed, and stored through the application. It explains the categories of data collected, the reasons for collection, the groups of people to whom data may be disclosed, and the rights of data subjects. HCN makes every effort to ensure the privacy of personal data, provided that the information shared is accurate and complete. Additionally, this policy outlines the security measures in place to protect the data, as well as the commitments HCN has made regarding the limitations on the use of personal data.

HCN Commitment to Your Privacy
At HCN, protecting our clients’ privacy and personal data is our highest priority. We are dedicated to delivering personalized services tailored to your needs while ensuring your information remains secure. Personal data is used solely by HCN and its authorized employees to respond to your requests and enhance your experience, strictly following this Privacy Policy. Our team is trained to handle personal information with care and confidentiality. HCN representatives and trusted service providers maintain strict confidentiality and use your data only to provide the services you have requested.
In some cases, we may ask for your permission to share information with trusted third parties. We will clearly inform you at the time of data collection if such sharing is anticipated. HCN will specify the types of businesses involved, the nature of the data shared (e.g., your address or email), and will only disclose information with your explicit consent.

Legal and Regulatory Framework
The limited liability company ΕΛΛΗΝΙΚΑ ΔΙΚΤΥΑ ΚΑΛΩΔΙΩΝ ΕΠΕ – HCN (Hellenic Cable Networks LTD – HCN), operating under the trade name HCN ΕΠΕ, located at 90-92 I. Pasalidi Street, Kalamaria, Thessaloniki 55132, as legally represented, with tel. (+30) 2313 250 000, email office@hcn.gr, collects and processes personal data to fulfill its responsibilities, operate its electronic services, and comply with legal obligations. For the purposes of this policy, HCN acts as the “Data Controller” as defined in Article 4(7) of the General Data Protection Regulation (GDPR). The collection, management, and protection of personal data provided by visitors and users through this application, which is owned and operated by HCN, are governed by these terms, the GDPR (Regulation 2016/679), and Law 4624/2019. These terms reflect both the fast-evolving nature of technology—especially the internet—and the existing legal framework governing data protection. This application strictly adheres to personal data protection principles and will not use your information improperly or without your explicit consent. We do not disclose, publish, or share any personal data you entrust to us. Furthermore, your personal information, including email addresses, will never be transmitted to any third-party organization or partner that is not directly affiliated with HCN.

What is the GDPR – Applicable Law
The General Data Protection Regulation (GDPR), formally Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter “the Regulation”), establishes a consistent legal framework for the processing of personal data throughout the European Union, replacing the previous Directive 95/46/EC. The Regulation recognizes that the protection of natural persons regarding the processing of personal data is a fundamental right, as stated in Article 8, paragraph 1 of the Charter of Fundamental Rights of the European Union and Article 16, paragraph 1 of the Treaty on the Functioning of the European Union (TFEU). The GDPR is directly applicable in all EU Member States and does not require transposition into national law (Article 83 of the Regulation).

What is personal data?
The term “personal data” refers to information considering natural persons, such as name, postal address, e-mail address, contact telephone number, etc., which identify or can identify you, hereinafter referred to as “Personal Data” or “Data“.

What is Personal Data Processing?
Any act or series of acts performed with or without the use of automated means, in Personal Data or in personal data sets, such as the collection, registration, organization, structure, storage, adaptation or modification, retrieval, the search for information, use, disclosure by transmission, dissemination or any other form of disposal, association or combination, restriction, deletion or destruction.

What is a Data Controller?
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

What is a Data Processor?
The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Is the provision of your data necessary?
Submitting personal data to HCN via this website may be either required or optional, depending on the purpose outlined in this Policy. If you choose not to provide the information marked as mandatory, it will prevent us from fulfilling the primary purpose of collecting that data. This may, for example, make it impossible for HCN to deliver certain services available on this website.

What kind of data does HCN collect through this application?
HCN collects any information that qualifies as personal data under the Personal Data Protection Regulation only if its collection is not required by law or related to the conclusion or performance of a contract. Such data is collected through this website solely when you provide your explicit consent.

We collect the following personal data:

We do not collect or access any special categories of personal data (“sensitive data”) or information related to criminal convictions and offences from our clients. Clients are required to refrain from submitting such data concerning themselves or third parties. Should such data be inadvertently provided to HCN, it will be promptly deleted upon our awareness. HCN assumes no liability for any sensitive data submitted or processed due to clients’ failure to comply with this requirement. Visiting the HCN website does not typically require you to share personal data. However, in certain cases, providing specific personal information is necessary and clearly indicated in the relevant data entry sections on this website.

HCN may collect and store your personal information from the following limited sources:
a) Identification, contact, transaction, contractual, and behavioral data collected when you enter into a contract with us for the provision of our services.
b) Identification, contact, transaction, contractual, and behavioral data collected when you purchase products or services online from HCN.
c) Contact data collected when you contact us to request information or make inquiries about the services we offer.
d) Information available from publicly accessible sources.

Collection and Purposes of Use of Personal Data
Contract: We process your personal data to fulfill our contractual obligations to you, including order processing, billing, handling claims, and providing customer support.
Transactions: Your personal data may be used to complete transactions, such as credit card payments and other payment processing activities.
Marketing and promotions: With your explicit consent, we may use your contact details to inform you about competitions, special offers, and other promotional activities from HCN, its partners, and sponsors.
Website improvement and personalization: We use your information to tailor the website’s content to your needs, improve its functionality, and make it more user-friendly.
Credit checks: In some cases, we may conduct credit checks with relevant institutions if you request certain products or services. These checks will be clearly stated in the relevant terms and conditions.

Legal compliance: We also collect and process personal data when required by the General Data Protection Regulation (GDPR) or other applicable laws, or to protect the legitimate interests of both parties involved in the business relationship.

IMPORTANT NOTE: For the collection of personal data that does not occur electronically through the HCN website and pertains to the processing of personal data of employees, prospective employees, partners, contractors, suppliers, clients, and individuals in general, data subjects are provided with separate, detailed written information at the time of data collection, in compliance with the requirements of Articles 13 and 14 of the GDPR.

Data Retention and Storage
At HCN, we store personal data only for as long as necessary to provide the service you have requested or for which you have given your consent, unless otherwise required by law. This includes compliance with applicable commercial and tax legislation, as well as other relevant regulations. In any case, personal data you provide to us—reflected in written agreements, contracts, or electronic correspondence related to contract execution or commercial transactions—are retained for a period of 20 years. These records are securely stored in both physical and electronic formats within the legal, sales/contracts, and accounting departments of HCN, or with third parties who directly or indirectly provide these services, assist these departments, or offer management services to us.

Data Deletion
Your data will be deleted as required in each case and always in accordance with the provisions set forth by the applicable legislation.

Transfer of Personal Data
HCN does not transfer personal data to third parties unless it is necessary for legitimate purposes, to respond to your requests, or if required or permitted by law. Access to your personal data is strictly limited to authorized personnel who require it to carry out the purposes of collection, use, and processing as outlined in this Statement. In certain cases, HCN may transfer your personal data to competent public authorities or to third parties entrusted with processing on our behalf, provided that we inform you in advance and obtain your consent when required. All individuals with access to your data are obligated to maintain its confidentiality.

Date Security
The Internet, like any medium used to transmit information, cannot be considered 100% secure. Internet security is a sensitive issue that relies primarily on trustworthy organizations and businesses that respect the confidentiality and protection of their users’ data. At HCN, we are committed to maintaining strict security measures and protocols to safeguard your personal information and ensure compliance with all applicable legal requirements. We implement technical and organizational safeguards designed to protect the data we collect from you against any intentional or accidental attempts of access, handling, loss, destruction, or unauthorized use. Our security practices are continuously reviewed and updated in line with the latest technological developments. Access to your personal data is strictly limited to authorized employees who require it to provide products and services to you. Physical, electronic, and procedural safeguards are in place, fully aligned with data protection regulations, to ensure the security of your personal information. While HCN takes every possible precaution to keep your data secure, due to the inherent nature of the Internet, we cannot guarantee the absolute protection of communications or data stored in browsers from unauthorized access by third parties.

Internet Access
If you contact HCN via the internet, we may occasionally use the email address or telephone number you have voluntarily provided to correspond with you. Please be advised that communications transmitted over the internet, including emails, are not secure unless properly encrypted. HCN disclaims any liability for unauthorized access to or loss of your personal information that occurs beyond our reasonable control.

Privacy Policy and Children
This application is designed and intended for use by adults. If you are a minor under the age at which parental consent is required in your country (in Greece, this age is over 15 years, in accordance with Law 4624/2019), you should review this Statement together with your parent or legal guardian to ensure that you fully understand and accept its terms. In the event that we discover we have collected personal information from a minor without the required consent of their parent or guardian, we will take prompt action to delete such information as soon as possible.

Contact via This Application
Should a user choose to communicate with us, whether through the contact form or by any other means, the provision of personal data is voluntary and made at the user’s sole discretion. We will process any personal data provided only to the extent necessary to fulfill the specific purpose of the communication.

Social Networks
Our website may provide features that enable you to share content and activities with Social Networks and related platforms. These tools facilitate the sharing of your interactions on our website with other applications, websites, or media outlets, and vice versa. Utilizing such features allows you to share information with your contacts or the public, depending on the privacy settings you have configured in your personal profile. For detailed information on how your data is processed by these social networking services, please refer to the respective Privacy Policies.

Special Categories of Data
We kindly request that you refrain from sending sensitive personal data to us via email or disclosing such data through this application. The processing of this category of personal data is not intended or necessary for the purposes outlined in this Policy.

Recording of Telephone Conversations
All telephone conversations are recorded and retained for a period of 90 days. In the absence of a justified need or explicit request to preserve a specific recording beyond this timeframe, the conversation will be permanently deleted after 90 days.

External Links
Our application may include links to external websites. This Privacy Statement exclusively governs the use of this website, which is operated solely by HCN. Under no circumstances shall the operator of this portal be held responsible for the data protection practices or policies of third-party websites, which fall under the jurisdiction of their respective owners (natural or legal persons).

Revisions to the Statement
HCN reserves the right, at its sole discretion, to amend or revise this Statement periodically. In the event of any changes, HCN will indicate the date of the latest amendment on this Statement, and such updated Statement shall become effective as of that date. We encourage you to review this Statement regularly to stay informed of any modifications in the manner in which we process your personal data.

Applicable Law and Jurisdiction
Any disputes arising between a user and HCN shall be governed by Greek law. The competent courts with jurisdiction over such disputes shall be those of the Prefecture of Thessaloniki.

What are your rights?
Under the EU General Data Protection Regulation (GDPR) 2016/679, as applicable, you have the following rights:
(a) the right of access,
(b) the right to rectification,
(c) the right to erasure (in certain circumstances, such as when the data is no longer necessary for the purposes for which it was originally collected and there is no compelling reason for us to continue processing or storing it),
(d) the right to restrict processing,
(e) the right to data portability,
(f) the right to object and the right not to be subject to decisions based solely on automated processing, including profiling,
(g) the right to lodge a complaint with the supervisory authority.

That is, you have the right to obtain, free of charge and upon request, information regarding the personal data stored about you. You also have the right to object to the processing of your data, with effect for the future, and to withdraw your consent at any time. In addition, in accordance with applicable provisions, you have the right to request rectification, restriction of processing, data portability, and erasure of your data, as well as the right to lodge a complaint with the competent supervisory authority. To exercise these rights, please submit your request in writing, either by sending an original signed letter or by email, to the Company’s Data Protection Department at the contact details provided below.

Right to Lodge a Complaint
If you consider that the processing of your personal data violates the provisions of Regulation (EU) 2016/679 (General Data Protection Regulation), you have the right to lodge a complaint with the competent supervisory authority. In Greece, the supervisory authority is the Hellenic Data Protection Authority, located at 1-3 Kifisias Street, 115 23, Athens, Greece. Further information is available at www.dpa.gr or via telephone at +30 210 6475600.

Contact
HCN has appointed Data Protection Officers, who may be contacted at the following address: gdpr@hcn.gr. Should you have any questions or suggestions regarding this Policy, please do not hesitate to reach out to this address. Continuous developments on the Internet and in the field of data protection necessitate periodic updates to this Policy. HCN reserves the right to modify these rules at any time, in order to ensure full compliance with applicable data protection laws and regulations.

Level B – Notice on the Processing of Personal Data Obtained Through Video Surveillance Systems

Information on the Data Controller: The limited liability company ΕΛΛΗΝΙΚΑ ΔΙΚΤΥΑ ΚΑΛΩΔΙΩΝ ΕΠΕ – HCN (Hellenic Cable Networks LTD – HCN), operating under the trade name HCN ΕΠΕ, located at 90-92 I. Pasalidi Street, Kalamaria, Thessaloniki 55132, as legally represented, with tel. (+30) 2313 250 000, email office@hcn.gr.
Purpose of Processing and Legal Basis: The operation of our surveillance system serves the purpose of safeguarding individuals and protecting property. This processing is carried out pursuant to our legitimate interests as a Data Controller, (Article 6(1)(f) of the GDPR).

Analysis of Legitimate Interests: Our legitimate interest lies in the protection of our premises and the assets located therein from unlawful acts such as theft. This also extends to safeguarding the lives, physical integrity, health, and property of our personnel and third parties lawfully present on the monitored premises. We collect image data solely in areas where we have determined there is a heightened risk of such unlawful acts—such as theft or vandalism—given the specific nature of our commercial operations. Video recording takes place at key access points, including the main entrance to our offices, as well as designated areas such as the reception area, cash registers, the control room, the perimeter of our building, the warehouse, and locations housing mechanical equipment. We ensure that cameras are positioned to monitor only protected property and not employee workstations or areas. Under no circumstances do we record in areas where there is a reasonable expectation of privacy (e.g. areas designated for eating, personal hygiene facilities, or toilet lobbies).

Data Recipients: The stored material is accessible only to authorized personnel of our company and external partners, who are bound by data processing agreements under Article 28 of the General Data Protection Regulation (GDPR) and are contractually obligated to maintain strict confidentiality and ensure data security. Data will not be disclosed to third parties, except in the following cases: (a) to the competent judicial, prosecutorial, or police authorities, when the data are necessary for investigating a criminal offense involving persons or property of the data controller; (b) to the competent judicial, prosecutorial, or police authorities, when they lawfully request such data in the exercise of their duties; (c) to the victim or the alleged perpetrator of a criminal offense, when the data may constitute evidence of the offense; (d) to any party demonstrating a legitimate interest, in accordance with applicable law.

Retention Period: We retain the data referenced in paragraph 20 (CCTV) for a period of five (5) days, after which it is automatically deleted. Should an incident be identified within this timeframe, the relevant video segment will be securely isolated and retained for an additional period of up to one (1) month to facilitate investigation and, if necessary, initiate legal proceedings to protect our legitimate interests. In cases where the incident involves a third party, the retention period may be extended up to three (3) months.

Rights of Data Subjects: Data Subjects have the following rights in relation to the processing of personal data captured through Closed-Circuit Television (CCTV) systems, as described in Paragraph 20 of this Notice: • Right of Access: You have the right to be informed whether we are processing your image and, if so, to obtain a copy of that image. • Right to Restriction of Processing: You may request that we restrict the processing of your data, for example, by refraining from deleting footage you deem necessary for the establishment, exercise, or defense of legal claims. • Right to Object: You have the right to object to the processing of your image for reasons related to your particular situation. • Right to Erasure: You may request the deletion of your personal data under the conditions set forth by the General Data Protection Regulation (GDPR). To exercise any of the above rights, you may contact us by sending an email to gdpr@hcn.gr, by submitting a written request to our official postal address, or by presenting your request in person at our offices. In order for us to process your request effectively, we kindly ask that you provide an approximate date and time when you were within range of our CCTV cameras, along with a recent image of yourself. This will assist us in identifying your data and ensuring the privacy of any third parties depicted in the recordings. Alternatively, you may visit our premises to view the footage in which you appear, under our supervision. Please note that the submission of a request for objection or erasure does not guarantee the immediate deletion or cessation of processing. All requests will be evaluated in accordance with GDPR requirements, and we will respond to you as soon as possible, and in any event within the statutory deadlines.

Right to Lodge a Complaint: If you consider that the processing of your personal data violates the provisions of Regulation (EU) 2016/679, you have the right to lodge a complaint with the competent supervisory authority. In Greece, the supervisory authority is the Hellenic Data Protection Authority, located at 1-3 Kifisias Street, 115 23, Athens, Greece. Further information is available at www.dpa.gr or via telephone at +30 210 6475600.

CV Policy

HCN collects CVs and accompanying documents directly from individuals expressing interest in working with us. This data is essential to evaluate each candidate’s suitability for a specific role or collaboration. By voluntarily submitting your CV and related documents, you consent to the collection, storage, use, processing, and transfer of your personal information as described in this notice. HCN takes all appropriate technical and organizational measures to ensure the secure processing of your personal data.
Access to your personal data is strictly limited to authorized HCN personnel or, where necessary, to staff from partner companies (“Processors” or “Controllers” for whom HCN acts as a Processor). These partners are bound by confidentiality agreements. Your data may be shared only with these affiliated parties for the specific purposes related to the evaluation and selection for the position. HCN will not disclose, sell, exchange, or transfer your personal data to unrelated third parties without your explicit consent, except as required for the role in question or in compliance with Article 6(1)(b) of the General Data Protection Regulation (GDPR). Affiliated companies will use the data solely for collaboration with HCN.
The purpose of processing the submitted personal data is to assess your qualifications with a view to potentially entering into a cooperation agreement, as requested by you, the Data Subject. This includes verifying your credentials, evaluating your fit for the role, integrating you into HCN’s project framework if applicable, and facilitating communication throughout the process. The legal basis for this processing is Article 6(1)(b) of the GDPR, which permits data processing necessary for pre-contractual steps and to protect HCN’s legitimate interests.
If the individual has provided consent for future cooperation opportunities, HCN will retain the CV and related data for up to 6–12 months from the date of submission. During this period, the information may be used to evaluate the candidate for any new or relevant positions. After this timeframe, the data will be securely deleted, anonymized, or destroyed.
If such consent has not been granted, the CV data will be retained only for the specific position to which the candidate applied. Once that position is filled, the data will be securely deleted, anonymized, or destroyed within a maximum of three years, unless legal obligations require HCN to retain it for a longer period. Any additional personal information required to fulfill insurance or tax-related legal obligations will be processed exclusively for purposes directly linked to the individual’s cooperation with HCN. After the cooperation ends or expires, such data will be stored only for the duration legally required, and then securely deleted, anonymized, or destroyed.