Personal Data Protection Policy

Welcome to the website www.netourwork.com. We take personal data protection issues responsibly and sensitively, and for this reason we have created this policy so that you can find out how your data is processed by our Company.

1. Introduction – Data Processing Controller

The website at www.netourwork.com, hereinafter referred to as “the Site”, belongs to INNOVATIVE NETWORKS GP (General Partnership), holder of Tax ID number 801038180 issued by the Marousi Tax Office, which has its registered offices at 31, Dios Street, Melissia, Athens, PC 15127, here in after referred to as “the Company” or “we”, having as its purpose the provision of tourist and other online promotional and advertising services, as well as the organisation of training seminars for professionals, Telephone: 2108033473, Email: info@netourwork.com.

In order to be able to provide our services and also to comply with our legal obligations, we process certain information about visitors to and members of the Site. This data could lead to their identification, either directly or indirectly. Under the current legal framework, some of this information is “personal data,” while you, as a guest or member, are considered to be “data subjects” and we, as a company, are the “data processors” of your data.

The purpose of our policy is to provide you, in an easily understandable and concise way, with information about which personal data we process, for what purpose, with whom we share that information, and about your rights and how to exercise them. If you have any questions about the processing of your data or the exercising of your rights, please feel free to contact us at privacy@netourwork.com

2. The basic principles of data processing

We undertake to process your data in a fair and transparent manner, in accordance with the applicable legal framework, namely the General Data Protection Regulation (GDPR), Law 3471/2006, other relevant legislation and the decisions of the Personal Data Protection Authority.

Simply put, this means that:

• We process your data only for purposes that are explicit, legitimate and determined from the outset, and we do not process them further in any manner incompatible with these purposes (limitation of purpose)
• We process only data that is appropriate, relevant and necessary for the intended purposes set for processing (minimisation)
• We make every effort to ensure that your data is accurate, giving you, where appropriate, the ability to have it corrected/deleted
• We retain your data in a format that allows us to identify you only for the time required for the intended purposes set for processing (storage period limitation)
• We make every effort to safeguard the security of your data, protecting it from unauthorised or illegal processing and accidental loss, destruction or damage.

Within the framework for protection of your data, the Company implements a range of appropriate technical and organisational measures, adopts internal security policies, trains its staff, who are committed to maintaining confidentiality and secrecy, and exploits a range of technologies to ensure that your data is secure (e.g. SSL certificates, encryption, certified hosting providers).

In strict compliance with the principles of information security and data protection, we regularly monitor security measures and, if necessary, adapt them to comply with new best practices.

3. Which personal data do we process?

First of all, the Company only processes your data when you actively provide it yourself (such as when you fill out a contact form or when you sign up).
This rule does not apply to certain data collected through cookies (see in detail here) and some data that we automatically collect during your visit to the Site.

A. Information gathered automatically

When you visit our Site, our server records your IP address, which according to applicable law is personal data, even if we cannot identify you on the basis of this information alone. In addition, we collect certain other information, such as the date and time of your visit, the page from which your visit came, the type of browser, and the operating system you use to visit the Website.

The processing of such data by us rests (its legal basis) on the Company’s legitimate interest, since it is technically necessary both for the operation of the Site and to safeguard networks, information and services from random events or illegal or malicious actions which compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data (e.g. denial of service (DOS) attacks).

This processing is in line with the relevant legal framework, given that it does not carry serious risks to your rights and freedoms.

Β. Information you provide to us
We process personal information you provide to us in the following cases:

I. Communications with the Company via contact form/email

II. Creation of an Account

IΙΙ. Newsletter

Important note: Responsibility for the accuracy of the information submitted in all cases is borne by the person submitting it. You may change your personal information at any time through your personal account. Find out about correcting your personal information in the section of the policy statement concerned with your rights.

4. Who has access to your data

As a rule, access to your data is granted to authorised personnel of the Company, who process your data in the strictest confidentiality, and only to the extent and in the context of the purposes which we have already outlined for you.

Furthermore, in order to be able to provide our services, we share some of your data with affiliated companies. These companies (data processors) process your data only for the purposes mentioned above and only for and on behalf of the Company, with the exception of any legal obligations. During transmission of your data, the Company takes all necessary technical and organisational measures to ensure the best possible level of security.

In the context of the provision of its services, the Company has the right to disclose your business details (name, surname, business name, address, email, telephone) to the organisations responsible for providing the training services you have received, with the object of verifying participation and for future communications with you. You reserve the right to object to this processing of your data at any time by submitting a statement to the organisation concerned.
One of the key criteria for choosing our partners is their adherence to the rules for the safe processing of your data, and our partners are also contractually bound to provide guarantees and take appropriate technical and organisational measures to ensure that processing is conducted legally and to ensure the protection of your data and your rights.

These companies provide us with: (a) web hosting services, (b) commercial marketing services of the services we provide to you, (c) video recordings, sound recordings and live streaming services.

Newsletters are sent out using the services of SendinBlue, which has registered offices in Paris (55, Rue d ‘Amsterdam, 75008 Paris, Registration No 498019298). SendinBlue provides its services in compliance with the General Data Protection Regulation (GDPR). View the Company’s data protection policy here.

The webinar and live streaming are viewed using the services of the Los Angeles-based CSZ Corporation (5482 Wilshire BLVD, Suite 1642, CA 90036.)
CSZ Corporation provides its services in compliance with the General Data Protection Regulation (GDPR), respecting the Privacy Shield Agreement standards for secure data transfer between the EU and the USA. View the Company’s data protection policy here.

5. Where and for how long do we store your data

Your data is stored in the Company’s information system, which is hosted in a data centre located in Germany and any backups are held on servers within the European Union. In any case, appropriate organisational and technical measures are always applied to avoid any violation. Data is stored exclusively for the period of time necessary for the purpose in each case. For example, if you have registered with the Site, the data remains stored for as long as you remain registered. If your account remains inactive for a long time, the Company will notify you and if there is no response, it may delete all of your data, except for whatever details are necessary to comply with legal obligations or any pursuit of claims.

6. What are your rights regarding your data and how can you exercise them

Based on the respective legal framework, you have a number of rights in relation to the processing of your data by the Company.
Specifically, you have the right to:
1. Submit a request to the Company to inquire whether we process data and, if so, which information (right of access)
2. Ask for correction of personal information (right to rectification),
3. Request, under certain conditions, deletion of information (right to erasure),
4. Request, under certain conditions, limitation of personal data processing (right to restriction of processing)
5. Object, under certain conditions, to processing by us (right to object), especially with regard to processing of data related to marketing (e.g. issue of newsletters),
6. Ask for the data you provide to us in a structured, commonly-used and machine-readable format (right to data portability), if this is considered to be technically feasible.
7. In case of a data breach which may put your rights and freedoms at high risk, if this does not fall under one of the exceptions provided for in the GDPR, the Company undertakes to inform you of the breach without unjustifiable delay.

Compliance with the legal framework for data processing and, in this context, the exercise of your rights is a priority for us. For this reason, we have the right to request the provision of additional information necessary to confirm your identity, before you exercise your rights.

In principle, the Company is required to respond to your request immediately, and within one month at the latest. If deemed necessary, taking into account the number and complexity of the request(s), this period may be extended by a further two months. In each case we will notify you as soon as possible, and always within one month of submitting your request, regarding the progress of your request and the reason for any potential delay in the satisfactory resolution of your issue.

In the event that your claims are clearly unfounded or excessive, in particular because of recurrence, the Company may either impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or refuse to follow up on your request.

If you believe that we are not in compliance with data protection legislation, you have the right to submit a complaint to the Greek Data Protection
Authority (www.dpa.gr).

7. Hyperlinks to third party websites

Access to third party websites is provided with the assistance of appropriate hyperlinks on the Site. The placement of these hyperlinks has been done for the sole purpose of facilitating visitors while browsing the internet. It is in no way an indication of the acceptance or approval of the contents of the websites shown by a hyperlink.
Access using the links provided on this site its done solely at your own discretion and we encourage you to read the data protection policy of each website you visit carefully.

8. Social Media

Facebook
The Company maintains an official Facebook page (https://www.facebook.com/Netourwork-1824620037609043/). You can contact us through our Facebook page to get more information about our services via the ‘send message’ facility. In order to respond to your queries, we process your Facebook username and other information publicly available through your profile (e.g. your email address). Sending a message for the purposes of communication between us implies your consent to the abovementioned processing of your data. Access to and use of the webpage is subject to this Personal Data Protection Policy.

In the event that you choose to click “LIKE” on our page, this means that you give your consent to view news and promotions (via the newsfeed) made by the Company through its Facebook page. If you do not wish to receive such updates, you can click “UNLIKE” at any time.

Facebook Inc., 1601 S California Ave, Palo Alto, CA 94304, USA and Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin, Ireland, are responsible for Facebook’s operations in the European Union. You can learn about the processing of your Facebook data via the following links:

https://el-gr.facebook.com/policy.php?CAT_VISITOR_SESSION=c7b73ebc78d1681ade25473632eae199
https://el-gr.facebook.com/business/GDPR

Instagram
The Company maintains an official Instagram account (https://www.instagram.com/netourwork/). Through the Instagram platform you can follow the Company’s account and comment on its posts, thus providing data to be processed on the platform. Instagram, which belongs to Facebook Inc., 1601 S California Ave, Palo Alto, CA 94304, USA, and Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin, Ireland, has its own cookie and data protection policies, over which we exercise no control and which we are not in a position to influence. Access to Instagram is solely at your own risk, and we encourage you to read its Data Protection Policy carefully since you are accepting its terms by using its services.

Twitter
The Company maintains an official Twitter account (https://twitter.com/netourwork). Through the Twitter platform, you can follow the Company’s account, retweet and comment on its posts, thus providing data to be processed on the platform. Twitter, which belongs to Twitter, Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, has its own cookie and data protection policies over which we exercise no control and which we are not in a position to influence. Access to Twitter is solely at your own risk and we encourage you to read Twitter’s data protection policy carefully, since you are accepting its terms by using its services.

YouTube

The Company maintains an official YouTube channel (https://www.youtube.com/channel/UCgzRn36s1FapYM08MJ2bkDw). Through the YouTube platform, you can follow the Company’s account, watch its video posts and comment on them, thus providing data to be processed on the platform. YouTube, which belongs to Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA, has its own cookie and data protection policies over which we exercise no control and which we are not in a position to influence. Access to YouTube is solely at your own risk, and we encourage you to read Google’s Data Protection Policy carefully since you are accepting its terms by using its services.

General information regarding social media

The Company takes all appropriate technical and organisational measures to ensure the security of data processing via social networking, including, but not limited to, restricting the number of persons with administrator-level access to each page. The Company is only responsible for the method and means by which it processes your data for its own purposes (communication, information and promotions) and to the extent that it exercises control over your data. On the other hand, it bears no responsibility for the method or means that any social networking platform uses to process your data.

In all cases, we urge you to be particularly careful about the content you post on our social media platform pages, especially when you provide personal or third party personal information, and you must make sure that the page you are communicating with is indeed the official page.

Comments on Social Media

We encourage users to comment on posts and/or on pages they maintain on social media, in the context of an open dialogue with respect for differing opinions. We do not have a general obligation to review the content submitted by users of these social media platforms, although it does work to ensure a secure online environment.

Accordingly, the Site administrators reserve the right to remove any kind of content found to be in violation of its terms of use, such as content that is abusive, vulgar, pornographic, threatening, constitutes advertising, or infringes intellectual property rights or contains a false statement about the user, and at the same time it reserves the right to block users who submit such material. Should you believe that user content hosted on Company pages on social media platforms affects or otherwise violates our terms of use, please contact the administrators directly.

9. Minors

The Company operates its services exclusively for persons over 18 years of age. In the case of submission of orders, the user/visitor is presumed to be over 18 years of age or, if they are under 18, they are presumed to have obtained the necessary consent from the person having parental responsibility, and it is also presumed that said person’s information will be provided if requested by the Company.

Since it is not technically feasible to effectively control the age of the visitors/users of the Site, we are committed to deleting all relevant information if the submission of personal data relating to minors is reported. This deletion is without prejudice to the need to keep the data in the event of provision of grounds for, or exercise or support of our legal claims or the fulfillment of a legal obligation.

10. Changes in policy and updating of information

This policy may be changed at any time and without prior notice. Guided by the principle of transparency, we are committed to notifying you of any major changes in our policy. In any case, however, you should periodically review our policy, since the use of our services implies acceptance of its terms by you.