Lever Development Consultants S.A. implements a certified Quality Management System according to ISO9001:2015, Environmental Management System according to ISO14001:2015 and Information Security Management System according to ISO27001:2013.
It also implements procedures for the Management and Protection of Personal Data in accordance with Regulation EU2016/679 (GDPR).
N.G.E.MI 043319006000
The Data Controller is the Societe Anonyme with the name “LEVER S.A. – Development Consultants” which is based in Thessaloniki (26th October 43, Limani center) and is legally represented, with a call center 2310-552113, 2310-541620 and e-mail contact [email protected] as well as each of the companies of the “SAMARAS & ASSOCIATES” Group as they are listed on the Company’s website, namely: (a) “SAMARAS & ASSOCIATES S.A. – CONSULTING ENGINEERS” (e-mail:[email protected]), (b) “SAMARAS & ASSOCIATES E.P.E.” (e-mail: [email protected]), (c) “DELTA ENGINEERING – Consulting Engineers E.T.E.” (e-mail: [email protected]), (d) “LEVER Learning I.K.E.” (e-mail: [email protected]), (e) “Pointers Property Services S.A.” (e-mail: [email protected]), (f) “GEOMELETITIKI E.T.E.” (e-mail: [email protected]), (“Companies”).
2.1. Any information we provide to you with this document, as well as any information you may request from us in the future, is provided to you free of charge, provided that the request is not made repeatedly, excessively or is manifestly unjustified (see more in 2.3.)
2.2. For each of the above rights that you exercise, the Companies will respond to you within one (1) month of receipt of the request or in case of objective difficulty, complexity of the request or number of requests, the Companies will respond within a maximum period of three (3) months in total regarding either the completion of your request or the justified refusal to execute what you requested for legitimate reasons explicitly specified in the General Regulation 2016/679.
2.3. In the event that we judge that any of your above rights is exercised manifestly unfounded or the request is excessive or (much more) of a repetitive nature, we are entitled on the one hand to impose a reasonable fee on you for the provision of further information (which is in principle free of charge) and on the other hand to refuse to follow up on the request.
2.4. In the event that we have reasonable doubts about your identity when you submit a request to exercise any of your above rights, we may request the provision of additional information necessary to confirm your identity before processing the request.
2.5. In the event that we delay beyond the justified period to respond to your request as well as in any case that you consider that your rights are violated or we are not consistent with the obligations to store your data, you are entitled to file a complaint with the supervisory authority. (Personal Data Authority, Athens Kifisias 1-3, P.C. 115 23, Athens, [email protected], +30-210 6475600.
2.6. You retain the right to withdraw your (any) consent provided at any time by submitting a relevant request document, as well as the right to address all your requests for the exercise of your rights below to the email address [email protected].
3.1 Right to Information
You have the right to request information regarding the personal data we have received from you and which we retain for one or more purposes as described below under A to C. This text as a whole constitutes a manual of basic information and understanding of the philosophy of the regulatory framework governing the protection of your personal data. Updates, in-depth information and clarifications to this text can be provided to you upon submission of a relevant request to exercise the right to information.
3.2 Right of Access
You have the right to request access to your data that we hold and confirmation as to whether it is being processed and more specifically information regarding the purposes of processing, the categories of personal data, the recipients or categories of recipients, the period of retention and processing, the existence of a right to complain to the Personal Data Protection Authority, any available information regarding the origin of the data when it has not been provided by you yourself, the existence or non-automated decision-making including profiling and the relevant methodology, guarantees regarding the policy we follow when the transfer is made to third countries, a copy of the personal data held and being processed.
3.3 Right of Rectification
You have the right to request rectification of your data in the event that any of the data for which we have the right to process has changed or has been incorrectly recorded.
3.4 Right to Erasure
You have the right to request the complete or partial erasure of your data that we are entitled to keep and process either because they are no longer necessary for the fulfillment of the purposes for which they were collected, or because you withdraw your consent, or because the data was collected for a purpose that you consider unlawful. Within a reasonable time (no longer than one month and under certain conditions if there is difficulty no longer than three months in total) we will respond to you confirming the complete or partial erasure of your data respectively or regarding the impossibility of erasing specific data if a law or the fulfillment of a duty in the public interest, or the right to freedom of expression and information or the exercise or support of a legal claim requires their preservation. In this case, you have the possibility of, on the one hand, filing a complaint with the supervisory authority, and on the other hand, of filing a legal appeal.
3.5 Right to Restriction
You retain the right to request restriction of the processing of your data, quantitatively, temporally or with regard to the purpose of their processing and more specifically (a) either because you dispute the accuracy of your data and for as long as we need to confirm their accuracy, (b) either because you consider the processing unlawful but instead of deletion you choose restriction (c) or because we no longer need to use them but you do not wish them to be deleted as their retention will serve you for a legal claim, (d) or in the case in which you have objections regarding the processing of the data and until it is verified whether your rights as a Subject prevail over the legitimate grounds for processing for us.
3.6 Right to Portability
You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit them without objection, given that the processing of your data is based on consent. In the context of exercising this right, you also have the possibility to request direct transmission from us to the third party without your intervention.
This right is exercised without prejudice to the limitations of the right to erasure (see above under 3.4.) and its exercise may not adversely affect the rights and freedoms of others.
3.7 Right to Object
3.7.1. You have the right to object to the use of your personal data for the purpose of direct marketing and profiling related to this direct marketing.
3.7.2. There is no relevant right in the case of Employee Candidates as this data is not transmitted to the Marketing department and is not treated as such.
Your data is not intended to be transferred to any organization outside the Companies with the exception of (a) the service providers supporting our Companies’ electronic systems and networks – and for the sole purpose of their execution of the contract to support our Companies and (b) the competent tax authorities in the context of our mandatory compliance with tax legislation and to the extent (and under the condition) that this is required.
We assure you that the Companies will exhaust every technical and organizational measure to protect the Data and will make the best, minimum and absolutely necessary use and processing of the Data as prescribed by law and strictly and exclusively for the purpose for which you have made it available to us.
A.1. Purpose: The receipt, processing and storage of your data provided exclusively in the context of communication (some or all of: name, email address, telephone number, address, capacity) is to inform you about the products, actions and news of the Companies, including the possible sending of commemorative gifts – corporate calendars and/or greeting cards.
A.2. Legitimizing basis for processing: The legitimizing basis for the processing of your data is your consent to it in order to fulfill the respective purposes above, pursuant to article 6 par. 1 letter a’ of the Regulation on the Protection of Personal Data.
A.3. Data Retention Period: In order to fulfill the above processing purpose, namely informing you about our products and actions, we consider a reasonable and necessary retention period of your relevant data to be ten (10) years. After ten (10) years from the time of receipt of your consent, the relevant data will be deleted unless consent is provided again by you under the above conditions.
B.1. Purpose – Legitimating Basis:
(a) During the pre-contractual stage and especially in the event of completing an electronic contact form on our website or directly sending an email or telephone communication or completing a printed form, (in which case you provide us with your name and surname/email address and/or telephone number and/or Address and/or capacity and/or our services that interest you), the purpose is to investigate the possibility of a transaction with any of the Companies and the legitimating basis is to serve the legitimate interest of each Company to pursue its commercial purposes by responding to the requested communication to investigate the possibility of a transaction with you (or with the legal entity for which you are acting).
(b) In the event that a transaction is carried out with any of the Companies, your Data that you have provided to us pre-contractually (as well as what you will provide to us in the context of our transaction – including the personal data of legal representatives of legal entities and your addendums) will be processed for the purpose of implementing the contract between us and our compliance with tax legislation. In this case, the legal basis for the processing of your data is the execution of the contract between us as well as our compliance with the legislation (art. 6 par. 1b’ and 1c’ of the Regulation on the Protection of Personal Data. Specifically, with regard to the personal data of your relatives and/or (in the case of a legal entity) legal representatives, the legal basis for the processing of the specific data is the serving of the legitimate interest of the Company to duly fulfill its contractual obligations as above.
It is clarified that the above under (b) data may be transmitted by your contracting Company to the rest of the Companies. In this case, the legal basis for the processing of your data (by the rest of the Companies) is the serving of their legitimate interests (art. 6 par. 1f’ of the Regulation) and in particular the organization and proper functioning of all legal persons who make up the “SAMARAS & ASSOCIATES” Group in order to fulfill their statutory purposes. It goes without saying that in the event of non-transmission of your data, the Data Controller under (b) is only your counterparty from the Companies.
B.2. Data Retention Period:
We will retain the above under B.1.(a) data for ten (10) years and then we will delete them and the above under B.1.(b) data for as long as necessary by tax legislation.
B.3. It is noted that especially with regard to Partners who provide services to the Company and/or have signed a project contract with it, in addition to the data under B.1 above, the Company with which they have signed a contract may also keep records of evaluations of their cooperation. The purpose of processing this specific file is to optimize the company’s cooperation in the context of pursuing its statutory objectives and the legal basis for processing, pursuant to art. 6 par. 1 f of the Regulation, is to serve its legitimate interests, which consist in the aforementioned optimization and evaluation of its cooperation.
C.1. Purpose: To evaluate the likelihood of your recruitment by any of the Companies (to which you sent your CV).
C.2. Legitimating basis for processing: For the data that you have provided us in the context of evaluating the possibility of your recruitment by any of the Companies, the legitimating basis is your consent pursuant to art. 6 par. 1 letter a’ of the Regulation.
C.3. Data Retention Period: In order to fulfill the purpose of processing which concerns the investigation of filling a certain job position, we consider a reasonable and necessary period for retaining your relevant data to be twenty-four (24) months. After the lapse of twenty-four (24) months from the time of receiving your CV, the relevant file with all your data will be deleted.
It is clarified that in the event of non-transmission of your data to the remaining Companies, only the Company to which you submitted your Data is the Controller of your specific Data. You can automatically and at any time be informed about any intra-group transfers by exercising the above-described right to information.
