The EUROGNOSI Group, with the aim of ensuring the privacy of your personal data, has drafted this Data Protection Policy. By reading it, you will receive all the necessary information about:
Who we are
The personal data we collect
How we process your personal data
The purpose of each processing
The retention period of your personal data
When we request your consent
Recipients of your personal data
Your rights and how you can exercise them
For any other information or clarification, please do not hesitate to contact the Data Protection Officer
GLYFADA CENTER I +30 210 8980222 | [email protected]
The Personal Data Protection Policy applies to all natural persons who interact with the franchisees of EUROGNOSI, such as students, parents, legal guardians, employees, trainers, suppliers, and partners.
With this policy, we commit to comply with all the terms and provisions of the General Data Protection Regulation 679/2016 (GDPR), as well as national and community legislation for the protection of personal data.
Who we are
The EUROGNOSI Group is engaged in providing foreign language and IT training services, developing an extensive franchising system. The franchisor ensures that all franchisees have the appropriate technology and support for information systems to effectively manage their activities. Regarding the processing of personal data, as defined in the General Data Protection Regulation, the franchisor and franchisees jointly act as Data Controllers.
This policy applies to all EUROGNOSI tutoring centers, and you can contact them at any time by obtaining contact information from the following link: https://www.eurognosi.com/
What personal data we collect
Personal data, as defined in the General Data Protection Regulation 2016/679, are "any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person."
At EUROGNOSI tutoring centers, we collect the following personal data:
Student data: name, date of birth, home address, phone number, email, school grade (for minors), profession (for adults), Identity Card number for participation in certification exams, information about any learning difficulties, proficiency level in foreign languages.
Parent data (for minor students): name, home address, contact phone number, email, profession.
Employee data: name, father's name, mother's name, ID card, Tax ID, Tax Office, AMKA (Social Security Number), AMKE (Health Insurance Fund), address, phone number, email, ethnic origin, bank account number, education level, years of work experience, family status, number of children.
Supplier data: Company name, Tax ID, Tax Office, address, phone number, email.
Third-party data: name, phone number, address (information provided as a source of recommendation).
The above data is collected from you upon expressing interest in enrolling or seeking employment at our tutoring centers, either by phone, in person, or through an online application on the EUROGNOSI franchisor's website. We do not retain data that we have not received directly from the individuals themselves.
How we process your personal data
Processing, as defined in the General Data Protection Regulation, includes "any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction."
If you need further information or clarifications, please feel free to ask.
For all processing activities, the Eurognosi Group's tutorial centers, as Data Controllers, ensure legality, objectivity, and transparency. Personal data is collected for specific, explicit, and lawful purposes and is not subjected to further processing. The legal basis for processing is the legitimate interest of the tutorial centers and the execution of the contract for the provision of educational services.
For any new processing purpose, your explicit consent will be requested after providing you with complete information about the terms and conditions of processing.
Within the Eurognosi Group, all tutorial centers adhere to the principle of data minimization. Personal data that we process is appropriate, relevant, and limited to what is necessary for the purposes for which it is processed.
Data accuracy is at the core of the Personal Data Protection Policy. Personal data we process is accurate, and we ensure its timely update. At the same time, we take all reasonable measures for the immediate deletion or correction of inaccurate personal data.
We limit the storage period only to the time required for the purposes of processing personal data. Specifically:
The physical records of applications and re-registration applications are destroyed at the end of the school year.
Foreign language diplomas are retained at the tutorial centers for up to 2 years after your successful participation in the exams, after which they are destroyed.
Progress reports are retained until the start of the new school year and then destroyed.
Documents related to learning difficulties are immediately destroyed after your participation in the examination process, unless you explicitly request their retention until the next exams.
Student records are retained until the end of the following school year and then destroyed.
Please note that there are personal data stored for a longer period of time for archiving purposes in the public interest. This includes tax and insurance information, for which we implement the appropriate organizational and technical measures.
Integrity and Confidentiality
Processing is carried out in a manner that ensures the security of personal data, through integrity and confidentiality. Authorized access, monitoring of access to personal data, proper destruction, and other technical measures are provided for in every case.
When We Request Your Consent
For any processing purpose other than the execution of the contract for the provision of educational services and the fulfillment of the legal obligation of the tutorial centers, your explicit consent is requested after all necessary information has been provided. We may request your consent for:
Sending informational emails about our services after you have expressed interest in them
Sending informational SMS about our services after you have expressed interest in them
Taking photos and videos during holidays and various events of our tutorial centers
Posting photos and videos on our website
Posting photos and videos on social media with clear descriptions
Printing photos in promotional materials
Displaying your name on the list of successful candidates on our website
Displaying your name on the list of successful candidates in promotional materials
Taking videos during the educational process as part of the preparation for the examination
This consent is retained by our tutorial centers in compliance with the requirements of the General Data Protection Regulation (GDPR).
You have the option to withdraw your consent at any time by contacting us. Please note that the withdrawal of your consent does not affect the legality of processing that occurred prior to such withdrawal.
Recipients of Your Personal Data
Your personal data is stored in the information system of the franchisor Eurognosi, in accordance with the legal obligations of the educational institutions. The franchisor has taken all necessary technical measures to ensure a high level of security. Through the implementation of appropriate technical and organizational measures, we ensure the security of data processing, always in accordance with the latest technological developments, to protect your data from any unauthorized access, misuse, alteration, prohibited dissemination, disclosure, loss, or accidental/unlawful destruction, and any other form of unlawful processing. Specifically, encryption is applied, while we also ensure the confidentiality, integrity, availability, and reliability of the processing systems. There is the possibility of restoring availability and access to personal data in a timely manner in case of a natural or technical event. The franchisor adopts a process of assessing and evaluating the effectiveness of technical and organizational measures to ensure all of the above.
Your personal data is shared with language certification authorities for the purpose of executing our contract, following your notification.
Your personal data is also shared with IT knowledge certification authorities for the purpose of executing our contract, following your notification.
In the case of collaboration with third parties and/or the use of related software to serve our purposes, we take all necessary precautions for the secure processing of your personal data.
What Are Your Rights
We respect all your rights arising from the processing of your personal data. Your rights according to the provisions of the General Data Protection Regulation 679/2016/EU are:
Right of Access (Article 15): You can access your personal data at any time to confirm the categories of data we hold, the purpose of processing, the legal basis for processing, any disclosure to third parties, the storage period, or the criteria for determining this period, your rights, the source of your personal data if it was not collected from you.
Right to Rectification (Article 16): You can contact us at any time to correct/update your personal data. We regularly update your details to ensure accuracy.
Right to Erasure (Article 17): You can decide at any time to delete your personal data. We will delete the data we hold if it is no longer necessary for the purposes for which it was collected, there is no other legal basis for processing due to the withdrawal of consent, and if you no longer wish for the processing. Please note that personal data will be retained for the establishment, exercise, or defense of our legal claims and for archiving purposes for public interest or legal obligations imposed by tax and insurance law.
Right to Restriction of Processing (Article 18): You have the right to request the restriction of processing. In this case, the personal data, except for storage, will be processed by us only with your consent.
Right to Withdraw Consent: You have the right to withdraw your consent for cases where the processing of your personal data is based on consent.
Right to Data Portability (Article 20): You can request at any time that we transfer your personal data in a readable format to another data controller, provided that the processing is based on consent or carried out by automated means.
Right to Object (Article 21): You can object at any time to the processing of your personal data, where the legal basis for processing is our legitimate interest or public interest.
Right to Lodge a Complaint with the Supervisory Authority: If we do not respond to your request within the time frame set by the General Data Protection Regulation, you have the right to lodge a complaint with the supervisory authority. In Greece, the supervisory authority is the Hellenic Data Protection Authority (dpa.gr).
When exercising your rights, we will notify any correction or deletion or restriction of processing to each recipient to whom your personal data has been disclosed, if this is possible. At the same time, you will be informed, if you wish, about these recipients (Article 19).
How to Exercise Your Rights
We have provided easy ways to exercise your rights. To restrict processing for commercial purposes or withdraw consent, you can click on the "unsubscribe" link in each email or configure your phone to disable unsolicited messages.
For all your rights, we follow the requirements of the General Data Protection Regulation, as described in Article 12. You can fill out the attached form and send it by email to [email address] or by fax to [fax number] or deliver it to our offices at [address]. You have the option to exercise your rights orally, provided that your identity is proven by other means. For the security of your data, we may request certain information for your identification.
Cost and Response Time
We will process your request promptly and incompletely, and within one month, we will satisfy your request. In exceptional cases, our response time may be extended by two additional months, taking into account the complexity of the request and the number of requests. In this case, we will inform you of the extension and the reasons for the delay within one month from the receipt of the request.
All information is provided free of charge. Obvious unfounded or excessive requests are an exception, especially due to their repetitive nature. In this case, according to Paragraph 5 of Article 12 of the General Data Protection Regulation, we may impose a reasonable fee or refuse to further process the request.
If we do not satisfy your request, we will inform you without delay and no later than one month from the receipt of the request, explaining the reasons for not taking action, the possibility to contact the Data Protection Authority, and the possibility to file a judicial remedy.
The Eurognosi tutoring centers do not adopt automated decision-making methods.
The tutoring centers may have installed a closed-circuit television (CCTV) for the purpose of protecting persons and property from damage and unlawful acts.
The system operates in accordance with the applicable legislation and the guidelines of the Data Protection Authority.
Cameras are not installed in teaching rooms or staff workplaces, only in common areas, storage areas, the cash desk area, and the perimeter areas of the tutoring center, without capturing images from the surrounding public areas.
Informative signs are displayed before entering the monitoring areas.
Monitoring screens are located in a secure area and are only accessible to authorized personnel and the General Director. In the event of cooperation with an external company, the tutoring centers have ensured their commitment to confidentiality and the implementation of all necessary security measures.
The cameras do not record audio.
The retention period of the recorded material is 15 days, after which it is destroyed. In the event of an incident, the relevant material is kept in a separate storage unit, locked, and transferred to the competent law enforcement authorities.
Access to the recorded material, for as long as it is retained, is granted to the individuals depicted and third parties who demonstrate a legitimate interest upon their written request. The request is evaluated by the General Director, who has the right to refuse access if they determine that there is no overriding legitimate interest of the third party or that access by the individual depicted could obstruct the examination of the incident.
Personal data of all categories is retained for as long as necessary for the purpose of processing.
Eurognosi tutoring centers, all employees, and our external collaborators are bound by a duty of confidentiality regarding personal data they become aware of in the course of their duties. They have all the obligations provided for by the General Data Protection Regulation.
Updating of this Policy
We reserve the right to update this policy in case personal data that we process changes or enriches the processing activities taking place or any other change deemed significant for the protection of personal data. The update will be posted on our website, and you will be notified by any means available.
Contact Us for Personal Data Matters
GLYFADA CENTER I 210 8980222 | [email protected]
In case we do not respond to your questions or concerns regarding personal data, you can contact the Independent Data Protection Authority, Kifisias 1-3, Postal Code 11523, 2106475600.