Technografia Limited (“Technografia”) an entity registered in Cyprus with Registration No. HE 330968, which is engaged in translation and interpretation services.

At Technografia, as an organization, we are committed to carry out all our activities in accordance with all local and/or European Laws and regulations and in full compliance with the European Union General Data Protection Regulation (Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016) (hereinafter referred to as the “GDPR”). As we respect and fully understand the importance of protecting  personal data, at Technografia we strive to keep you informed of:

  • what personal information we collect about you;
  • how we use your personal information;
  • on what basis we use your personal information;
  • how long we keep your personal information for;
  • when, how and why we may share your personal information with others and/or transfer it internationally;
  • how we protect your personal information;
  • your rights regarding your personal information; and
  • what to do if you do not want to provide us with your personal information.

 

For the purposes of this Privacy Policy, the following words are to be read and interpreted in the same manner as they are read in the GDPR:

‘Personal Data’ means any information relating to an identified or identifiable natural person (‘Data Subject’); 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘processing’ means 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 or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

‘Controller’ means 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

‘Third Party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

‘supervisory authority’ means an independent public authority which is established by a Member State;

‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

 ‘international organization’ means an organization and it subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.

1.    Scope of the Privacy Policy

Technografia handles Data Subjects’ Personal Data, in accordance with the eight privacy principles stated in the GDPR in the process of collecting, processing and managing a Data Subject’s personal information and is committed that the data:

  • Shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject (‘lawfulness, fairness and transparency’);
  • Shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes which are in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes that the data was collected for (‘purpose limitation’);
  • Shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);
  • Shall be accurate and, where necessary, kept up to date. Every reasonable step shall be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is collected and/or is being processed, is erased or rectified without delay (‘accuracy’);
  • Shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data is collected and processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
  • Shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).
  • Shall be transferred for processing to a third country or an international organization or Third Party only if the conditions laid down in Technografia’s Privacy Policy are complied with by the controller and the processor (“Transfer”).
  • Maintained by Technografia under their own responsibility and Technografia, as the Controller, shall be responsible for and be able to, demonstrate compliance with the GDPR (“Accountability”).

This Privacy Policy applies both to the use of Technografia’s website (www.technografia.com) and where any personal information is therein shared (whilst being read in conjunction with the Cookie Policy) and to all Personal Data made available to and/or shared and/or collected and/or possessed and/or being processed by Technografia.

By using www.technografia.com and/or submitting any personal information to us, you agree to our use of your personal information in accordance with the provisions of this Privacy Policy and of Technografia’s Cookie Policy.

This Privacy Policy applies only to information obtained by us and not to information obtained and/or shared by you with Third Parties.

2.    Legal Basis for processing your personal data

Technografia gathers and processes your personal data only in accordance to and within the lawful basis provided in the GDPR, as this may apply in any particular circumstance:

Consent

The processing of your personal data is rightful if it is done with your unequivocal and express consent and for the purposes for which your data is collected. Your consent can be taken either in writing or electronically.

For the performance of a contract

Data processing is permitted if it is necessary for the performance of a contract to which you, as a Data Subject, are a party, or for taking steps at your demand, prior to entering into a contract, including, but not limited to, the case of an electronic employment application.

For compliance with legal obligations of Technografia

Personal data can be processed for the purposes of complying with national and/or European and/or international laws and/or Regulations and only to the extent that such processing is necessary and within the restrictions provided in the said Laws or Regulations.

For the protection of vital interests of the Data Subject and/or any affected Third Parties

Personal data may be shared when it is in the interest of the Data Subject that such information is being shared with the authorities or any Third Party.

For the purposes of the legitimate interests pursued

Data processing is justifiable if it is necessary for Technografia to pursue a legitimate interest, provided that it will not override the fundamental rights of the Data Subject.

3.    Information Collection and Use

While using our website, we may ask you to provide us with certain personally identifiable information that can be used to contact you or to identify you. Personal identifiable information may include, but not be limited to, your name, surname, date of birth, address.

In the event that data is stored in any manner, as further provided below, we are assured that all steps necessary were taken by the intermediary data controllers in order for them to fully comply with the provisions of the European and Local legislation relating to the protection of Personal Data.

“Request a Quote” or “Get a Consultation” Forms

Should you wish to contact us using the “Request a Quote” or “Get a Consultation” forms on our website, the data that you supply will be collated into an email and sent to the Central Desk of Technografia in Greece, as further described above, and shall subsequently be distributed and/or forwarded to the appropriate department or individual within the organization. Personal information therein included shall be stored on our local servers for a period of six (6) months, from the date of submission, should no additional steps need to be taken in relation to them, and shall subsequently be deleted, subject to the provisions further stated in the present.  In the event that further steps are taken, or need to be taken, this information and/or personal data shall be stored, retained, processed and shared as further stated herein.

“Careers” – Employment Application Option

In the event that you choose to use our online application for employment feature, we will ask you to provide us with personal data including, but not limited to, your name, address, telephone number.  Further we will ask you to upload a copy of your CV.

This information shall be stored to our website servers and website’s database, which are hosted by and shall then be available to the authorized personnel of the appropriate Department of Technografia, as further described above, responsible for the processing of the information provided. This is usually the Human Resource Department of Technografia, but this may vary.

Your personal data provided to us through our online employment application form will be stored in our website’s database and your CV will be stored in our webserver. Your personal data and your CV will be accessible by authorized personnel through our website’s administration panel.

Our Human Resources Department or the appropriate department of Technografia shall receive a notification for your application by email and shall store all such information locally on our servers which we take all reasonable steps to ensure that are protected via password access and encryption. Our SMTP server communication is protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using a cipher before being sent across the internet.

If hard copies of the provided information are made, such shall be kept in files located in the Human Resources Department with access only from the Department’s  members of, the Management of Technografia or individuals who may be authorized to have access to such information.

Use of such Data

We shall internally process the information shared with us in order to determine your suitability for the position you have applied.  Use of such information will be made in the event that we wish to contact you in relation to your application.

By submitting an application with Technografia, you agree to your information being maintained by Technografia for a period of six (6) months after the completion of the recruitment process for the position you have applied and we may contact you within such period in the event of an opening for the same position.  Should you wish for Technografia to keep your personal information for future openings, you must expressly consent to Technografia maintaining your records and/or personal data for a period of two (2) years. Upon completion of either one of the two periods set out above, Technografia shall delete all personal information shared by you, subject to the provisions further stated herein.

We shall not use, sell or otherwise make available or distribute such information to third parties and/or entities outside of Technografia, unless as further herein provided.

4.    Information collected for minors under the age of 16

In the event that the individual submitting their personal information to Technografia is under the age of 16, Technografia shall require the consent of the parent of legal guardian of the minor.

5.    How we store your information

All Sensitive information and personal data that Technografia obtains, is stored on our local servers/ database and all reasonable steps have been taken by Technografia to ensure that such data is kept secured whilst being stored and/or processed.

Information saved on our local servers is accessible only to the Senior Management of Technografia and/or to the personnel with whom such information has been or needs to be shared. Servers may only be accessed by the use of individually assigned passwords and the contents of our servers are encrypted.

Any hard copy of personal information is maintained in files locally stored by the individual authorised to have access to such information and/or the appropriate manager of Technografia.

Strict checks and controls are in place to ensure that personal data you shared with us is accessed by and shared, only with authorised individuals and is processed only for the purposes that such information has been shared.

All our personnel accessing personal data in any way, is legally bound by our Data Protection Policy (DPP). Failure to comply with the provisions of our DPP will result in various internal sanctions against the employee and may even lead to the termination of their employment.

6.    Website Server

Our website is hosted by Hetzner Online GmbH. Also information shared on our website is shared to a third party IT company, which collates all the information gathered in our website and shares only it with Technografia.

We ensure that all data processors obtaining information shared with Technografia are fully compliant with the GDPR.

7.    Automated Decision Making

Information that you provide us with, shall not be subjected to automatic decision making and/or categorization.  In the event that Technografia does carry out such automated decision making, we shall inform the Data Subject accordingly, including, the manner that such automated decision making is done.

8.    Disclosure of Your Personal Data

Disclosure to entities and/or affiliates and/or third Parties within the EEA

Due to the nature of Technografia’s services and/or business it may be necessary to share such personal data collected and/or shared with us, either within the company, namely another department or with Third Parties and/or affiliates of Technografia, to fulfill the purpose that such data has been collected and is being processed.

In the event that such data is shared with Third Parties and/or affiliates of Technografia, and only to fulfill the purposes for which such data has been collected, Technografia has taken all reasonable steps and assurances, including but not limited to written undertakings and/or contractual undertakings by the other party, to ensure that such third parties have sufficient measures in place to ensure that such personal data is processed and held appropriately pursuant to the provisions of the GDPR and in accordance to this Privacy Policy.

Disclosure to entities and/or affiliates and/or third Parties in non-EEA jurisdictions

It may be necessary in performing the services for which personal data was shared with Technografia, for such personal data to be communicated and/or shared with Third Parties who may be located outside of the EEA, therefore, in locations where the GDPR is not applicable and/or binding on corporations.

In the event that such personal data is so shared by Technografia to affiliates and/or intra-group companies and/or subsidiaries and/or otherwise, to entities directly related to Technografia, despite them been located outside of the EEA, such entities are bound to comply with and to follow the provisions and procedures herein contained. Such transfers and processing outside of the EEA takes place on the basis of an agreement between Technografia and the entity which shall receive and process the personal data and with the purpose of carrying out Technografia’s contractual obligation to the Data Subject.

In the event that such personal data is shared by Technografia with third parties located outside the EEA, such transfer and processing shall be conducted on the basis of a contractual agreement between Technografia and the third party for full compliance with the principles herein contained and with the GDPR.  In the event that there is a conflict between the provisions herein contained and the GDPR and the laws and regulations of the jurisdiction in which the third party is located, then the third party is under an obligation to apply the present with the least possible derogations in order to act in accordance with local laws and regulations.

Such transfers outside of the EEA are performed by the use of, but not limited to, the following services or applications:

  • Email services

Our communication with our SMTP server  is protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using a cipher before being sent across the internet to our mail server. When emails are sent to third parties outside the EEA and personal information is submitted and/or included in this email and/or any attachments, then we encrypt the email itself prior to sending it out.

  • Secure FTP services

In computing, the Secure File Transfer Protocol, or SFTP, is a network protocol that provides file access, file transfer, and file management over any reliable data stream.

SFTP safeguards the file transfer operation as follows:

  • A user’s logon credentials (password, public key, etc.) are verified during user authentication.
  • The server is authenticated through host identity verification, a process that involves host keys.
  • Using SFTP, only one secure connection is established through which all data (authentication information, file data, etc.) is transmitted. SFTP ensures data integrity and data security by applying SSH2 Message Authentication Code (MAC) to hashed data payload packets, which are encrypted in the data stream.
  • Proprietary platforms provided

Each platform used by a third party company have different methods to exchange data with Technografia.

All platforms used by third parties are GDPR compliant and ensure that your data is managed in accordance with EU Data Protection laws. Techografia seeks only GDPR compliant partners and evaluates the use of any Proprietary platform requested and provided by the third party prior to personal data information transferring.

9.    Direct Marketing

Personal Data/ Information shared with Technografia can or may, with your approval, be used for marketing purposes. Such information shall be used to get in touch with you by sending you updates of our services, news and information in relation to Technografia.

In the event that you no longer wish to receive such informational or marketing material from us, you may unsubscribe from such a service by using the link at the end of the email sent to you (by clicking “Unsubscribe”). Alternatively, you can email info@technografia.com requesting that you no longer want to receive emails of such nature. We will take all reasonable steps to delete your email from our mailing lists as soon as possible.

10.    Personal Data Retention

Personal data shared with Technografia, for any of the reasons herein contained shall be retained by Technografia only for as long as it is necessary in order to carry out the purposes for which such data was collected or until the completion of Technografia’s contractual obligations towards the Data Subject and/or otherwise and/or as further provided herein.

If personal data has been provided to Technografia with a consent to process them, we will process such data for the period that such consent is valid.

Technografia has the right to maintain personal data collected and/or shared with them for longer periods for legitimate purposes such as for tax reasons or as it may further be necessary and requested by laws and regulations in the jurisdiction that such data has been collected, is processed and or relates to, unless there is another legal basis for such processing.

Technografia shall retain the personal data for a period equal to that provided for in the statute of limitation.  In the event of litigation and other dispute Technografia shall retain the personal data until the resolution of such dispute or the finalization of the litigation process plus three (3) years.

In the event that Technografia shall keep personal data for a longer period of time as herein provided then such data shall be maintained in a manner so that the Data Subject would be unidentifiable, by means of pseudonymization and/or as otherwise may be deemed appropriate and reasonable.

11.    Data Subject Rights

You have the following rights in relation to personal information we hold about you:

Your right to be informed & to access information

We are transparent in how we collect and process personal information and the purposes that we intent to use it for. We are obliged, should you request us to do so, to provide you a copy of all your personal information we hold and inform you whether such information is in any matter or form being processed. Should you request it, we can provide you with copies of all the information we have in our possession about you.

Your right to correct information

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it corrected.

Your right to “be forgotten”

You can ask us to remove your personal information, in some circumstances such as when we no longer need it.

Your right to restrict information

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as when you contest the accuracy of that personal information or you object to us processing it. It will not however, stop us from storing your personal information. We will inform you before we lift any restriction.

Your right to data portability

As of 25 May 2018, you have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object

You can ask us to stop processing your personal information, and we will do so, unless we can demonstrate compelling legal grounds for the processing.

If you wish to enforce any of the above rights or have questions please send your request, to info@technografia.com.

Dealing with your requests on the basis of exercising the aforementioned rights comes free of charge, provided that your demands are not manifestly unfounded and/or excessive. In the event that your requests are unfounded and/or excessive, Technografia has the right to apply a reasonable fee for the cost incurred.

In the unlikely event that there is a personal data breach, Technografia shall notify the affected Data Subjects and the appropriate Data Protection Authority, of the security breach without undue delay.

In the event of a breach on our part or in the event you are dissatisfied by our handling of your personal data contrary to the provisions of the GDPR, you can submit a complaint about how we process your personal data to the Data Protection Authority or Court.

12.    Points Of Contact

Data Controller

The data controller of this website and generally for all the personal data shared with Technografia is: Technografia Limited, a Private Limited Liability Company with company number HE 330968, whose registered and operating office is at 6 Vassili Kouli Str., Office 203, CY-4155, Kato Polemidia, Limassol, Cyprus.

Data Protection Officer

You may contact Technografia in relation to Personal Data matters via telephone at 0030-210-9355646 or via email at info@technografia.com

Other websites

If, whilst using the Technografia website you are diverted to a third party website, kindly note that this Privacy Policy and Technografia’s Cookie Policy shall not apply and Technografia shall have no liability and/or otherwise deriving from the misuse and/or otherwise of your personal data shared in such third party websites. Other websites will have their own privacy and cookie policies, which we strongly advise that you familiarize yourself with prior to sharing any information.

13.    Miscellaneous

Security

The Security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is or can be 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

In the event of a breach we undertake to report it to the appropriate authorities and notify you as soon as possible and/or as further provided in the GDPR.

Changes to our privacy policy

This Privacy Policy is effective as of 25 May 2018 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this website.

We reserve the right to upgrade or change our Privacy Policy and Cookie Policy at any time and you should check this Privacy Policy and the Cookie Policy periodically.  Your continued use of the website after we post any modifications to the Privacy and Cookie Policy on this page, shall constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy and Cookie Policy.

The provisions of this Document are not exhaustive and Technografia shall at all times ensure full compliance with the GDPR. If any provision is or may in the future be conflicting with the provisions of local and European legislations, such provisions shall be disregarded and the legislation shall prevail.

Technografia Limited

December 2018