Data Protection Policy

1. Information regarding the collection of personal data

(1) This document describes how personal data is collected when you use the CIRCLE app. Personal data are all data that can be linked to you personally, such as your name, address, email addresses, or your user behaviour.
(2) The data controller under data protection law is Threenitas S.A. Software Systems (hereinafter “Threenitas”), Ilia Iliou 75, 11744 Athens, Greece.
(3) The contact information concerning data protection officer at Threenitas is as follows: [email protected].

2. Purpose of data collection

We use the personal data you provide in this context exclusively in order to supply information on matters relating to CIRCLE, to communicate with you with regard to CIRCLE, and to process travel management for the annual CIRCLE Meeting. The basis for data processing is your (implicit) consent to data processing or the legitimate interests of Threenitas that take precedence your interests with regard to data processing. This is in particular the case if data processing relates to travel management or the introduction of new CIRCLE members.

3. Which personal data are processed?

We process the personal data that you provide us with. This includes your surname, first name, photos, date of birth, information from your curriculum vitae, postal address, email address, phone number, and surname and first name of your partner.

4. Who processes the data?

(1) The data that you provide to us shall be processed exclusively by those bodies of Threenitas which are responsible for CIRCLE.
(2) In addition, all CIRCLE members can view the personal data of the other CIRCLE members.
(3) Personal data are only disclosed to third parties for specific purposes within the scope of order processing, in accordance with data protection regulations, to bodies which e.g. operate our servers or provide specific services. These bodies are located in the EU Member States and Switzerland, and are required by contractual obligations and data protection instructions to handle personal data in compliance with statutory requirements.

5. Duration of storage

(1) We retain your personal data for as long as is necessary for the purposes for which it has been collected in accordance with this Data Protection Policy.
(2) However, it may be that we are legally required to store certain data over specific periods of time. In this case, we ensure that your personal data are treated confidentially beyond the entire timeframe in accordance with this Data Protection Policy.

6. Your rights

(1) You have the right to request from us – at any time and free of charge – access to/information regarding the personal data we have stored concerning you, as well as its origin, the recipients or categories of recipients to whom these personal data are transferred, and the purpose of storage.

(2) In addition, you have the right at any time to request that we rectify, erase or restrict the processing of your personal data. You also have the right to data portability. Furthermore, you have the right to lodge a complaint at any time with the competent supervisory authority.

(3) You also have the right to object to our processing of your personal data at any time.

(4) If you have provided us with your consent to use personal data, you may withdraw this consent at any time without stating grounds.

(5) If you would like to assert the rights stated above, please send an email to [email protected] or write to the address stated under Section 1.2.

(6) When you use the contact form or send us a separate email to our contact address, and enter your (contact) details, these data, including personal data, are forwarded to us and stored. We will not disclose these data without your consent, and instead will use these data for the sole purpose of processing your request. You may object to this use of data after sending the completed contact form, feedback or an email at any time without stating grounds, and withdraw your consent to the use of these data.

7. Data security

To protect our data, we implement data security measures which comply with the current statutory regulations on data protection and the available technology (e.g. firewalls, virus scanners, and intrusion detection software).

8. Amendments to the Data Protection Policy

If we decide to amend the content of this Data Protection Policy, we will publish these changes on our website. If we amend this Data Protection Policy, we will always provide easily-accessible links to previous versions.

9. Questions on data protection

Please direct any further questions relating to data protection to [email protected].

December 2018