Privacy notice

Privacy Statement regarding the protection of personal data

in the context of e:Presence.gov.gr service

Data controller details:

Α public limited company (societe anonyme) under the corporate name "National Infrastructures for Technology and Research S.A.” and the distinctive title “GRNET S.A."

Competent Processing Service:

e:Presence.gov.gr Support Team

Data controller’s Contact Details:

support@epresence.grnet.gr

Sub-processor:

"Zoom Video Communications Inc", (hereinafter referred to as "Zoom") a foreign, international company providing modern technical solutions for the use of cloud infrastructure for the purpose of holding teleconferences.

More detailed information on the provision of “Zoom” services, the Terms of Use and the Privacy Policy thereof, is available on https://zoom.us/trust.

In the context of the service, "Zoom" may also provide, as sub-processor, functionalities relating to the dynamic allocation of licences to named "coordinator" accounts, the holding of teleconferences and webinars, optional recording in its cloud, transcription, the automatic generation or translation of captions and phone participation, provided that such functionalities have been enabled for the service and are used by the "coordinator" or the participants.

Subcontractor / Sub-processor:

The consortium "DELOITTE-VODAFONE" - the "Subcontractor". The Information System of the service is hosted on infrastructure of Amazon (AWS), by virtue of Agreement no. 16950/21.11.2024 between GRNET SA and the consortium "DELOITTE-VODAFONE", as it stands together with its Annexes.

"EPAFOS" - the "Contractor", which provides support, development and maintenance services for the Information System of the e:Presence service, by virtue of by virtue of Agreement no. 11658/01.07.2026 with GRNET SA.

Scope of this Privacy Statement:

National Infrastructures for Technology and Research S.A. (hereinafter referred to as “GRNET SA") is bound by European Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation – hereinafter referred to as “the GDPR”) and Law 4624/2019 (Official Journal issue 137/A/2019) on "Data Protection Authority, measures for the implementation of Regulation(EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and for the incorporation into national law of Directive(EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 and other provisions”, as in force at any time (hereinafter “the Law”). This Privacy Statement details all information necessary for the processing of personal data carried out in the context of e:Presence.gov.gr service, as well as the policies and procedures implemented by GRNET SA for the protection of the e:Presence.gov.gr users privacy. This Privacy Statement sets out the criteria as well as the terms and conditions under which GRNET SA collects, processes, uses, stores and transmits the personal data of the service users, how it ensures the confidentiality of such information, including any law and/or regulation implemented or enacted in accordance with Union and national laws on personal data protection and electronic privacy, as well as any law and/or regulation amending, replacing, issuing or consolidating any of the latter, including any other applicable Union and national laws on the processing of personal data and privacy, which may exist in accordance with applicable law.

GRNET SA reserves the right to amend and update this Privacy Statement whenever necessary, whereas any such updates shall become effective five (5) days after they have been posted on the e:Presence.gov.gr website and relevant notification email has been sent to all active "users" of the service.

For the purposes of this Privacy Statement, the terms “controller”, “processor”, “third party”, “supervising authority”, “personal data”, “processing”, “data subject” shall have the meaning ascribed to them by applicable legislation on the protection of personal data.

In addition, for the purposes of the present, the following definitions shall also apply:

"Website" – the website accessible via domain name https://www.epresence.gov.gr, ,including the entirety of the web pages thereof.

"e:Presence.gov.gr Service" - the e:Presence.gov.gr service addressed to the Organizations of the Greek State allows its members to organize and conduct online teleconferences of high quality and interactivity.

“Organization" - the organization of the public and wider public sector, whose members use the e:Presence.gov.gr service to organize and conduct online teleconferences.

“User” - the online e:Presence.gov.gr service user, whom the data refer to, whose identity is known or may be verified, namely it may be directly or indirectly determined. In e:Presence.gov.gr service, two distinct user categories are supported, as such are differentiated by the user rights assigned to each subcategory. The first user subcategory is that of "ordinary users" whereas the second is that of "coordinators".

"Guest User" - "Guest" - the online user of the e:Presence.gov.gr service, who is invited through their email address to participate in one or more teleconferences of the service, without being authenticated through the Authentication Service OAuth2.0 users of the GSIS , without the prior creation of a respective user account in the service, and applicable only for a specific teleconference. For a "Guest", no user account is maintained in the service.

"Coordinator" - is the special user category which is also responsible for supervising and managing all teleconferences carried out on behalf of an organization or an organizational unit of the organization, where the coordinator pertains to, as well as for inviting participants to join a teleconference. Two distinct subcategories of "coordinators" are supported in the context of the e:Presence.gov.gr service. The first subcategory of “coordinators” is that of the “organization coordinators” whereas the second is that of the “organizational unit coordinators”.

“Organization Coordinator” - The status of an “organization coordinator” is assigned to an e:Presence.gov.gr service user upon approval of the user’s relevant request to change role, submitted to the “e:Presence.gov.gr Support Team, on condition that said “user” is registered with the Human Resources Register of the Greek State and has adequately justified the valid and lawful nature of such request.

”Organizational unit coordinator” - The status of the “organizational unit coordinator” is attributed to an e:Presence.gov.gr service user either by the “organization coordinator”, or subject to the approval of the user’s relevant request for a change of role, submitted to the “e:Presence.gov.gr” Support Team, on the said condition that the user ” is registered with the Human Resources Register of the Greek State and has adequately justified the valid and lawful nature of such request. The organizational unit coordinator shall have the said powers only for the teleconferences of the organizational unit, for which they have been appointed as coordinator.

"Ordinary user" - is a person who can participate in a teleconference, upon receiving an invitation sent to them, without being able to host a teleconference by engaging resources of the system‘s available services at a specific time. Moreover, any stakeholder may be registered as a "ordinary user" even if they may not have been invited to join a teleconference by a "coordinator", provided that such "user" is registered with the Human Resources Register of the Greek State.

In the context of this Privacy Statement, the term "user" is used to describe both "ordinary users" and "coordinators" (it is noted that the term “user” does not include guest user – guest) and respectively, the term "coordinator" is inclusive of both "organization coordinators" and "organizational unit coordinators".

A. Purpose/s for processing the data collected:

i. GRNET SA – as data controller – processes the personal data of the “users" as referred to in the following section, for the following purposes:

• i. Authentication of “e:Presence.gov.gr” service users
  • “Users” authentication is effected through the “user”’s TaxisNet credentials by using the User Authentication Service oAuth2.0 available through the interoperability center of the General Secretariat of Information Systems of the Greek State (GSIS)
• ii. Confirmation of the status of the e:Presence.gov.gr service “usesr” as members of the human resources of the Greek State
  • Following the identification of the "user" through the user authentication (oAuth 2.0) of GSIS, by entering the VAT number of the "user", information on whether such user actually belongs to the relevant "Register" as well as details of the Organizations, where the user has been inventoried with, may be sourced from the Register of Human Resources of the Greek State (http://apografi.gov.gr/) (hereinafter "Register"). In case of more than one "Organizations", where the user has been registered with, the "user" selects the Organization" that they wish to appear in their account.
• iii. Provision of the e:Presence.gov.gr service
  • Uninterrupted operation of the "website" and the e:Presence.gov.gr service.
  • Technical support to "coordinators" of the e:Presence.gov.gr service
  • Easy and user friendly operation of the "website".
  • Enhancement of the online experience when providing the e:Presence.gov.gr services
  • Seamless provision of the e:Presence.gov.gr service to Organizations
  • In addition, in the context of the new licensing functionality, GRNET SA processes the necessary "coordinator" and teleconference data for the dynamic allocation of named user licences, the application of scheduling and time-overlap rules for teleconferences and for ensuring that scheduled teleconferences can reliably start at their scheduled time.
• iv. Recording of a teleconference held in the e:Presence.gov.gr service (optional right for "enhanced management" host key offered to “coordinators”). The functionalities of the service also include optional recording in the cloud, transcription and the automatic generation or translation of captions
  • The option to record video and audio streaming of a teleconference, locally on a storage medium of the personal device whereby the "coordinator” connects to the teleconference (personal computer) and/or in the cloud of zoom and/or of GRNET S.A., is offered to the latter.
  • Provision of the option to have the chats taking place during a teleconference recorded in the cloud in text form.
  • Utilization of Artificial Intelligence (AI) tools: transcription/automatic generation or translation of captions.
• v. Communication with the "coordinators" of the e:Presence.gov.gr service
  • Solving any teleconference management problems of the "coordinators" of the service
  • Sending notifications to the service "coordinators" via email massages only in case of major changes in the service operation requiring “users” to perform specific actions in order to continue seamless use of the service. Indicative examples may include the need to install new software in order to access teleconferences due to an urgent security software update or, for example, the unavailability of the service due to an upgrade etc.
• vi. Creation of statistical reports and charts to monitor the e:Presence.gov.gr service
  • Data used in such statistical reports and charts do not contain any “users” personal data, as they result from anonymized information.
• vii. Real time live streaming of a teleconference to a wider audience
  • The video and audio streaming of a teleconference is decrypted and made available in the DIAVLOS service of GRNET SA, which undertakes further distribution of it to the public, through a special website created for each live teleconference streaming event.
• viii. Conducting polls during a teleconference
  • The "coordinator" who organizes a teleconference can create one or more polls to a teleconference, each containing one or more questions. The questions of these polls can be displayed to the participants of a teleconference, if the "coordinator" of this teleconference chooses to enable them. The participants may, at their sole discretion, select an answer for each question. The results of these polls are made available to the "coordinator" of the teleconference, immediately after their completion.
• ix. Option for phone participation of the "user" over a PSTN line
  • A "user" who is unable to connect over the internet may participate in a teleconference by calling, from a landline or a mobile phone, an access number of the service and entering the teleconference identifier. In such case participation is by audio only.
• x. Option to organize webinars
  • The "coordinator" may, provided that the relevant functionality is offered through the service, organize a teleconference in webinar form, in which the speakers present to a wider audience, whereas the participants have by default no option to transmit video and audio and interact through questions or comments.

GRNET SA collects and processes “users” and “guests” personal data in the context of providing the e:Presence.gov.gr service solely for the aforementioned purposes and only to the extent strictly necessary to effectively serve such purposes. Such data shall be, at all times, relevant, appropriate and not more than those required in view of the aforementioned purposes. They shall also be accurate and, if necessary, updated.

Furthermore, the aforementioned data shall be retained only during the period required as mentioned hereinabove, in order to accomplish the purposes for which they are collected and processed, and shall be deleted at the end thereof (see below “Retention period of personal data”).

ii. "Zoom"– as data processor – collects and processes “users” and “guests” personal data using its infrastructure for the purpose of holding teleconferences.

iii. "EPAFOS" - as data processor - collects and processes “users" and "guests” personal data for the purpose of providing technical support to the e: Presence.gov.gr service.

Β. Categories of personal data processed:

i. To authenticate e:Presence.gov.gr service “users”

The authentication of the e:Presence.gov.gr service "users" is effected through the Interoperability Centre of the General Secretariat of Information Systems of the Greek State (GSIS ) by using the user’s TaxisNet credentials as set out in Decision No 3981ΕΞ2020 of the Minister of State «Provision of User’s Authentication oAuth2.0 Service in Information Systems of third Party Organizations” (OJ Β’ 762). For the sole purpose of authenticating the e:Presence.gov.gr service "users", GRNET SA collects through the aforementioned authentication procedure (o Auth 2.0), and processes – as data controller- the following personal data:

• Name
• Surname
• TaxisNet username
• Father’s name
• Mother’s name
• Date of birth
• VAT number

ii. To confirm the identity of the e: Presence.gov.gr service "users" as members of the Human Resources Register of the Greek State

Following identification of “users” through the GSIS authentication (oAuth 2.0), data relevant to the “users” registration with the Human Resources Register of the Greek State (http://apografi.gov.gr/) [hereinafter the "Register"] and details of the “Organizations”, such “users” have been inventoried with, are sourced by entering the “users” VAT number. In case of “users” having been registered with more than one "Organizations”, the former needs to select the "Organization" that they wish to appear in their account.

With the sole purpose of confirming the status of the e: Presence.gov.gr service “users” as members of the Human Resources Register of the Greek state, as well as of the Organization such “users” pertain to, GRNET SA collects through the aforementioned service, and processes - as data controller - the following personal data:

• Organization (id) - one or more
• Name of Organization
• Primary status (true / false) for each Organization

iii. To provide the e:Presence.gov.gr service

For the use (when logging in, creating an account, participating in teleconferences – trial/official) of the e:Presence.gov.gr service as well as for the efficient and lawful provision of such service, GRNET SA processes – as controller – the following personal data:

• The IP address wherefrom a “user“ logins to the e:Presence.gov.gr service and the teleconferences
• In-site navigation data via cookies installation (see relevant Cookie policy)
• Service use timestamp
• Connecting device details (device type, manufacturer, model, operating system)
• “Coordinators” e-mail address
• “Coordinators” telephone number
• “Coordinators” organization
• “Coordinators” full name

iv. For the optional recording, transcription and automatic generation or translation of captions of a teleconference

In odrer to grant” coordinators” with the right of "enhanced management" (Host Key) to record video and audio streamings of a teleconference, locally in storage medium of the device whereby the "coordinator" connects to such teleconference (personal computer), GRNET SA processes, - as controller- the following:

• unique activation code for the "enhanced management" of a teleconference

A "coordinator" with such “enhanced management” (host Key) right, receives from GRNET SA pertinent unique activation code for the "enhanced management" of a teleconference and bears together with their “Organization”, the exclusive responsibility for the proper and lawful use of such service option. It is noted that “the coordinator” may, at their own risk, further assign such “enhanced management” right to any participant in a teleconference. In any event, should a teleconference be recorded or live streamed by virtue of the "enhanced management" right, the full responsibility for the lawfulness, the storage as well as for the eventual further disposal of the outcome of such recording shall lie solely with the "coordinator" of the teleconference as well as with the" Organization " holding the teleconference.

With regards to the possibility of recording a teleconference, to the audio and/or video data originating therefrom, and in general with regards to all data processed by the "Organization" for its own purposes while making use of the e:Presence.gov.gr service, the "Organization as Controller is solely responsible for the collection, processing, the legal basis and the purpose of the processing, for informing the data subjects, and for satisfying the rights of the latter, for carrying out a Data Protection Impact Assessment (DPIA), for being accountable vis-a-vis the Data Protection Authority (DPA) and the data subjects, in accordance with the provisions of the currently applicable law on personal data protection.

Moreover, where a teleconference is recorded using technological means available to the "user", in such case, the full responsibility for such recording and eventual disposal of such recording shall lie with the ”user” and the “Organization” where the “user“ belongs to.

Should a “guest” invited in a teleconference, proceed to such a recording, the responsibility for the recording and the disposal of the content, shall lie with the “guest” and the “coordinator” who invited them in the specific teleconference .

For the provision of the optional capabilities of recording locally on a storage medium of the device whereby the "coordinator" connects to the teleconference (personal computer) and/or in the cloud of zoom and/or of GRNET S.A., of transcription (using AI tools) and of the automatic generation or translation of captions (using AI tools), GRNET SA and "Zoom", in their respective roles as described herein, may process video, audio and shared content data, generated recording files, transcription files, caption data and chat recordings in text form, only if the relevant functionalities are enabled and used by the "coordinator" or the "Organization".

The "coordinator" and the "Organization" bear the exclusive responsibility for the lawful use of such functionalities, for informing the participants, for the legal basis, the retention period, the access to and any further disposal of the product thereof, in accordance with the applicable legislation on personal data protection.

v. To communicate with the e:Presence.gov.gr service “coordinators”

For communicating with e:Presence.gov.gr service “coordinators”, GRNET SA processes - as data controller - the following personal data:

• “Users” and “Guests” e-mail address
• “Coordinators” e-mail address
• “Coordinators” telephone number

vi. For the creation of statistical reports to monitor the e:Presence.gov.gr service

Statistical reports do not include any personal data, as they result from anonymized information.

vii. To provide teleconferences streaming services to wider audience

For the provision of teleconferences streaming services, "Zoom"- as sub-processor- on behalf of GRNET SA and GRNET SA - as data processor on behalf of any “Organization” - process the following personal data:

• Live streaming of video, audio and shared data of a teleconference

viii. For the utilization of polls during a teleconference

For the utilization of polls during a teleconference "zoom"- as sub-processor -on behalf of GRNET SA and GRNET SA - as processor on behalf of any “organization” - process the following personal data:

• Personalised answer selections to each question of a poll, for every participant who opts to answer that question. The "coordinator" may select to create the poll with the "Anonymous answers" option, in which case the "coordinator" will not have the information of personal answer choices for any participant. The selection of the "Anonymous answers" option is at the sole discretion of the "Coordinator", based on the particular needs that each poll involves.

ix. For the phone participation of the "user" over a PSTN line

For the participation of a "user" in a teleconference over the phone, "zoom" - as sub-processor on behalf of GRNET SA - and GRNET SA - as processor on behalf of any “Organization” - process the following personal data:

• The telephone number, landline or mobile, wherefrom the "user" calls in order to participate in the teleconference, as well as related technical call data (start and end time, duration)

x. For the organization of webinars

For the organization of a webinar during a teleconference, "zoom" - as sub-processor on behalf of GRNET SA - and GRNET SA - as processor on behalf of any “Organization” - process the following personal data:

• Full name and e-mail address of the participants, where registration is required in order to participate in the webinar
• Questions and comments submitted by the participants during the webinar

Horizontally, for providing teleconference services

For the horizontal provision of teleconference services, "Zoom"- as sub-processor- collects and processes the following personal data on behalf of GRNET SA:

• “Users” and “Coordinators” full name as it results from data maintained with GSIS.
• “Guest”s full name, as declared by the “Guest” themselves when entering the teleconference where they have been invited to.
• E-mail address and account identifiers, to the extent necessary for the creation or matching of named "coordinator" accounts and licences.
• The IP address wherefrom the “user” or the “Guest” connects to the e:Presence.gov.gr service and to the teleconferences.
• Teleconference metadata, such as start and end time, participant role, participation details and technical connection details.
• Video, audio and shared content data, recording files, transcriptions, caption data and chat recordings in text form, only if the relevant optional functionalities are enabled and used.
• Telephone number or related call data, where the “user” opts to participate over the phone (PSTN dial-in).

It is noted that the aforementioned data are stored on the infrastructure of "zoom" within the European Union.

xi. To provide technical support services to GRNET SA

For the provision of technical support services to GRNET SA, "EPAFOS" - as data processor - collects and processes all personal data mentioned in items (i) to (x) hereinabove, as well as in the "Horizontally, for providing teleconference services" section.

xii. Special categories of personal data

GRNET SA does not intend to collect, process, or gain access in any way to specific categories of data as set out in the provisions of applicable law (in particular data relating to racial or ethnic origin, religion, health data, etc.). In the event that any "user" posts data of a specific category on the "website" or the e: Presence.gov.gr service, such data shall be removed as soon as they come to the knowledge of the e: Presence.gov.gr management team.

C. Legal bases for processing

The processing of “users” personal data is necessary for the performance of the Agreement on the provision of the e:Presence.gov.gr teleconferencing services, in line with the need (technical and organizational) to provide the best possible services, to serve its "users" and its legal basis can be found along the provisions of Decision No 3981ΕΞ2020 of the Minister of State «Provision of User’s Authentication oAuth2.0 Service in the Information Systems of third Party Organizations” (OJ Β’ 762/10.03.2020) and joint Ministerial Decision No 429/2020-OJ 850/b/13.03.2020, as it stands amended.

D. Access to personal data:

For the provision of e:Presence.gov.gr services and the seamless operation of such service, access to the “users” and “guests” personal data shall be granted to the following:

• To the e:Presence.gov.grservice support team, consisting of personnel engaged in a contractual relationship by virtue of either a project or a services agreement with GRNET SA hereinafter referred to as "GRNET associates”, bound by a confidentiality agreement (NDA) with GRNET SA.
• To "Zoom" personnel with regard to teleconferencing services, as specified in the "Horizontally, for providing teleconference services" subsection of section (B) hereinabove.
• To "EPAFOS" personnel with regard to technical support services, as specified in item (xi) of section (B) hereinabove
• To e:Presence.gov.gr service "coordinators" for the sole purpose of organizing teleconferences and notifying "ordinary users" of the service in view of their participation in a teleconference under way of organization.

The processing of e:Presence.gov.gr service “users” and “guests” personal data by the aforementioned, is carried out under the supervision and solely at the request of GRNET SA, within the scope of the mission and the role of each associate. Such associates undertake, finally, to comply with the same requirements regarding privacy and personal data as GRNET SA itself, in accordance to the present Privacy Statement.

Access to the product of any optional recording, transcription, automatic generation or translation of captions, as well as to any related file or metadata, is limited to the authorized persons and to the roles provided for by the settings of the service and of each "Organization". The "coordinator" and the "Organization" enabling or using the relevant functionalities bear the responsibility for the lawful access to, storage, retention and further disposal of the product thereof. GRNET SA does not use the content of teleconferences, recordings or transcriptions for purposes other than the provision, support and security of the service, in accordance with the applicable roles and processing instructions.

E. Recipients of the collected personal data:

GRNET SA shall in no way transmit/transfer or in any way disclose the e:Presence.gov.gr service “users” and “guests” personal data to any third-party entities, private businesses, natural persons or legal entities, public authorities, agencies or organizations, other than as expressly set out herein.

The personal data of the e:Presence.gov.gr service “users and “guests” may be disclosed or transmitted to government authorities and/or law enforcement officials, only if necessary for the abovementioned purposes, in the context of enforcing a court decision, criminal prosecution or a provision of the law or if necessary to secure the legitimate interests of GRNET SA in its capacity as data controller, in compliance with the terms and conditions of applicable law.

The personal data of the e:Presence.gov.gr service "coordinators" are communicated to "ordinary users" of the service via a notification e-mail, they receive with regard to their participation in a teleconference under way of organization, for the sole purpose of establishing communication between "coordinators" and "ordinary users" or “guests” with regard to a teleconference under way of organization or already organized.

Should any “coordinator” make use of the "enhanced management" right to real time live stream a teleconference to a wider audience, the video, audio and shared data live streaming of a teleconference shall become available to a wider audience. The same applies in the event a webinar is organized, where the video, audio and shared content of the speakers become available to the audience of the webinar. During such live streaming of a teleconference or the holding of a webinar, the responsibility for keeping the participants informed on such fact, lies exclusively with the "coordinator" of the specific teleconference.

F. Rights of data subject

As regards the data processed in the context of providing the e:Presence.gov.gr service, GRNET as data controller – takes all necessary action, in accordance with the terms of this Privacy Statement, both during the collection as well as in every subsequent stage of processing of the personal data of the e:Presence.gov.gr service “users” and “guests”, so that every "user" and “guest” may fully exercise their rights, as laid out in applicable legislation on the protection of personal data, namely the rights of Access, Rectification, Erasure, Restriction of Processing, data Portability, as detailed hereinbelow and in accordance with the terms and conditions of applicable law:

• Right of Access: The data subject is entitled to request and obtain from GRNET SA, a confirmation on whether or not their personal data are processed and, if so, to exercise the right to access such personal data pursuant to applicable legislation. The data subject may also request a copy of the personal data undergoing processing, as described in this Privacy Statement, by sending an email to the following email address: support@epresence.grnet.gr. Finally, it should be noted that the right to obtain a copy of the personal data undergoing processing shall not adversely affect the rights and freedoms of others in accordance with applicable law.
• Right of Rectification:The data subject shall have the right to request GRNET SA to rectify any inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall have the right to request that any incomplete personal data be completed, including by means of providing a supplementary statement, in accordance with applicable legislation.
• Right of Erasure:The data subject has the right to request GRNET to erase their personal data within the framework of e:Presence.gov.gr service, in accordance with the provisions of applicable law and under the following specific terms and conditions:
  • If the data subject has received an account activation message in the e:Presence.gov.gr service but does not wish to activate the account and does not take any further action after receiving such message, such inactivated account shall be automatically erased after four (4) months.
  • If the "user" has activated their account in the e:Presence.gov.gr service but has never participated in any teleconference, they may, under own responsibility automatically erase the account using a special button that exists for this purpose on their account management page. In such case, all personal data relating to said “user” shall be permanently erased from the web server and may not be recovered.
  • If the "user" has activated their account with the e:Presence.gov.gr service and has participated in one or more teleconferences, full erasure of the account shall not be possible for reasons of coherence of the service usage data. In such case, “the user” may, under own risk, activate the anonymization of their data, using a special button that exists for this purpose on their account management page. In this way, their account becomes inactive, their personal data are replaced with pseudo-data (e.g. full name Deleted, email address in the form of deletedXXXXXX@example.com), any eventual password is replaced by a random, non-recoverable password, and the "user" ceases to have access to the service.

In case of a request by a “user” to erase of their personal data, the “user” shall be referred to their account management page, as mentioned hereinabove.

In case of a request by a “guest” to erase their personal data, the “guest” shall have to fill out the Request Form for the Exercise of a Right and forward it to the appropriate email address, as mentioned hereinbelow.

• Right to restriction of processing: The data subject is entitled to ensure that GRNET SA restricts the processing of their data, if any of the conditions laid down by applicable legislation on the protection of personal data, is met..
• Right to data portability: The data subject has the right to obtain any personal data concerning them, which they have submitted to GRNET SA in a structured, commonly used and machine-readable format, as well as the right to transmit such data to another controller without any objection from the controller to which the personal data have been submitted, in accordance with the provisions of the applicable legislation on personal data.

To exercise any of the above rights, the “user” or “the guest” may contact the e:Presence.gov.gr Support Team at the following email address: support@epresence.grnet.gr by filling out the following Request Form to Exercise a Right..

The aforementioned rights of the data subjects are subject to restrictions in accordance with applicable legislation.

GRNET SA– acting in its capacity as data controller – shall provide the data subject with information about any action taken following their request to exercise any of the above rights within one (1) month as of receipt of the request. This period may be extended by an additional period of two (2) months, in accordance with the terms of applicable law.

GRNET SA, when processing personal data in the capacity of a data processor on behalf of an Organization, shall immediately forward any request filed by a data subject with GRNET SA concerning the processing carried out by the Organization in the context of providing e:Presence.gov.gr service, and shall assist the Organization to fulfill its obligation to respond to such request. GRNET SA shall not be responsible to respond to the data subject’s request in such cases.

G. Personal data retention periods

The e:Presence.gov.gr service users personal data shall be retained no longer than it is necessary for the needs of the service and the audits the service is subjected to. More specifically:

H. Privacy and Data Security:

The processing of personal data by GRNET SA is performed in a manner that ensures both confidentiality and security thereof. All appropriate organizational and technical measures are taken to safeguard and protect data against any accidental or unlawful destruction, accidental loss, alteration, prohibited dissemination or access or any other form of unfair processing. More specifically:

• The communications of the e:Presence.gov.gr service are protected by the available technical security measures of the teleconferencing platform, including encryption in transit, in accordance with the settings and functionalities available in the service at any given time.
• The use of functionalities such as phone participation (PSTN dial-in), cloud recording, transcription, automatic generation or translation of captions and streaming may require the partial reversal of the aforementioned encryption of video and audio streams as well as the technical processing of video, audio, shared content streams or related metadata by the Zoom platform or its sub-processors, in accordance with the applicable contractual and technical settings of the service.
• The implementation of the application ensures that access to a teleconference is granted only to authorized users or invitees, in accordance with the authentication, invitation and access control mechanisms of the service. By way of exception, the invitation to a teleconference sent to a "Guest", is activated by the "Coordinator" of the teleconference who, by doing so, assumes the responsibility for the participation of non-authenticated via the GSIS users in the specific teleconference of the service, as described in detail in the Terms of Use of the service.
• The use of optional functionalities entailing recording, storage, transcription, translation of captions or streaming to a wider audience is made under the responsibility of the "coordinator" and the "Organization", which must ensure the required information notice and the lawfulness of the processing.

Additional information on the methods used for safeguarding communications is available in the "Detailed information on communication and compliance with the institutional framework" document posted on the e:Presence.gov.gr service home page https://www.epresence.gov.gr/service_security.pdf".

The e:Presence.gov.gr web application is hosted on computing infrastructure provided by Amazon (AWS) which provides high availability and fault tolerance, according to the contract between GRNET S.A. and the consortium "DELOITTE-VODAFONE" as it currently stands (Contract no. 16950/21.11.2024). 

I. Processing of personal data by the Organization

Every Organization using the e:Presence.gov.gr service, shall act as a controller with regard to all personal data processed for its own purposes during the use of the e:Presence.gov.gr service for the purpose of the preparation/setting up and holding of the teleconference, as well as with regard to any audio and/or image data generated should the available option to record a teleconference be used on a local system and/or in the cloud of zoom and/or of GRNET S.A., with regard to transcription data (using AI tools) and to the automatic generation or translation of captions (using AI tools), with regard to the answers and the results of polls, with regard to the holding of a webinar during a teleconference, as well as with regard to the option to live stream a teleconference, and shall be responsible for the collection, the processing and the legal basis thereof, the purpose, for notifying the data subjects and for satisfying their rights as well as for carrying out a Data Protection Impact Assessment (DPIA). It shall also be accountable towards the Data Protection Authority (DPA) and the data subjects, in accordance with applicable law on data protection.

When holding a teleconference, GRNET SA acts as the processor on behalf of each Organization, in compliance with the provisions of law on personal data, and shall not be responsible for the lawfulness of the collection, the processing and the legal basis thereof, the purpose, nor for notifying the data subjects and for satisfying the rights thereof.

J. Contact

For any question or clarification regarding this Privacy Statement and as well as in the event of any violation related to personal data issues, "users" and “guests” may contact the Competent Department of GRNET SA at the e-mail address mentioned hereinabove.

They may also contact the Data Protection Officer (DPO) of GRNET S.A. at the e-mail address:dpo@grnet.gr.

K. Recourse/Complaint

In the event that a request by any e:Presence.gov.gr “user” or “guest” is not satisfied by the controller the "user" and /or the “guest” may at any time file recourse with the Competent Supervisory Authority, namely the Data Protection Authority https://www.dpa.gr.