Special Terms of Use

Last updated: 6 April 2023

1. Introduction.

This Privacy Policy describes the practice of the company under the name “ORIENTUM CAREER COUNSELLING COMPANY LTD” and the distinctive title “ORIENTUM”, with registered offices at 2 Papada Street, Athens, Greece, Tel. +30 210-6778777 & Fax +30 210-6774444, Tax Identification No (TIN) 998405767, Tax Office of Psychiko, with General Electronic Commercial Registry (GEMI) No 008208201000, (hereinafter “We”, “we”, “us”, “our”, or the “Company”) in relation to the collection, use, storage and processing of Personal Data (as defined below) provided to Us by: a) the users (hereinafter the “User” or the “Users”) of the platform https://orientum.assessment.gr/el/static/Home (hereinafter the “Assessment Platform”) and/or b) the Users of the platform https://www.edu4schools.gr/Account/Login (hereinafter the “Edu4schools Platform”) and/or c) the Users who make use of the vocational orientation and career counselling services offered by the Company (e.g. through individual interviews) (hereinafter jointly referred to as the “Services”) and/or d) in the case of minors (under the age of 15 years old), the holder of parental responsibility of the aforesaid Users who wish to make use of the Services. Detailed information on the characteristics of the Company's psychometric tests is available at https://www.assessment.gr/en/normal/home.

We are aware of the importance of protecting your personal information; we respect and support individual rights to privacy and the protection of Personal Data (as defined below). In this context, we have developed this Policy in order for you to understand how we collect, use and disclose your Personal Data and information in the context of an expression of interest in the Services provided or in the course of providing the Services.

2. Applicable Law.

The applicable law on personal data protection (hereinafter the “Applicable Law on Personal Data Protection”) consists of the applicable national and Community legislation on the collection, use and processing of your Personal Data by us, including Law 4624/2019 and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter the “Regulation”).

3. Definition of Personal Data.

For the purposes of this Privacy Policy, “Personal Data” means information and data about a specific individual, such as, for example, date of birth, first name and surname, home address, telephone number, gender, IP address, etc. We collect, use or disclose your Personal Data in accordance with this Policy and in accordance with the Applicable Law on Personal Data Protection.

4. Data Controller.

The Company acts as the controller of your Personal Data and, in this capacity, undertakes to make every effort to ensure the confidentiality of your Personal Data and to ensure the unimpeded exercise of the rights granted to you by the Applicable Law on Personal Data Protection.

5. Special note for minors.

5.1 The Edu4schools Platform as well as the psychometric tests of vocational interests and/or personality offered to the User and conducted through the Assessment Platform are addressed to both adults and minors aged from twelve (12) to seventeen (17) years old.

5.2 In the event that the Services (including, but not limited to, the performance of a psychometric test, access to the Edu4schools Platform, etc.) are to be provided to minors under the age of fifteen (15) years old, the Company obtains the prior consent of the holder (or holders) of parental responsibility in order to collect the Personal Data described below in Article 6 and process them for the purposes described in Article 8, as well as to contact the minor (in order to send them the passwords of the platform they have chosen to use, etc.), always in accordance with the Applicable Law on Personal Data Protection and this Policy.

6. Personal Data we collect.

6.1 The Personal Data we collect, where applicable, are the following:
6.1.1 With regard to the completion of the expression of interest form, by the User themselves or, in the case of minors under fifteen (15) years old, by the holder (or holders) of parental responsibility:
  • Full name, phone number, e-mail address of the holder of parental responsibility.
  • Full name, phone number, e-mail of the User.
  • Class the User attends.
  • Place of residence

6.1.2 With regard to the connection and use of the Assessment Platform, the following User details are collected:
  • Gender.
  • Date of Birth.
  • Place of residence.
  • E-mail.
  • School they attend.
  • Class they attend.
  • Psychometric test results.
6.1.3 With regard to the connection and use of the Edu4schools Platform, the following User details are collected:
  • Full name
  • e-mail
6.1.4 Any other detail/information that the User or the holder of parental responsibility may provide during the provision of the Services or subsequently (e.g. results of Panhellenic Examinations, higher education school in which the User was admitted, postgraduate studies, etc.).

7. Information we receive automatically when you log in to one of the platforms.

7.1 We may collect information when you visit or log in to the Assessment Platform and/or Edu4schools Platform with your passwords as your web browser sends data to our servers. With this information, we can optimise our Services by personalising and improving your experience when using any of the aforesaid platforms (via a computer, mobile phone or other mobile device). This information may include the following:

7.1.1 your IP address;

7.1.2 the date and time of your visit to the respective platform;

7.1.3 the referral URL (i.e. the website from which the user originated);

7.1.4 information about the device you are using and your web browser (type of web browser and version, operating system, etc.)

8. Purposes for which your Personal Data are used.

8.1 We use your Personal Data for the purposes outlined below:

8.1.1 Provision of Services: We use the Personal Data described above in Article 6 to the extent necessary to provide the Services, to register, manage and maintain the account created by the User on the respective platform as well as to contact the User or the holder of parental responsibility (if the User is under 16 years old) in order:
to create a customer record in the Company's system;
  • to set, by telephone, the date and time of a meeting (online or in person) with a counsellor of the Company;
  • to e-mail the necessary information regarding the meeting (e.g. counsellor's name, etc.). In case the User is under fifteen (15) years old, the holder of parental responsibility decides whether the necessary information will be sent to them or directly to the User;
  • for the Company to create a User's account on the Assessment Platform and then send the unique codes to the User to log in to the platform and answer the questions of the test;
  • for the Company to create a User's account on the Edu4schools Platform (if and to the extent that it is part of the Services provided) and then send the unique codes to the User to log in to the platform, which contains useful information concerning the educational system;
  • for the User to have access to the results of the test they have performed.

8.1.2 Marketing: Upon completion of the Services, we use your contact details to serve our legitimate interests, and in particular, to recommend to the User Services that may be of interest to them, taking into account the results of the psychometric test, their age and other factors. In any case, you can unsubscribe from the Company's list of recipients at any time.

8.1.3 Use of each platform: We use your Personal Data (e.g. IP address) to analyse the use of each platform and improve them functionally and technically.

8.1.4 Dispute Resolution: We may also use your Personal Data to resolve disputes, address issues and enforce any policies and rules governing the use of the Platform.

8.1.5 Other purposes: To the extent required by law, we will ask for your consent when we want to use your data for other purposes than those set out above.

9. Disclosure of your Personal Data.

9.1 We do not sell your Personal Data to third parties. However, in the context of providing the Services and in the normal course of our business activities (e.g. IT management and maintenance, provision of counselling/legal/tax services by external partners), we may share some of the Personal Data of the adult User or the holder/holders of parental responsibility of the User with:

9.1.1 a limited number of our staff and employees in the sales, customer service and technical departments, to the extent necessary to provide you with the Services;

9.1.2 third party partners acting on our behalf in accordance with this Policy (as detailed below); or

9.1.3 as permitted or required by the applicable legislation on personal data protection. You can request the full list of processors on our behalf by sending a written request to the address indicated at the beginning of this Policy.

9.2 Service providers.
We may use third-party service providers (e.g. web hosting providers, data management providers) to manage one or more aspects of our business activities, including the processing or delivery of personal information on our behalf. When using an external company or partner, we ensure that your Personal Data are being processed according to this Policy and the applicable legislation through contractual commitments or other appropriate means.

9.3 Disclosure according to law.
We may disclose your Personal Data as permitted or required by law. For example, we may be required to reveal and disclose your Personal Data pursuant to a court order, a prosecutor's order or writ, or a decision of another person or administrative body with statutory authority to compel disclosure of such information. If we have reasonable grounds to believe that your Personal Data could be useful for the investigation of improper or illegal activity, we may disclose such information to law enforcement agencies or other competent investigative authorities.

10. The right to be informed, the right of access, the right to object and the right to erasure.

10.1 With regard to your Personal Data, you retain, inter alia, the right to be informed, the right of access, the right to object and the right to erasure (“right to be forgotten”), as specifically described in Articles 13-21 of the Regulation. In this context, you may have access, at any time, to your Personal Data that we maintain in databases in order to modify, correct or update this data, even to object – at any time and for reasons related to your particular situation – to the processing of Personal Data concerning you, as well as to withdraw your consent to the processing thereof or to request their permanent erasure from the Company's records. To do this, please follow the steps indicated each time in the message you receive via the relevant means of communication (e.g. e-mail).

10.2 You can, at any time, request the permanent erasure of your Personal Data, which we keep in our records, by sending a request for erasure of the Personal Data by e-mail to: [email protected] or by calling +30 210-6778777. For our part, we will respond within thirty (30) business days of receiving your request. In the event that we do not respond or our response is not considered satisfactory by you, you have the right to appeal to the Hellenic Data Protection Authority and request a review of our response or failure to act.

In case you make an erasure request:

a) We will stop using and making available your Personal Data (unless otherwise provided or required by law).

b) We will delete all your Personal Data from our databases, except those contained in emails, correspondence or other documents that we may retain in order to be able to prove the terms of our contractual relationship with you or as otherwise provided by the legislation in force.

c) Taking into account the available technology and the implementation costs, we will take reasonable technical and organisational measures to inform other processors who process your Personal Data on our behalf, as specifically mentioned above, that you have requested that they (the processors) erase any links to such data or copies or reproductions of such Personal Data.

Please note that we may need to ask you to verify your identity before proceeding with your above request.

11. Summary of your rights in accordance with the provisions of the Regulation.

In the context of respecting your privacy/personal life, we endeavour to ensure that your Personal Data are kept in accordance with the Applicable Law on Personal Data Protection, as well as in accordance with any other applicable relevant legislation. In this regard, we guarantee that your Personal Data will be:

(a) processed fairly and lawfully. In particular, we will demonstrate transparency with regard to the processing of your Personal Data;

(b) collected only for explicit and legitimate purposes and not further processed in a manner inconsistent with those purposes. Should we decide to further process your Personal Data, then your explicit consent is necessary;

(c) relevant, appropriate, and no more than what is required each time in view of the purposes of the processing. We will collect and retain your Personal Data where necessary to fulfil operational and administrative requirements or to comply with any legal obligation;

(d) accurate and, if necessary, updated/corrected upon your request;

(e) kept in a form that allows you to be identified and for no longer than is necessary for the purposes for which they were collected or for the purposes subsequently processed;

(f) processed in accordance with the rights of the subject of Personal Data as such rights have been established by the Applicable Law on Personal Data Protection (right to be informed of the processing undertaken, right of access to Personal Data, right to object/restrict the use/processing of Personal Data, right to interim judicial protection, right to lodge a complaint with a supervisory authority, right to portability and restriction of processing, right to be informed in case of automated decision-making/profiling of the user of the Services);

(g) protected, through the implementation of appropriate technical and administrative measures, against unauthorised or unlawful processing as well as against accidental loss or destruction or damage in the context of the Company’s activity;

(h) your Personal Data will not be transferred by Us to non-EU countries, unless you have given your consent and only if an equivalent level of protection of the rights and freedoms of the Personal Data subjects has been established and implemented in relation to the management of the exported data;

(i) Right to data portability: According to the Regulation, as the subject of your Personal Data, you retain the right to data portability and, in particular, the right to receive the Personal Data concerning you, which you have provided to Us as the controller, in a structured, commonly used and machine-readable format, as well as the right to transfer such data to a new controller without our objection, in accordance with the specific provisions of Article 20 of the Regulation. In such a case, we bear no responsibility for the processing of the data by the new controller to whom your Personal Data will be sent, nor for the quality of the data to be transferred, beyond what we are obliged to do under the Regulation. As the controller, we will need to verify your identity before proceeding with the above. The right to portability – if exercised – does not negate the other rights provided for under the Applicable Law on Personal Data Protection.

The website of the Hellenic Data Protection Authority provides information and assistance with regard to the rights under the Regulation and the related legislation (www.dpa.gr/en). In summary, your basic rights are as follows:
  • The right to know what information is held about you in electronic form and in paper records.
  • The right to access and be informed regarding the purpose of the processing of Personal Data, the recipients or the categories of recipients.
  • The right to be informed of possible changes that have taken place in the way of processing since our last update to you.
  • The right to be informed about the methodology applied to the automatic processing of Personal Data.
  • The right to be informed about the security measures imposed by the Data Controller for the security of your Personal Data.
  • The right to be informed about the relevant transfer of your Personal Data to third parties.
  • The right to take steps to stop the processing of your Personal Data if the processing is likely to cause you to suffer significant damage or significant non-material damage, where this is unjustified.
  • The right to object to the processing of your Personal Data, as well as to request that your Personal Data are not used to promote various products and services.
  • The right to prevent decisions made about you based solely on automatic processing (profiling).
  • The right to request the rectification or destruction of Personal Data that are incorrect or which you no longer wish to be processed.
  • The right to restrict the processing of your Personal Data, as well as the right to portability thereof (when the processing relates to identifiable personal data and is based on a consent and the performance of the contract).
  • The right to object at any time to the processing of your Personal Data, as well as the right to withdraw your consent to the processing thereof at any time and to request their permanent erasure from the Company's databases.
  • The right to lodge a complaint with a supervisory authority.
  • The right to claim compensation if you have suffered damage and non-material damage as a result of a breach of the provisions of the Regulation.

13. Duration and country of storage of your Personal Data

13.1 Unless the User submits a request to restrict the processing or to erase their Personal Data, such data are retained by the Company:

13.1.1 For a period of ten (10) years from the date of completion of the Services provided in order for the User to have access to the results of the psychometric tests and other assessments carried out during the provision of the Services and/or for the Company to be able to offer Services suitable and appropriate for the User's professional or academic career.

13.1.2 At least for as long as required under the applicable legislation (e.g. tax legislation). Exceptionally, the User's unique passwords to each platform shall remain active for a period of only one (1) year from the time of activation and shall then be automatically deactivated.

13.2 Unless you express the wish for us to retain your Personal Data for a period longer than ten (10) years, we will proceed to the anonymisation of your Personal Data in order for the Company to use such data for statistical purposes (e.g. to statistically evaluate the validity and reliability of the Services provided, the assessments of our counsellors, etc.), in accordance with the Applicable Law on Personal Data Protection. The anonymised data will no longer be disclosed to third parties. In any case, you reserve the right to erasure of your Personal Data before completion of the ten (10) years period, as specifically defined above.

13.3 Your Personal Data are stored and processed in countries within the European Union.

14. Contact details for any queries.
If at any time you have any questions or queries about this Policy or believe that we have mishandled your Personal Data, please send an email to [email protected] or alternatively contact our Customer Service Department at +30 210-6778777 and we will make every effort to resolve any issue or reply to any query you may have.