Introduction

The Pre-school Education Center – Kindergarten MIKRODROMIO (hereinafter “MIKRODROMIO”), fully understands the importance of keeping and protecting any collected personal data and therefore has implemented appropriate technical and organizational security measures, as defined in the General Regulation for the Protection of Personal Data (EE) 2016/679, according with the national and European Community legislation, and in compliance with the applicable relevant legal framework.

Personal data collected by MIKRODROMIO are collected and processed for an absolutely explicit and specific legal and legitimate purposes, and kept for specific period of time, as stated by the law. The way the data is processed is such that the confidentiality, integrity and availability are preserved at all times.

The principles governing the processing of personal data are the following:

• Principle of legality – personal data are processed legally and fairly
• Principle of lawful purpose – personal data are collected for specific, explicit and lawful purposes and will not be processed any further in a manner incompatible with the specific purpose.
• Principle of proportionality – collect no more than is justified or necessary.
• Principle of data minimization – data should be appropriate, relevant and accurate according to the purposes for which they are collected.
• Principle of accuracy – data are accurate and regularly updated.
• Principle of limitation – personal data should be kept for no longer than necessary.
• Principle of integrity, availability and confidentiality – data are processed in a way that guarantees their safety.
• Principle of transparency – informing the agent about the characteristics, scope, purpose and responsible party for processing of personal data.

This Security Policy provides accurate and transparent information to all interested parties, in a concise manner, in regard of practices followed for the management and protection of collected personal data.

This Policy may be amended and updated whenever it is necessary, i.e. when a change in current legislation takes place, while Policy is updated and published on the school website, www.microdromio.gr

Aggeliki Andrianopoulou

10 K. Karamanlis Street, Glyfada,  16675

TIN: 159259527

Tax Administration: Glyfada

Phone: 2108941800

Email: info@microdromio.gr

Contact Person: Aggeliki Andrianopoulou

Definitions

Personal data

Data of personal character (or personal data) consist of any information concerning an identified or identifiable individual/person (Data Subject).

• Genetic data: Genetic data are personal data related to the individual’s inherited or acquired genetic characteristics, as they originate from the analysis of a biological sample of the individual in question that provide unique information about the physiology or health of the individual.
• Biometric data: Biometric data are personal data, which result from special technical processing related to natural, biological or behavioral characteristics of an individual that allow or confirm the unmistakable identification of that individual.
• Health data: Health data are personal data related to the physical or mental health of an individual that include information about the provision of health care services and disclose information about his or her health state.
• Special category of personal data: Special category of personal data are, among others, genetic, biometric and health data. 
• Processing of personal data: Is any act or series of acts, that may include collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, use, disclosure through transmission, dissemination or any other form of disposal, combination, restriction, deletion or destruction.
• Editor: Editor is the individual or legal representative, public authority, service or other entity that, alone or in conjunction with others, determines the purposes and manner of processing personal data.
• Processing: The processing is performed by the individual or legal representative, public authority, service or other body that processes personal data on behalf of the Editor.

Protection of personal data: Legal Framework

The legal framework for the protection of personal data, within the context of this Policy, is stipulated in the article no. 2016/679 of General Regulation on the Protection of Personal Data of the European Parliament and of the Council on the protection of individuals, with regard to the processing of personal data and on the free movement of such data, implementing the law No 4624/2019 and any other law or regulation subsequently issued for the application of the above mentioned General Regulation.

At MIKRODROMIO we collect and process your personal data in accordance with the following:

• In compliance with the General Regulation (EU) 2016/679, and the law No 4624/2019,
• The current Greek data protection legislation,
• The consent we get from you.

Personal Data we process

At MIKRODROMIO we process the following personal data:

(a) Personal data of parents and guardians of students or prospective students:

• Name, surname, occupation, home address, identity card number/issuing authority, details of parent/guardian kindergarten/school, tax information of parents/guardians, number/age of children, payment data and means of payment
• Health information of parents/guardians and student siblings we should need to be aware of

(b) Personal data of (prospective) students:

• Name, surname, parents/guardians name and surname, sex, nationality, religion, date of birth, place of birth, contact telephone number of parents/guardians, home address, birth certificate registration number (for boys), any custody court decision or any other personal arrangements details, authorized certificate for third party who will pick up the student at the end of the daily schedule
• Health data, allergies, chronic diseases, health history, history of hospitalization, birth data, psychosomatic development data, health booklet, vaccinations, medical reports, data on learning disabilities certified by Center for Differential Diagnosis, Diagnosis and Support or similar relevant private centers
• Habitual data, arrival and departure route, dietary preferences
• Data related to the program of activities, participation in activities and/or events, daily attendance schedule, important happenings during the study, absences, photos and videos taken during the student’s study or various activities and events in which the student took place, yearbooks.

These data are collected in the following ways:

• In digital form
• In hard copy form
• In combination of the above mentioned forms.

We collect and process personal data provided freely by parents/guardians themselves.

Purpose of Processing your personal data

According to the legal framework stated above, MIKRODROMIO collects and processes personal data of parents/guardians and students or users of its website for the following purposes and only to the extent absolutely necessary for effectively serving these purposes.
These data are always accurate, relevant and in accordance to the principle of minimum requirement and, if necessary, are subject to updates. MIKRODROMIO may process personal data, if the processing is necessary, for at least one of the following legal bases. Namely:

• for the execution of transactions or contract between the two parties
• for compliance with its legal obligation
• for the purposes of its legal interests
• when you have given your consent
• for the protection of vital interests of the students
• for the performance of a duty in public interest
• for the establishment, exercise or support of any legal claims or when the courts act according their jurisdiction.

MIKRODROMIO collects the data to provide its best services. Therefore, the purpose of the processing can be:

• enrollment or transfer of a student
• promotion of the safety, health, hygiene, psychosomatic development of students, as well as the protection of the vital interests of students in general
• informing the parent/guardian about the child’s daily participation in the various activities
• wider participation of students in various events and activities
• promotion of channels of communication with parents/guardians about the student’s daily activities
• promotion of communication regarding activities and events organized, coordinated or participated by MIKRODROMIO
• information about the child’s participation in school activities, through the application ……………………. (TBA), if your consent has been provided, as well as the consent of other parents/guardians to whom relevant data will be communicated
• provision of yearbooks, photos and/or videos regarding the student’s attendance or participation in the events
• compliance with applicable educational legislation and obligations as it arise from the collection, processing and transmission of data.

In addition, for the security reasons (both, of the equipment and facilities) MIKRODROMIO has installed a closed circuit television (CCTV). Our legal interest is the need to protect our space and the goods located within it from illegal acts, such as theft. In particular, the installation of the CCTV system has been implemented based on the following rules:

• The system is in operation only during the hours when the Center is NOT open
• We collect image data only and limit the live streaming to the areas we have assessed as areas where there is an increased chance of committing illegal acts
• The cameras do not record adjacent privately owned spaces or entrances
• The stored material is accessible only by our authorized personnel who are in charge of the security
• This material will not be passed on to third parties, except in cases where it is sought by the competent judicial, prosecutorial and police authorities.
• The recorded data are deleted on the next working day. In case that in that period an incident occurred, we will isolate relevant video excerpt and keep it for 30 days to investigate the incident and initiate legal procedures to defend our legal interests; if the incident concerns a third party we will keep the video three (3) more months.

We may share personal data that we process with third parties other than MIKRODROMIO in the following cases:

• When required by law
• When there is a relevant court decision
• When required by a relevant Public Authority (tax, insurance, educational supervisors)
• When requested in writing by the police in order to investigate a crime or to prevent a serious crime
• When required by external collaborators, such as medical and nursing staff, photographers, editors, transport services and school bus drivers, legal advisors, educational and development consultants, etc. In each such case, all necessary security measures will be taken. The external partners will act as executors of the processing on our behalf and at our request, bound by a contract. They will process personal data, taking into account all the rules and laws of such a process, with a strong commitment to data confidentiality, availability and integrity
• When required for the collection and repayment of debts arising from the provision of services, as well as for the exercise or support of legal claims or rights
• When needed in order to develop, improve and promote the overall level of with a positive consent from your part
• Upon indication that better communication between parents/guardians is needed (with a positive consent from your part).

Curriculum Vitae Management

MIKRODROMIO can collect and process for the purpose of future employment the following types of data through CVs:

name, e-mail addresses, home and work addresses, telephone numbers, degrees, employment history, including job titles and employer’s name, any other information provided in CV.

We do not collect personal data that disclose racial or political affiliation, political views, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health status or sexual orientation of a candidate.

Data retention time

MIKRODROMIO is obliged to keep documents and/or electronic records for the period stipulated by the national legislation. Analytically:

• Data related to tax and other legal obligations will be kept for as long as the current legislation stipulates.
• Data regarding the relationship between MIKRODROMIO and parents/legal guardians, and cooperation and the participation of students in our activities are kept for as long as necessary, each time for the purposes of proving it in case of legal claims and until their statute of limitation.
• Parents/legal guardians data and contact details may be retained for up to three years from the end of our cooperation, so that they might be informed about possible updates on the activities of the center
• Data that serve to promote commercial services and/or the provision of privileges, are kept for a period of three years after the completion of the action
• Data we collect and process with parents/guardians consent, such as photos and videos, are retained for a period of three years, unless you revoke your consent at any given time.
• Other data we process with parents/guardians consent are retained for a period of three years, unless you revoke your consent at any time.
• CVs are kept for up to three years.

Rights of subjects regarding their personal data

You have the right to exercise, in accordance with the stipulations of the law, the following rights:

• Right of access
• Right of correction
• Right to fill in any incomplete personal data
• Right to delete your personal data, unless there are compelling and legal reasons for processing
• Right to restrict the processing of your personal data, unless there are compelling and legal reasons for processing
• Right to object to the processing of your data, unless there are compelling and legal reasons for processing
• Right to portability
• Right to revoke the consent at any time (with no retroactive effect).

The rights of the subject, as described above, may not be exercised due to a law enforcement obligation.

Technical and Organizational Security Measures

MIKRODROMIO has taken the appropriate technical and organizational measures, in accordance with the current technological developments, to ensure the implementation of the relevant legislation and the appropriate level of security of personal data. Also it has developed a culture of data protection and security, through proper training, for all staff and associates equally.
It has developed and implemented appropriate security policies and procedures. Measures taken each time are subjected to evaluation, so that the required level of security and protection of personal data is always maintained on the highest possible level. In addition, it has carefully selected all partners who may have access to the data and who are bound by a contract non-disclosure policies.

Cookies Management

Our website (www.microdromio.gr) uses cookies. The categories of cookies are the following:

• Essential for the operation of the website.
• These cookies are necessary for the proper function of our website.
• Performance
• These cookies help us measuring the visits and website traffic to improve its performance. Through these we can learn what is the traffic of visitors/users to the website, as well as to find out which elements of the website are the most popular. The information collected by cookies is anonymous. If you deny the use of cookies then we will not be able to know that you have visited our website and as a result we will not be able to monitor its performance.
• Functionality
• These cookies enable our website to offer personalized and improved functionality. They are designated either by us or by third party service providers whose services have been added to the Website. If the use of the cookies is denied then part or all of these services may not work properly.
• Targeting/Advertising
• We also reserve the rights to use, in accordance with the law, the information we receive through cookies and through the analysis of the users behavior on our website to display specific ads for some of our products or services.

The use of cookies is allowed only after the relevant information is provided to the user and after the consent (through pop-up window or information box). On the other hand each website user reserves the right to revoke the consent in the same way and at the same ease as it was given.

Termination Rights

If you have any questions about your privacy policy, or if you wish to make a complaint in case you believe your rights may be infringed, please contact your Personal Data Protection Authority:

1-3 Kifissias Avenue, Athens, 115 23
Tel: +30 2106475600,
Email: contact@dpa.gr

For the protection of your personal data, you reserve the rights to appeal to the relevant judicial authorities.