Privacy Policy
Effective Date: 1st of January 2023
Please read our privacy policy carefully to clearly understand how we collect data.
Your data is safe with us
At modulus SA (“modulus”) we value privacy and data protection. We comply with all relevant legislation, including the European Union Regulation 2016/679 of the General Data Protection Regulation (also known as “GDPR”), which came into force on 25 May 2018 and affects the protection of all personal data we hold on our possession.
What is personal data?
The term Personal Data refers to any item or information that can identify or contact an individual. This also includes cases where someone’s identity can be ascertained even indirectly by reference to a factor unique to that person’s physical, physiological, genetic, psychological, economic, cultural or social identity.
The purpose of this Privacy Policy is to inform you in detail about everything concerning your personal data and modulus. If you have any further questions, please do not hesitate to contact us.
What categories of personal data do we use?
The main categories of personal data we use are:
Data for your identification
We may use data such as your first name, surname, ID or passport number, telephone number, date of birth, email address, residential address, vehicle registration number, vehicle type/model, tax registration number, to identification purposes.
In order to assess a claim, additional categories of personal data may be processed, for example, photographic material as well as sensitive data in relation to your state of health, medical reports and medical history.
Bank information
We may use your banking institution or card details and billing information to process your payment, for example when you purchase a service from us or when we want to make a payment to reimburse you.
Browsing data
Your browsing data will also be processed. For example, we will use your IP address and place cookies on your browser to give you a better online experience on our website. More information is provided in our cookie policy.
Personal data of minors
We will not request or process minor data for any reason. Our website is not directed at minors and should not be used by minors.
At modulus SA (“modulus”) we value privacy and data protection. We comply with all relevant legislation, including the European Union Regulation 2016/679 of the General Data Protection Regulation (also known as “GDPR”), which came into force on 25 May 2018 and affects the protection of all personal data we hold on our possession.
What is personal data?
The term Personal Data refers to any item or information that can identify or contact an individual. This also includes cases where someone’s identity can be ascertained even indirectly by reference to a factor unique to that person’s physical, physiological, genetic, psychological, economic, cultural or social identity.
The purpose of this Privacy Policy is to inform you in detail about everything concerning your personal data and modulus. If you have any further questions, please do not hesitate to contact us.
What categories of personal data do we use?
The main categories of personal data we use are:
Data for your identification
We may use data such as your first name, surname, ID or passport number, telephone number, date of birth, email address, residential address, vehicle registration number, vehicle type/model, tax registration number, to identification purposes.
In order to assess a claim, additional categories of personal data may be processed, for example, photographic material as well as sensitive data in relation to your state of health, medical reports and medical history.
Bank information
We may use your banking institution or card details and billing information to process your payment, for example when you purchase a service from us or when we want to make a payment to reimburse you.
Browsing data
Your browsing data will also be processed. For example, we will use your IP address and place cookies on your browser to give you a better online experience on our website. More information is provided in our cookie policy.
Personal data of minors
We will not request or process minor data for any reason. Our website is not directed at minors and should not be used by minors.
How do we collect personal data?
Customers receiving an offer
In order to receive a quote for services from modulus, you must provide us with certain information that falls under the category of personal data, such as your name, company you work for, address and contact details. We only ask for the personal data that is absolutely necessary. Without this, we cannot correctly quote you a price.
By completing the above fields in the offer process and by voluntarily sharing your personal data with us, you accept their processing by modulus. In addition, you agree that we will send you your offer, to the email you have provided us. Throughout the process, you will receive three (3) emails reminding you of the offer.
Customers who purchase services from us
When you decide to purchase services from us, we will need to receive more categories of personal data from you in order to be able to provide you with the required services.
The necessary personal data that we collect and process are: name, address, email, phone (landline and mobile), VAT number, call recording and collection of written communications from and to modulus, copy of ID or passport, number of visits to the website, account details and other financial information. Where necessary, we may process legal data. This type of personal data will also be obtained when renewing or modifying your services.
Other ways we may receive your personal data:
- Whenever you can provide us with such data – for example during a telephone conversation with us
- We may collect your personal data from any publicly accessible platforms
- When you purchase services from us through one of our trusted resellers
Our goal is to offer you the best services and to improve them and for this purpose the collection of the above personal data is absolutely necessary.
How do we process personal data?
We process personal data in accordance with relevant laws and regulations. We will only process your personal data if:
- you have consented to processing for one or more purposes
- the processing is necessary for the proper implementation of a contract to which you are a party or for actions to be taken at
- your request prior to the conclusion of a contract
- the processing is necessary to comply with a legal obligation we may have
- the processing is necessary to safeguard your or someone else’s vital interests
- the processing is necessary for the performance of a task carried out in the public interest or in the exercise of a public authority entrusted to us
- processing is necessary for the purposes of the company’s legitimate interests, except where your fundamental rights and freedoms override those interests – in such cases, the protection of your personal data will override the company’s legitimate interests
Purposes of communication
We need your personal information to be able to contact you when necessary. In addition, we will contact you to remind you about the end of your contract. Also, in the event that you submit a complaint or support request, we will need to contact you to obtain all relevant information so that we can evaluate your complaint or support request.
Marketing
With your express consent, we will use some of your information for marketing and market research purposes. We will use your details to send you informational material, as well as any information we think may be of interest to you and our offers on any products we may have available. Any information (email / sms) sent to you will provide you with the option to stop receiving such information if you wish to discontinue such communication.
Remarketing
With your express consent, we will use some of your personal data for remarketing purposes, to display our advertisements related to your interests through our trusted partners. In this way we may use your data to provide you with targeted and personalized advertising. If you have purchased services from us, your data will be used for remarketing purposes for as long as you remain our customer, and for 18 months after the end of your contract. If you have received an offer from us, your data will be used for remarketing purposes for a period of 9 months from the date we gave you an offer.
What will we do if you give us false information?
If you provide us with inaccurate, incomplete or false information, we may cancel or terminate your contract or refuse to renew it.
How long will we keep your personal data?
We will retain and process your personal data for as long as is necessary to achieve the purpose for which you originally provided the data.
Customers receiving an offer
In the event of a quote, we will process your details to calculate the cost of your service. If you do not proceed with us, we will retain your data for eighteen (18) months from the date of the offer.
Customers who purchase services
In the event that you enter into a contract with us, we will retain and process your data for the period necessary for the duration of your contract, our activities and the appropriate service to you. After termination or cancellation of your contract, we will retain your information for as long as required by applicable laws and regulations.
How is your personal data processed? What are we processing?
We use automated systems to process your personal data. This means we have systems that automatically collect, organize and evaluate the data you give us.
Automated processes are controlled by our analytics department. This means the department can carry out regular checks to ensure everything is working properly.
Who has access to your personal data?
Access to this data is available only to those who need access, for the sole purpose of serving you.
Our customer service department will refer to your information if you have any questions and if you need assistance. This is also the department that will collect your data if you choose to receive a quote or enter into a contract over the phone.
The finance and payments team will process your data in case of cancellation of your service, renewal of your service, balance check, invoicing, refund and any other billing procedure that module may have.
Finally, if you have given us permission to send you promotional material, some of the data may also be used by our communications and marketing department.
Besides modulus, who else has access to this data?
In general, we avoid disclosing personal data to third parties. However, in some cases this is necessary. Your details may be shared with:
- Public or government bodies (such as courts, regulatory bodies, law enforcement agencies, tax authorities and the Cybercrime Directorate) and third parties and their accountants, auditors, lawyers and other advisers and their representatives, as we believe is necessary or appropriate.
- Partners who help us deliver the services you have purchased. These include external call centres, lawyers and legal advisers, accountants, banks and financial institutions and others.
Will your data be used for commercial purposes?
In accordance with the GDPR, before we can send you any advertising material, you must first give us your consent. Without it, we cannot send you updates about new services or new products or partnerships with affiliated companies. We will also not be able to send you company news or market news.
If you choose to participate in these communications, you have the right to withdraw your consent at any time. Just let us know by emailing us at telecoms@modulus.gr or simply “unsubscribe” from the next email you receive. We will immediately stop processing your data for commercial and promotional purposes.
Is your personal data safe?
Absolutely! We use all appropriate technical and organizational measures to ensure the security of your personal data. We have chosen to keep only the data that is absolutely necessary, all encrypted and/or anonymized, either in part or in whole. The security of your data is extremely important to us.
What kind of changes are we making?
From time to time, we may make changes to our Privacy Policy in order to improve customer service and comply with relevant legislation. We encourage you to visit our website periodically to be informed of any changes. However, if we make material changes to this Policy, we will notify you by email to give you an opportunity to review the new terms and conditions in order to decide whether or not you agree with them.
What are your rights in relation to your personal data?
You have the right to know what data we process, why and by whom.
The right to rectification if for any reason your data is invalid or incorrect.
The right to restrict processing, as the case may be, to determine which data you want to be processed and which you want to restrict.
The right to be deleted from our database in certain circumstances, especially if we no longer need to have your data.
The right to portability, to give you the data we have processed so that you can transfer it to another partner or another company.
The right to object. If applicable, you have the right to object to the processing of your data. However, since some of this data is necessary for us to provide services to you, objection may result in the termination of your service contract.
The right to automated individual decision-making, since you have the right not to be subject to decisions made solely on the basis of automated processing, including profiling.
The right to withdraw the consent you have given us to use your data for commercial purposes.
To exercise any of your aforementioned rights, you should send us your request by email at dpa@modulus.gr or by calling us at +30 215 215 1500. We will evaluate your request within thirty (30) days. If there are objective reasons that do not allow us to fulfill your request, we will inform you. You may exercise these rights at no cost. If they are repeated frequently, we have the right to ask you to pay an administration fee of up to €25.
How can you complain about how your personal data is processed?
If you disagree with the way your personal data is processed, you can send an email to the Data Protection Officer at dpa@modulus.gr. Alternatively, call us on +30 215 215 1500.
You can also contact the Personal Data Protection Authority, which is available at www.dpa.gr.
Customers receiving an offer
In order to receive a quote for services from modulus, you must provide us with certain information that falls under the category of personal data, such as your name, company you work for, address and contact details. We only ask for the personal data that is absolutely necessary. Without this, we cannot correctly quote you a price.
By completing the above fields in the offer process and by voluntarily sharing your personal data with us, you accept their processing by modulus. In addition, you agree that we will send you your offer, to the email you have provided us. Throughout the process, you will receive three (3) emails reminding you of the offer.
Customers who purchase services from us
When you decide to purchase services from us, we will need to receive more categories of personal data from you in order to be able to provide you with the required services.
The necessary personal data that we collect and process are: name, address, email, phone (landline and mobile), VAT number, call recording and collection of written communications from and to modulus, copy of ID or passport, number of visits to the website, account details and other financial information. Where necessary, we may process legal data. This type of personal data will also be obtained when renewing or modifying your services.
Other ways we may receive your personal data:
- Whenever you can provide us with such data – for example during a telephone conversation with us
- We may collect your personal data from any publicly accessible platforms
- When you purchase services from us through one of our trusted resellers
Our goal is to offer you the best services and to improve them and for this purpose the collection of the above personal data is absolutely necessary.
How do we process personal data?
We process personal data in accordance with relevant laws and regulations. We will only process your personal data if:
- you have consented to processing for one or more purposes
- the processing is necessary for the proper implementation of a contract to which you are a party or for actions to be taken at
- your request prior to the conclusion of a contract
- the processing is necessary to comply with a legal obligation we may have
- the processing is necessary to safeguard your or someone else’s vital interests
- the processing is necessary for the performance of a task carried out in the public interest or in the exercise of a public authority entrusted to us
- processing is necessary for the purposes of the company’s legitimate interests, except where your fundamental rights and freedoms override those interests – in such cases, the protection of your personal data will override the company’s legitimate interests
Purposes of communication
We need your personal information to be able to contact you when necessary. In addition, we will contact you to remind you about the end of your contract. Also, in the event that you submit a complaint or support request, we will need to contact you to obtain all relevant information so that we can evaluate your complaint or support request.
Marketing
With your express consent, we will use some of your information for marketing and market research purposes. We will use your details to send you informational material, as well as any information we think may be of interest to you and our offers on any products we may have available. Any information (email / sms) sent to you will provide you with the option to stop receiving such information if you wish to discontinue such communication.
Remarketing
With your express consent, we will use some of your personal data for remarketing purposes, to display our advertisements related to your interests through our trusted partners. In this way we may use your data to provide you with targeted and personalized advertising. If you have purchased services from us, your data will be used for remarketing purposes for as long as you remain our customer, and for 18 months after the end of your contract. If you have received an offer from us, your data will be used for remarketing purposes for a period of 9 months from the date we gave you an offer.
What will we do if you give us false information?
If you provide us with inaccurate, incomplete or false information, we may cancel or terminate your contract or refuse to renew it.
How long will we keep your personal data?
We will retain and process your personal data for as long as is necessary to achieve the purpose for which you originally provided the data.
Customers receiving an offer
In the event of a quote, we will process your details to calculate the cost of your service. If you do not proceed with us, we will retain your data for eighteen (18) months from the date of the offer.
Customers who purchase services
In the event that you enter into a contract with us, we will retain and process your data for the period necessary for the duration of your contract, our activities and the appropriate service to you. After termination or cancellation of your contract, we will retain your information for as long as required by applicable laws and regulations.
How is your personal data processed? What are we processing?
We use automated systems to process your personal data. This means we have systems that automatically collect, organize and evaluate the data you give us.
Automated processes are controlled by our analytics department. This means the department can carry out regular checks to ensure everything is working properly.
Who has access to your personal data?
Access to this data is available only to those who need access, for the sole purpose of serving you.
Our customer service department will refer to your information if you have any questions and if you need assistance. This is also the department that will collect your data if you choose to receive a quote or enter into a contract over the phone.
The finance and payments team will process your data in case of cancellation of your service, renewal of your service, balance check, invoicing, refund and any other billing procedure that module may have.
Finally, if you have given us permission to send you promotional material, some of the data may also be used by our communications and marketing department.
Besides modulus, who else has access to this data?
In general, we avoid disclosing personal data to third parties. However, in some cases this is necessary. Your details may be shared with:
- Public or government bodies (such as courts, regulatory bodies, law enforcement agencies, tax authorities and the Cybercrime Directorate) and third parties and their accountants, auditors, lawyers and other advisers and their representatives, as we believe is necessary or appropriate.
- Partners who help us deliver the services you have purchased. These include external call centres, lawyers and legal advisers, accountants, banks and financial institutions and others.
Will your data be used for commercial purposes?
In accordance with the GDPR, before we can send you any advertising material, you must first give us your consent. Without it, we cannot send you updates about new services or new products or partnerships with affiliated companies. We will also not be able to send you company news or market news.
If you choose to participate in these communications, you have the right to withdraw your consent at any time. Just let us know by emailing us at telecoms@modulus.gr or simply “unsubscribe” from the next email you receive. We will immediately stop processing your data for commercial and promotional purposes.
Is your personal data safe?
Absolutely! We use all appropriate technical and organizational measures to ensure the security of your personal data. We have chosen to keep only the data that is absolutely necessary, all encrypted and/or anonymized, either in part or in whole. The security of your data is extremely important to us.
What kind of changes are we making?
From time to time, we may make changes to our Privacy Policy in order to improve customer service and comply with relevant legislation. We encourage you to visit our website periodically to be informed of any changes. However, if we make material changes to this Policy, we will notify you by email to give you an opportunity to review the new terms and conditions in order to decide whether or not you agree with them.
What are your rights in relation to your personal data?
You have the right to know what data we process, why and by whom.
The right to rectification if for any reason your data is invalid or incorrect.
The right to restrict processing, as the case may be, to determine which data you want to be processed and which you want to restrict.
The right to be deleted from our database in certain circumstances, especially if we no longer need to have your data.
The right to portability, to give you the data we have processed so that you can transfer it to another partner or another company.
The right to object. If applicable, you have the right to object to the processing of your data. However, since some of this data is necessary for us to provide services to you, objection may result in the termination of your service contract.
The right to automated individual decision-making, since you have the right not to be subject to decisions made solely on the basis of automated processing, including profiling.
The right to withdraw the consent you have given us to use your data for commercial purposes.
To exercise any of your aforementioned rights, you should send us your request by email at dpa@modulus.gr or by calling us at +30 215 215 1500. We will evaluate your request within thirty (30) days. If there are objective reasons that do not allow us to fulfill your request, we will inform you. You may exercise these rights at no cost. If they are repeated frequently, we have the right to ask you to pay an administration fee of up to €25.
How can you complain about how your personal data is processed?
If you disagree with the way your personal data is processed, you can send an email to the Data Protection Officer at dpa@modulus.gr. Alternatively, call us on +30 215 215 1500.
You can also contact the Personal Data Protection Authority, which is available at www.dpa.gr.