We process your data to serve your contract or to take action during the pre-contractual stage.
For the preparation of a contract for fixed telephony and internet or mobile services with OTE and / or Cosmote, for the provision of our services, or to submit an application for the purpose of concluding it, for the transmission of your communication in our network and for billing you according to the use of each service and for the verification of the billing process, we process the data referred in section What personal data do we process
As part of the interconnection of our network for the transmission of communication, we may transfer your personal data to other telecommunications network providers located in or outside the European Union.
Another processing activity, which is inextricably linked to the provision of our services to you, is troubleshooting. Specifically, COSMOTE and OTE collect and process Traffic Data and Location Data of subscribers and users, in order to provide effective troubleshooting, when you call us mentioning a problem e.g. related to the coverage or quality of the network, e.g. call interruption, poor call quality, slow WiFi access, frequent Internet disconnections, etc. In these cases we process your data to determine if it is a general problem of the particular area or if it concerns only your connection, in order to manage the problem as efficiently and quickly as possible. In addition, this data may be used for precautionary measures in order to ensure the smooth operation of the services provided.
Finally, in the context of serving our contractual relationship, and within the framework of the current legislation, OTE and COSMOTE or their partners process Simple Personal Data in order to contact you via email or sms, by post or even by phone in order to send updates regarding the service of your contract, such as e.g. to inform you about the issuing of your bill.
We process your personal data based on your consent to create your personal profile.
In addition to the execution of the existing agreement between us, OTE and COSMOTE may process your personal data on another legal basis, such as your consent.
Specifically, OTE and COSMOTE may, following your consent, process in combination your personal data derived by many of their services provided to you, in order to create your personal profile based on your personal preferences.
Profiling is a form of processing your personal data by automated means, that we may use to evaluate certain of your preferences, so as to predict products and services that you might be interest to and send you the relevant updates/ newsletters/ ads, based on your interests
Read the text providing consent here
We process your personal data based on the legitimate interest of OTE and Cosmote or of our subscribers
OTE and COSMOTE may process your personal data based on our legitimate interests, always considering your corresponding consumer rights and interests. These specific types of processing, based on our legitimate interest, are conducted after carefully balancing our legitimate interests and the need to protect your personal data and are limited to the expected processing type compatible with our contractual relationship. These types of processing are:
- For the direct marketing of our products and services, OTE and Cosmote may process a limited range of your personal data and in particular Contract Data, Billing Data, Service Data and Equipment Data. This processing is limited and is intended solely for the purpose of submitting proposals and offers similar to yours and which are tailored to your specific needs. Examples of such messages are messages for offers in our retail network, contract renewals and pre-paid cards, or Internet speed upgrades. We will communicate with you in the contact details that you have disclosed to us in an earlier transaction or during the conclusion of your contract.
- Processing of your Contract Data, Billing Data, Service Data and Equipment Data may be performed by both OTE and COSMOTE for the purpose of performing surveys or evaluation of specific products or services. These surveys are usually in the form of a questionnaire and can be sent to you by email, SMS via an IVR system or via telephone calls. They can also be carried out on our behalf by other research companies.
- We may process your personal data in order to ensure the security of our network and IT systems or to prevent telecommunication fraud. In this context, we process Traffic and Location Data to prevent unauthorized access to our network and information systems and to prevent cyber attacks or even to protect our subscribers and to prevent or detect telecommunications fraud and prevent excessive or unusual use of our services.
- As part of their gradual operational integration of OTE and COSMOTE, we have proceeded to the mutual processing of our subscribers' personal data, in order to provide the best possible services and unified customer service. This means that OTE and COSMOTE, individually or collectively, determine the purpose and means of the processing of your personal data confided to us. The purpose of this processing is to enable our Customer Service to provide a unified customer service to the fixed and mobile subscriber and to offer tariff plans that perfectly match your telecommunication needs. In addition to OTE and COSMOTE, the stores of our network and the retail network of our partners have access to this information in order to provide you with a unified customer service.
- Both OTE and COSMOTE retain the right to perform pre-contractual credit assessment in order to safeguard our legal business interests, prevent telecommunication fraud and safeguard the interests of our prospective clients. This pre-contractual assessment is carried out as follows:
- In case you have previously been an OTE or COSMOTE subscriber: we process by automated means data that we already have in our information systems. In this case, we process information such as the prospective customers’ personal data (such as name, date of birth, TIN), as well as information about our previous contractual relationship, provided that you have not been deleted (such as contract duration, grant amount, average accounts, and payment history). The prospective subscriber may declare to the employee serving him that he does not wish for the automated processing of his personal data for the above purposes. In this case, the assessment will be carried out at a later stage with a different procedure.
- In the event that a credit check is not feasible based on the data available on OTE and COSMOTE systems (e.g. because this particular subscriber has never been an OTE / COSMOTE subscriber), OTE and COSMOTE perform a pre-contractual credit control using the database containing data relating to the economic behavior of customers of mobile communications created by the mobile telephony companies and operated by the company named “TELEGNOUS – TELECOMMUNICATIONS SOLVENCY ASSESSMENT AGENCY – PRIVATE COMPANY” with the distinctive title “TELEGNOUS PRIVATE COMPANY” (hereinafter “TELEGNOUS”).
- In case you have outstanding debts due to mobile usage, COSMOTE reserves the right to disclose your personal data to TELEGNOUS, which has been established by all the mobile electronic communications companies currently operating in the Greek market and maintains a record of customer behavior inconsistencies of the customer-subscribers and acts as a Data Controller for this record. The purpose of this record is to perform effective pre-contractual credit assessment and to clear the transactions in the mobile telephony sector.
- TELEGNOUS has been approved by the Hellenic Data Protection Authority (HDPA), as per its positive Opinion No 1/2015. Further details regarding the conditions of the legal operations of TELEGNOUS are included in the Decision No. 28/2017 of the Hellenic Data Protection Authority (HDPA).
- Thus, COSMOTE may transfer the personal data of its subscriber to TELEGNOUS if:
- A) the subscriber has a due arrears for more than ninety (90) days and for an amount equal to or greater than € 200,
- B) the subscriber's connection has been disconnected from the COSMOTE network or transferred to another via a number portability procedure, without the subscriber having settled their accounts.
- The personal data that COSMOTE may transfer to TELEGNOUS is the TIN number, ID number or Passport ID number, the subscriber’s first and last name, as well as an indication of whether the subscriber belongs to category a or b.
- The information that COSMOTE derives from the TELEGNOUS database will in no way be used to exclude the consumer from telecommunication services or portability. Instead, they are used as a supplemental consulting tool in the process of contracting with prospective subscribers to help you choose the right telecommunications product that best suits your personal needs and financial capabilities.
- Obviously, every subscriber retains the right of access and the right to object (including correction) in relation to the processing of his personal data by TELEGNOUS. For this purpose you can address your request to Cosmote in the ways described here or to the company TELEGNOUS (56 Kifissias & Delphi Avenue, Marousi, 15125).
- More information on TELEGNOUS and its operation can be found at http://www.telegnous.gr.
- vi) Under applicable law and in case of overdue debt, we reserve the right to transfer your personal data to cooperating debt collection companies in accordance with the provisions of Law 3758/2009 or any currently applicable law, in order to inform you of the existence of overdue debts and to negotiate the time, manner and other terms of repayment, on our behalf. In this context, we transfer Simple Personal Data to the aforementioned debt collection companies and to cooperating law firms. To this end, we cooperate with the companies E-VALUE INFORMATION debtors LIMITED LIABILITY COMPANY, PALADINO Management SA TRADE RECEIVABLES AND SERVICE CUSTOMER SERVICE, FIRST CALL SA UPDATE debtors FOR LIXIPROTHESMES REQUIREMENTS, EOS MATRIX (EOS Matrix) SA UPDATE debtors FOR LATE REQUIREMENTS AND CYCLE CIRCUIT REPORTING COMPANY FOR LATE REQUIREMENTS. ΟΤΕ and COSMOTE reserve the right to modify this list, by posting the updated list in this Policy. Moreover, we reserve the right to transfer your personal information to cooperating law firms in order to settle claims or settle disputes between us. Lawyers and / or offices may, cooperating with us and within their mandate, seek an amicable settlement of the dispute between us prior to any possible recourse to the courts by calling the contact phone number, we provide them with, or via mail, by using the available contact details e.g. telephones, e-mail, fax etc.
- vii) Following the expiration of our contract for any reason and the settlement of any outstanding dispute (e.g. overdue accounts) and following the expiration of the period that your personal data can be stored according to the applicable regulatory framework, OTE and COSMOTE retain the number of your connection (fixed or mobile) without any other information about you in order to identify you as our former customer in case of any future communication aimed for you to return to our network.
- viii) In cases of major natural disasters (e.g. fires, floods, earthquakes, etc.) and in order to meet the increased needs of our subscribers in emergencies or in case of unavailability issues in our mobile network we may process Contract Data and limited Location Data to determine which subscribers are in the area of natural disaster or were affected by the issue, in order to provide them with emergency benefits, such as free talk time or free MB. The purpose of these emergency services is to cover the increased need of our subscribers for telecommunication services, which has arisen either due to the natural disaster or due to the unavailability of our network for a certain period of time.
- ix) In addition, we process Contract Data and Billing Data in order to execute the cooperation contracts with our retail network and the return of the agreed commission to our partners.
These specific types of processing based on our legitimate interest are of particular importance to us and the development of our products and services, but also to your own protection and your interest as a consumer. However, you may at any time object to one or more processing activities, based on the legitimate interest (categories i-vix). In order to exercise your right to object, please see here.
We process your personal data for compliance purposes with our legal obligations.
- OTE and COSMOTE may process your data in order to transfer it to the competent police or prosecuting / judicial or supervisory Authorities, solely for the purpose of complying with their legal obligations, after receiving a relevant legal request and in order to comply with the applicable legislation.
- In addition, OTE and COSMOTE, in the context of complying with the current regulatory framework, are obliged to have in their organizational structure an Internal Audit Unit and a Compliance Unit, which might process the personal data of OTE and COSMOTE subscribers as part of their responsibilities.
- In the context of complying with article 3.2 par. n of the Decision no. 991/4/31-5-2021 “Regulation on General Authorization” of the Hellenic Telecommunications and Post Commission (EETT), ΟΤΕ and COSMOTE or their partners process Simple Personal Data in order to contact you via email or sms or even by phone, in order to inform you about the imminent expiration of your contract, which may result in changes to your billing or in order to suggest the best current rateplan for the services you receive from OTE and COSMOTE.
We further process your personal data in order to continuously improve our services and the customer service.
OTE and COSMOTE seek to continuously improve the services provided to you and to provide a high level of customer service. For this purpose, we further process Simple Personal Data, in order to draw useful statistical conclusions on the use of our services and the level of customer service e.g. request service times, call center waiting times, etc. We, also, formulate the Customer Experience Index based on the combined processing of Service Data and Contract Data, to help up evaluate the level of customer service and the quality of the telecommunication services we provide, so as to expedite the immediate remedial actions of the problem that you may mention and to identify the points that need improvements in our internal processes.