In order to become our subscriber, we will ask you for the necessary information to conclude the contract, such as name, VAT number, ID number, Address, contact details (phone and / or e-mail). We will also ask for proof of identity such as identity card or passport.

For the provision of telecommunication services and the transmission of your communication we process Traffic & Location Data, as mentioned above and we exchange them with other providers to ensure that you can communicate with subscribers of other providers as well as to use our services when you are abroad.

In order to serve your requests through the customer care channels of OTE and COSMOTE (eg call center, store network), we process your data to identify you and to serve your requests. The requests include, among others, information requests, requests for exercising rights, complaints or grievances that we receive through competent authorities (eg EETT, Consumer Ombudsman, Data Protection Authority (DPA), ADAE).

For the charge of our services we process Contract Data and Traffic Data, in order to configure your invoice.For the payment of the provided services, we process additional information, such as where you paid the bill, as well as Invoicing Data (means of payment, credit / debit card details, in case a card is used and / or the IBAN , in case of payment by standing order).

Also, in order to verify the correct operation of the billing process and to detect possible incorrect charges, we process Traffic Data, Invoicing Data and limited Contract Data, in order to carry out sample checks.

In addition, SMS messages originating from abroad networks are processed, in order to achieve their correct billing and payment of interconnections, as well as to protect the network from massively sent SMS messages, originating from dangerous destinations.

COSMOTE and OTE collect and process Traffic Data (which includes location data) of subscribers and users and Contract Data, in order to provide effective fault management. The Traffic Data we process for fault management purposes also include data of subscribers of other networks (mainly their phone number), which received call(s) by OTE / COSMOTE subscribers, as well as data of foreign subscribers, which use our mobile network as roamers. Data are utilized:

Data are utilized:

• to perform preventive actions to our network, in order to ensure the smooth operation of the services provided.
• to deal with a specific problem of our network, which is reported by you and may relate to the coverage or quality of the network such as call interruption, poor call quality, low access speed, frequent disconnections from the Internet, etc. In these cases we refer to your Data, in order to identify if this is a generalized problem in a specific area or if it only concerns your connection, in order to deal with the problem as efficiently and as quickly as possible.
• to resolve problems in the operation of our information systems, which are necessary for the provision of our services and their billing, such as for example the fault management of billing systems.

In order to inform you about issues related to your contract, such as e.g. to inform you about your current bill or for requests you have submitted, we contact you via email, sms, post or even by phone.

We process a limited range of your personal data and specifically Contract Data, Usage Data, Billing Data, Customer Care Data, Terminal Equipment Data and Promotional Data for the direct promotion of similar products and services. This processing is limited and aims solely at the submission of proposals and offers concerning the promotion of products and services similar to those you already have and are tailored to your needs. Examples of such messages are messages for offers in our store network, contract renewals and pre-paid cards, Internet speed upgrades. Our communication will take place using the contact details that you provided us in your contract or in a transaction.

We further process Customer Care Data, such as queries, complaints, fault reporting, call center downtime, new service requests, fault time or other service malfunctions in order to provide you with free communication packages with airtime and / or GB on your mobile phone, which facilitate your communication and internet access.

Also, in order to offer you reciprocal gifts (eg packages with free airtime and / or GB, discount coupons, etc.) for your loyalty, we process Simple Personal Data, such as the date of activation of your connection. Gifts can be given either automatically and then you receive relevant information (eg via sms or push notification through COSMOTE applications) or you could be informed (eg via sms or push notification through the COSMOTE applications) for the gifts you are entitled to and activate them through the COSMOTE applications.

In addition, after the expiration of the contract for any reason and the settlement of any pending issues between us (eg payment of overdue bills) and after the expiration of the data retention period provided by the current regulatory framework, OTE and COSMOTE retain your connection number (fixed or mobile) without any other information about you in order to identify you as our former customer in case we wish to contact you, in order to promote your return to our network.

We process a limited range of your personal data and in particular Contract Data, Billing Data, Customer Care Data and Equipment Data to ask you to participate to our customer satisfaction surveys or product/customer care evaluation surveys. These surveys are in the form of a questionnaire and can be sent to you via sms or IVR system, through COSMOTE applications, via email, or they could be conducted through outgoing telephone calls. They can also be carried out by an external partner.

In case you choose to participate in a survey, we will analyze your answers and may contact you.

We process Contract Data, Traffic Data, Usage Data, Billing Data in order to limit your exposure to usage that results in unusually high charges, as well as to ensure their payment.

For this purpose we process personal data related to an unusually high charge of a subscriber. An "abnormally high charge" is determined based on specific criteria, which include the average of the previous six months' billed traffic and the current billing period's above-average charge rate.

As long as the above charges meet the combination of the relevant criteria, they are included in the daily reports with unusually high subscriber charges. Then, the cases that require control and management are evaluated by a human agent and specific actions are performed such as: (a) sending an informative SMS for unusually (repetitive or not) high charges and a related SMS request for payment of the due amount within five (5) days , otherwise outgoing call barring will be applied, (b) in case of communication with you, information is given about the non-billed usage, while the call is recorded and kept in accordance with article 6 of this Update.

We process Contract Data, Traffic Data, Equipment Data and Invoicing Data in order to protect our subscribers and prevent or detect telecommunications fraud.

For these reasons, we create a profile of your telecommunications traffic and make automated decisions to prevent or mitigate fraud.

The automated evaluation of your telecommunications traffic results from the evaluation of indications of unusual telecommunication traffic in combination with your Contract Data, Equipment Data and Invoicing Data. After this assessment is carried out and if there are indications of telecommunications fraud, automated actions are activated, such as temporarily blocking of outgoing calls to high-risk destinations. The above processing constitutes profiling and automated decision-making, which has an impact to our subscribers such as possible adaptation of the service provided (e.g. temporary blocking).

In order to prevent unauthorized access to our network and information systems and to protect our network and systems against electronic attacks, we perform traffic management actions and process traffic and location data. This is how we prevent illegal and unfair actions on our network and ensure the privacy of your communications. In addition, we maintain logs, which may include traffic and location data of our subscribers for the purpose of monitoring compliance with our policies and ensuring the confidentiality of communications

In the context of the gradual operational integration of OTE and COSMOTE, as well as stores network of GERMANOS, we proceeded to mutual processing of the Contract Data of our subscribers in order to provide the best possible unified service. This means that the companies, together or separately, determine the purposes and manner of processing of your personal data that you have entrusted to us. The purpose of this processing is the uniform treatment and service of the fixed and mobile telephony subscribers by our customer care and stores as well as the promotion of rateplans that best meet your telecommunication needs. In addition to OTE and COSMOTE , our stores (GERMANOS) and the branch network of our partners have access to this information in order to provide you with a unified service.

OTE and COSMOTE provide services on credit, i.e. based on post-payment cycles and invoicing but also due to the provision of subsidies and the provision of equipment with retention of ownership.

In this context, we wish to protect our legal interest in dealing with reliable subscribers and prevent the creation of overdue debts in the course of our business activity. For this reason:

• 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.
  
  Information that COSMOTE derives from the TELEGNOUS database is an indication of whether a subscriber has a record in TELEGNOUS database and if he belongs to category a' or b'. This information 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 .
  
  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.
   
• We process personal data for the credit assessment of our new and existing subscribers. The credit assessment takes place during the pre-contractual stage, after the subscriber signs an application for a connection. It also takes place for existing subscribers that request a new service.
  
  When assessing credit risk, we perform credit profiling and automated decision-making. Specifically, we classify each transactional subscriber into credit profile categories, combining information concerning both the subscriber's Demographic Data and information regarding his transactional behavior resulting from the use of mobile and landline telephony services. The categorization takes place in different credit profiles (fixed and mobile telephony) depending on the product-service requested by the respective subscriber.
  
  The prospective subscriber may declare within the connection application form that he does not wish the automated processing of his personal data for the above purposes. In this case, the credit check will be performed at a later stage with a procedure involving a human agent using the abovementioned criteria.
  
  This pre-contractual inspection is carried out as follows:
  
  3.3.7.1 in case you have been an OTE or COSMOTE subscriber in the past:
  
  we process information that we already have in our information systems in an automated way, such as the personal details of the prospective subscriber (name, TIN), as well as information regarding our previous contractual relationship provided that they have not been deleted (such as contract duration, grant amount, average billing details and their payment history).
  
  The prospective subscriber may declare within the connection application form that he does not wish the automated processing of his personal data for the above purposes. In this case, the credit check will be performed at a later stage with a procedure involving a human agent using the abovementioned criteria.
  
  3.3.7.2 In case the credit check is not possible based on the data available in OTE and COSMOTE systems (eg because the specific prospect subscriber has never been an OTE / COSMOTE subscriber before):
  
  OTE and COSMOTE perform a pre-contractual credit control i) by processing Contract Data (data from your application, as well as information regarding the products and packages you request) and ii) using the database containing data relating to the financial behavior of customers of mobile communications of TELEGNOUS. More information regarding TELEGNOUS file are provided in paragraph 3.3.7.

3.3.8.1 In order to have a more effective collection of overdue debts from our subscribers and the corresponding reduction of bad debts

OTE and COSMOTE process subscribers' personal data, specifically Contract Data, Invoicing Data and Customer Care Data, in order to inform you about your overdue debt in the following ways: sending an informative sms, email or letter with the aim of reminding of your debt and the ways to repay it or sending a pre-recorded automatic voice notification (IVR) with corresponding content.

3.3.8.2 For the transfer of your data to cooperating debtor information companies, in case of overdue debt. 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,
• EFFECTIVE DIRECT SOLUTIONS (EDS) SA DEBT COLLECTION COMPANY

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.

Information about the operation of the cameras in our stores can be found here.

In order to ensure a high level of quality in the provided customer care service, a sample of the recorded communications with costumer care agents is evaluated.

***

The specific types of processing based on our legitimate interests are very important for the development of our products and services, but also for the protection of your interests as a consumer. However, you can at any time object to one or more types of processing, which are carried out on the basis of legitimate interest. To exercise the right to object please see here.

OTE and COSMOTE may process your data, in order to transmit it to the competent police or prosecutor / judicial or supervisory authorities, solely for the fulfillment of their legal obligation, after first receiving a relevant legal request and for the purpose of compliance by of the current legislation.

In addition, OTE and COSMOTE, in the context of their compliance with the current regulatory framework, are obliged to have in their organizational structure an Internal Audit Unit and a Regulatory Compliance Unit, which within their responsibilities can process personal data of OTE and COSMOTE subscribers.

In the context of our compliance with article 3.2 par. N of no. 991/4 / 31-5-2021 Decision of EETT "Regulation of General Authorization", OTE and COSMOTE or their associates process Simple Personal Data in order to contact you via email or sms or even by phone in order to inform you about the upcoming termination of your contract, which may lead to changes in your invoice, and suggest you the best current invoice for the services you receive from OTE and COSMOTE.

To provide information to emergency authorities, to respond to calls to emergency numbers, including the single European emergency number 112, and to locate the caller, we provide to the emergency services caller location information (Traffic and Location Data).

In case of emergencies, such as major natural disasters, and in order to meet the increased needs of our subscribers, we may process Contract Data and limited Location Data in order to determine which of our subscribers are at the scene of the natural disaster or emergency (eg state of war, terrorist attacks) and offer them benefits such as free airtime or free MB. The purpose of these temporary benefits is to cover the increased telecommunications needs of our subscribers which arose due to the emergency and to facilitate their communication.

OTE and COSMOTE seek the continuous improvement of the services provided to you, the provision of a high level of service and the implementation of promotional actions that meet the needs of our subscribers. For this purpose we further process:

• Simple Personal Data, in order to draw conclusions about the use of our services and the level of service. For example, we will process your Contract Data and Customer Care Data in order to draw statistical conclusions about the average customer response time to our customer requests or the average customer waiting time at our call center We will also process Simple Personal Data to draw conclusions regarding the use of our services and offers, in order to improve them and also to design new ones..
• Contract Data and Promotional Data in order to understand how effective our advertising campaigns are and to improve the design of young people.
• Customer Care Data and Contract Data, in order to configure the Customer Experience Index in order to provide you with the best service. Through the Customer Experience Index we evaluate the level of service we provide and the quality of our telecommunications services in order to launch immediate remedial actions of the problem that you may mention and to identify the points that need improvement in our internal processes.
• Traffic Data and Location Data, in order to analyze and draw useful statistical conclusions regarding the operation and design of our network after the application of anonymization techniques. Anonymity is the application of practices to personal information so that it is no longer possible to identify from this information what your identity is.
• Simple Personal Data, to which we have applied mechanisms to hide IDs, in order to improve our information systems. In particular, we process limited data in order to control and improve our information systems in case of upgrades or changes.

OTE and COSMOTE, in the context of their participation in European research programs, disclose to partners anonymous data, including Traffic data or Location Data, in order to draw useful statistical conclusions related to their research.

OTE and COSMOTE, in the context of their participation in innovation competitions, disclose anonymous data to participants, in order to use them for the development of innovative products and / or services.

The above cases are compatible further processing of the data for the evaluation of which we took into account specific factors, such as: the relationship between initial and further processing purpose, the reasonable expectations of our subscribers, the nature of personal data and the possible consequences of further processing, as well as the measures taken by the controller for data protection.

OTE and COSMOTE use anonymous data in order to draw useful conclusions so as to improve our internal processes.