INFORMATION ON THE PRIVACY AND PERSONAL DATA PROTECTION POLICY OF THE CIVIL NON-PROFIT ORGANISATION, ‘VOCI CONTRA TEMPO’

Tax Identification Number: 997017889

Registration Number (Thessaloniki Chamber of Commerce): 158958706000

DISCLAIMER: This policy document in English has been translated from the original, written in Greek. Should there be any discrepancies between the documents, or queries about the content, individuals’ rights or the use of their data, the Greek language document will take precedence over the English one for all legal purposes.

Translation Note: Although the direct translation of ‘ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ ΕΤΑΙΡΙΑ’ is ‘Civil Non-profit Company’, in order to avoid confusion in the English translation, this legal form of association (which ‘Voci Contra Tempo’ is constituted as) is referred to as ‘The Organisation’ in English rather than ‘The Company’, even though it is referred to as such in Greek. This is done to ensure the understanding that it is a non-profit entity. The entity of ‘Voci Contra Tempo’, in Greek law, is a company that has the right to sell products or services and generate income, but not profit. It has no shareholders and the Board of Directors do not profit from the income nor draw salaries. Is not a publicly traded company and the entire income from any products / services are used for the organisation’s projects and operations.

The Civil Non-Profit Company (henceforth ‘The Organisation’) with the name ‘Voci Contra Tempo’ founded in Thessaloniki (currently based at 47 Steliou Kazantzidi, Pylaia, 55535), is a legal entity which has the right to hold and process personal data, as set out in the framework of the General Data Protection Regulation (EU 2018/679), which entered into force on 25/05/2018 and is hereinafter referred to as the ‘GDPR’. ‘Voci Contra Tempo’ is additionally subject to, and upholds, the law 4624/2019 of the ‘Personal Data Protection Authority’ which comprises measures implementing Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data. This also allows for the transposition into national law of Directive EU 2016/680 of the European Parliament and of the Council of 27 April 2016 and other provisions. These acts and legislation provide the public with the following information about the gathering, storing, processing and use of your personal data and your rights as the subject of these processes.

The purposes of our Organisation are artistic and cultural.  Our primary aim is the foundation and formation of a choir, with the name ‘Voci Contra Tempo’ and the support and promotion of this choir. Our goals include, among others: the promotion of choral music (both Greek and international), the provision of support for young composers and musicians, cooperation with other music and arts organisations (both in Greece and internationally), cooperation with arts and cultural institutions and public bodies, the organisation of educational programmes (seminars, classes, workshops, collaborations with schools and universities etc).  In addition, we aim to support, utilise and promote the work of the local arts services and capacities, as well as to contribute to regional cultural development.

The information presented here, is addressed to individuals, who either take an active part in the activities of the Organisation (as participants of an educational programme, or as an audience member at a concert) or are simply informed about our work through e-mail, by telephone, or any other kind of communication. This information is intended to inform you about the personal data we collect and process in the context of the aforementioned described purposes and actions of the Organisation, as well as the manner and purposes of collection, storage, use and transmission of such information on a case- by-case basis. It also aims to inform you about your rights in accordance with EU legislation on privacy.

Legal Framework

According to Article 4 (1) of the GDPR,  ‘personal data’ denotes any information relating to an identified or identifiable natural person (that is, a private citizen, rather than an organisation, persona or representative of a group) and is referred to, in this context, as a ‘data subject’. An identifiable natural person is one whose identity can be verified immediately or indirectly, in particular with reference to an identity element such as name, passport / ID number, location data, online identity or one or more factors specific to his or her physical, physiological, genetic, psychological, economic, cultural or social identity as an existing, singular person.

Furthermore, in accordance with Article 4 (2) of the GDPR, ‘processing’ refers to any operation or series of operations carried out, with or without the use of automated means, to the personal data or within personal data sets-such as collection, registration, recording, organisation, structuring, storage, adaptation or alteration, retrieval of information, use, transmission, dissemination and dispersal.  In addition, ‘processing’ also includes, association or combining the data with other data sets as well as the deletion or destruction of the data. 

Finally, according to article 4 par. 7 of the GDPR, the ‘person / organisation responsible for the collection and processing of data’ is the natural or legal person, public authority, service or other body that, either on its own, or jointly with others, determines the purposes and manner of processing the data. The organisation responsible for this will undertake the data processing in full compliance with the purposes and manner of such processing, that have been determined by EU law or the law of the relevant Member State. The organisation responsible and the specific criteria for its designation as a legally responsible body, are identified as such (as legal entities with the right to do so) by EU law, or the law of the relevant Member State.

The non-profit organisation ‘Voci Contra Tempo’

The non-profit Organisation ‘Voci Contra Tempo’ is the body responsible for the collection and processing of the personal data- gathered by the means and the ways described in detail in this Data Protection Policy-which are subject to processing within the framework of your interaction with the Organisation.

What personal data do we collect?

‘Voci Contra Tempo’ collects only the personal data which you disclose to us, namely:

Identification data: 

-Name, Surname

*-Date of Birth – only if the activity in which you participate is for a specific age group

*-Gender – only if the activity involves travel or overnight accommodation

*-Identification card number – only if the activity involves travel or overnight accommodation

-Should an activity or concert of Voci Contra Tempo require that numbers of attendees / participants are restricted and we are obliged to check who attends, we may request to see some form of identification (legal I.D. card, passport, driving licence etc.) at the point and time of entry.  In such cases, we will not ask for, or keep, a copy of your identification, neither will we record the number of your identification document.

-Should an activity or concert of Voci Contra Tempo require that numbers of attendees / participants are restricted and we are obliged to check who attends, we may request to see some form of identification (legal I.D. card, passport, driving licence etc.) at the point and time of entry.  In such cases, we will not ask for, or keep, a copy of your identification, neither will we record the number of your identification document.

If a participant in any of our activities is a minor, none of their personal details will be kept beyond the duration of the action / programme / workshop etc. which links any data to an identifiable minor. We will hold specific data (e.g. the age of the participant, how many participants attended etc.) for statistical purposes, but these will be kept anonymously.  Furthermore, we will not collect any information on minors without the consent of their parents / legal guardian.

Contact Information: 

-Ε-mail address

-Telephone and cell (mobile) phone numbers

Purpose of collection and processing of personal data

The Organisation is entitled by law, to collect and process the aforementioned personal data disclosed by you, for the fulfillment of its purposes only, as described in detail here.

In a situation in which we collect data about your age, we will utilise this only a) to confirm that an activity is suitable for your age group, b) to record statistics (without any names connected to specific data points) about our activities so that we can improve and develop them in the future. 

In a situation in which we collect data about your gender, we will utilise this only a) to provide the most suitable accommodation for participants and b) to record statistics (without any identifying details) in order to evaluate the activity and the manner in which it was advertised. 

In a situation in which we request an Identification Card (or Passport) number, we will delete the information as soon as the activity which requires this detail has concluded.

Your e-mail address may be used as a means of communication between yourself and ‘Voci Contra Tempo’ in order to inform and update you about activities that may interest you, and to offer information about how to participate. If you choose to subscribe to our mailing list, we may use this means to inform you about our upcoming events and may also use it to ask for your opinion (for statistical purposes) about our activities. Your opinions will only be recorded with your consent.

Third party access to your personal data

The personal data collected by ‘Voci Contra Tempo’ may be disclosed or transmitted to third parties, if this is required for the fulfillment of obligations by law or is necessary for the fulfillment of the purposes and functions of the Organisation’s operations and work,  subject to relevant legislation. Some of the Organisation’s functions-in particular, technical and communications functions with regard to our website- are outsourced.  We may therefore entrust natural or legal persons (external to ‘Voci Contra Tempo’) with certain services and functions of our website and other essential technical processes. In these instances, the Organisation only shares the minimum personal data with external service providers, that is necessary for the task to be fulfilled (e.g. when utilising a mass-mailing service to send out an electronic newsletter, only the name and e-mail addresses of individuals will be shared with the third party / service provider).  These external service providers are bound by, and committed to, the same legal requirements of privacy and data protection as ‘Voci Contra Tempo’.

In each case, for such issues of access to data, the Organisation will request your consent.

Retention period of personal data

The data of the individuals who receive newsletters is held for one year after the individual’s request to no longer receive the newsletter. The data of the participants in our actions are kept for five years, from their last participation, but the Organisation is entitled to keep them for up to ten years for statistical reasons and in order to maintain an archive and long-term record.

Rights of personal data subjects

In accordance with the GDPR, the rights enjoyed by every natural person in relation to the processing of their personal data by ‘Voci Contra Tempo’ are the following:

Right to Information / Transparency (Articles 12 and 13 of the GDPR): You have the right to know the details of the organisation responsible for collecting and processing your data, the categories of personal data they collect, the purposes of collecting and processing this data, the recipients of your data, the retention time of this data, all of the rights described in Articles 15 – 22  of the GDPR (and analysed below), as well as the right to lodge a complaint. You are informed of these rights as ‘data subjects’ by ‘Voci Contra Tempo’ both through the relevant field of consent in the processing of personal data and through this text, which is posted on our website (vocicontratempo.com) as well as on our Facebook page (https://facebook.com/vocicontratempo).

Right of Access (Article 15 GDPR): As a data subject you have the right to request free access to your personal data held by ‘Voci Contra Tempo’.

Right of Correction (Article 16 GCC): As a Data Subject you have the right to request the correction of your inaccurate personal data and the completion of incomplete information.

Right of Deletion / Right of Oblivion (Article 17 GIP): You have the right to request the deletion of your personal data.

Right to Restrict Processing (Article 18 GDPR): As data subjects you have the right to request a restriction on the processing of your personal data when: (a) the accuracy of the personal data is questioned, up until it is verified or corrected, (b) the processing is illegal and rather than requesting deletion from our records, you would prefer a restriction of the use of your personal data, (c) the personal data is not needed for the purposes of processing, but are necessary for the establishment, exercise, support of legal claims, and (d) you oppose the processing and there are legitimate reasons concerning ‘Voci Contra Tempo’s’ use of your data. 

Right to data transferability (Article 20 GDPR): You have the right to receive your personal data free of charge in a form that allows you to access, use and process it, as well as request it from us, or, if it is technically possible, request that we transfer your data directly to another organisation. This right applies to the data you have provided us with, and its processing is based on your consent and is done by automated means.

Right to withdraw consent (Article 7 (2) GDPR: You have the right to withdraw your consent for the Organisation to retain and process your data, at any time, by submitting a written statement to ‘Voci Contra Tempo’.

Right of complaint to the National Authority for the Protection of Personal Data (of the relevant Member State) – (article 77 GDPR): You have the right to submit a complaint to the Personal Data Protection Authority (www.dpa.gr): Address 1-3 Kifissias, Ampelokipoi,11523 Athens, tel. 210 6475600, fax: 210 6475628, E-mail: complaints@dpa.gr

Security of personal data

‘Voci Contra Tempo’ has implemented all appropriate technical and organisational measures, as well as all physical security measures to ensure the secure processing of personal data and the prevention of accidental loss or destruction and unauthorised and / or illegal access to it. In addition, the Organisation ensures the legality of the collection, processing and secure storage of personal data, in accordance with the provisions of national, EU and international law concerning the protection of the individual in the processing of personal data, in particular taking into account the provisions of the General Regulation on Data Protection.

If you wish to contact us about any issue related to the collection, retention or processing of your personal data and your rights with regard to your data, you can contact us by email at: vocicontratempo@gmail.com