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Privacy Policy

1. Introduction

This Privacy Notice relates to the collection and further processing of personal data carried out in the context of the operation of the GAIA-X Accelerator platform, available at:  gaiax-accelerator.gr (hereinafter referred to as the “Platform“), implemented by the single-member limited liability company under the name “Information Society S.M.S.A.” (hereinafter referred to as “IS S.M.S.A.”).

Η Information Society S.M.S.A. in its capacity as Data Controller, guarantees respect for the privacy of natural persons and the protection of personal data processed during the operation of the Platform. In this context, IS S.M.S.A. considers the protection of the personal data of persons who visit and/or use the Platform as of paramount importance.

Full contact details of the INFORMATION SOCIETY ARE                      

IS S.M.S.A.– INFORMATION SOCIETY S.M.S.A.

Postal address: 194 Syggrou Avenue, Postal Code 17 671, Kallithea

Electronic communication: by filling in the relevant form at the link https://www.ktpae.gr

Contact telephone number: 213 1300700

Email of the Data Protection Officer: info@ktpae.gr

2.Definitions

“Personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.

“Controller”: the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the present Processing within the framework of the Platform’s operation, the Data Controller is defined as IS S.M.S.A., based on Article D1. par. 1 of Joint Ministerial Decision 1660/06.05.2025 “Amendment of Joint Decision No. 3345/2.6.2022 of the Ministers of Finance and State “Terms and conditions relating to the Action ‘Digital Transformation of Small and Medium-sized Enterprises’ (B’ 2798)” (Government Gazette B’ 2190), of the Ministers of Economy and Finance and Digital Governance.

“Processor“: the natural or legal person, public authority, agency, or other body that processes personal data on behalf of a controller. For the present Processing of the Platform, the Union of Companies of ERNST & YOUNG BUSINESS ADVISORY SOLUTIONS and “HELLENIC TELECOMMUNICATIONS ORGANIZATION S.A. (ΟΤΕ S.A.)” “Data Subject“: natural person for whom the controller collects and processes personal data. For the purposes of this Notice, data subjects are natural persons who submit a registration request in any capacity on the Platform (team members/representatives of SMEs, startups and business teams, mentors, market representatives), as well as users/administrators (admin, incubator, reviewer/evaluation committee members), hereinafter collectively referred to as “Users.”

“Consent” of the data subject”: any indication of intent, freely given, specific, explicit, and fully informed, by which the data subject indicates that they agree, by statement or clear affirmative action, to the processing of personal data concerning them. The consent of the data subjects is required and requested only in the context of receiving newsletters on issues related to the platform, such as, for example, sponsorships, activities, etc.

“Recipient“: the natural or legal person, public authority, agency, or other body to whom personal data are disclosed, whether a third party or not.

3. Personal data collected

IS S.M.S.A.. within the framework of the Platform’s operation, collects personal data from its Users to support businesses (SMEs, Startups, and Business Teams) in the creation of innovative tools.  In this context, the following personal data is collected through the Platform when the User registers:

  1. User Role (business representative, mentor, market/organization representative) during the first stage of registration;
  2. Application for participation by business representatives (SMEs, Startups, Business Teams) during the second stage of registration, as completed by their representative:
  3. Business representative details:
  • Full name;
  • Company name;
  • Contact phone number;
  • Email;
  • Short CV or LinkedIn profile link of the representative;
  • Role within the company;
  • Information regarding the source of information about the GAIA-X Accelerator;
  • Signature and date.
  1. Description of business idea/action (Name of idea/action, short presentation, sector of activity, maturity level of the idea/action, customer-related information, legal status of the company, and funding details);
  • Team/employee profile (Full name and email of team members/employees, roles of members/employees, relevant experience and previous activity of members/employees, information about potential skill gaps related to the implementation of the business idea);
  1. Other additional information the representative deems necessary to provide in the application.
  2. Application for participation by mentors:
    1. Mentor contact details (full name, contact phone number, email);
    2. Mentor professional details (company/organization they work for, company/organization website, position/role, brief description of main field of expertise, LinkedIn link, short description of professional background);
  • Experience and specialization in mentoring (areas in which the mentor wishes to offer guidance, previous experience);
  1. Availability (hours available for mentoring activity, possible conditions that may impede participation, such as conflict of interest, professional or personal circumstances that must be considered before assignment);
  2. Other details (reason for participating as a mentor, principles guiding the mentor’s role, source of information about the GAIA-X Accelerator).
  1. Application for participation by market representatives:
  2. Representative contact details (full name, contact phone number, email);
  3. Professional details of the representative (organization they work for, organization’s website, position/role in the organization, brief description of the main field of expertise);
  • Availability (hours available for advisory activity, possible conditions that may impede participation, such as conflict of interest, professional or personal circumstances that must be considered before assignment);
  1. Other details (reason for participating in the Program, source of information about the GAIA-X Accelerator).
  2. Information regarding the company’s location (country, city, etc.) during the third stage of registration;
  3. Username and password for User login, as well as OTP codes for registration confirmation;
  4. Areas of interest (e.g., areas requiring support, sector of business development, topics of interest for mentors) of the fourth registration stage;
  5. Documents to be submitted (from the second stage of registration, as well as the business plan) in the fifth registration stage;
  6. Details of administrators/incubators/reviewers (full name, email);
  7. Coach ID and team name;
  8. Newsletter consent details;
  9. Details of communications occurring within the Platform between Users;
  10. Application evaluation details for participation in the GAIA-X Program [the score (1–10) received by the application, as well as the reviewer’s signature];
  11. Platform trackers (e.g., cookies). For more information regarding the use of trackers, please see here.

4. Statistics and other information

IS S.M.S.A. further processes the above personal data to extract statistical data, evaluate the Platform and the overall “Development of Digital Products and Services” program, as well as to publish strictly necessary data for transparency and promotion of co-funded projects.

5. Sources of personal data

The data are collected from the Data Subjects themselves or from the business representative who fills out the relevant registration form.

6. Purpose of Personal Data Processing

The processing of personal data of Data Subjects within the operation of the Platform is carried out in order to:
a) Develop the “Development of Digital Products and Services” program;
b) Register Users on the Platform;
c) Promote and support the creation of innovative tools by participating companies;
d) Facilitate communication between companies and connect them with the market, under the guidance of a mentor;
e) Inform participating companies on topics related to the Platform and their activities (e.g., sponsorships, development programs, etc.) via newsletter.

The processing of personal data for the above purposes is necessary to fulfill the duty assigned to IS S.M.S.A.. in its capacity as Data Controller, for the achievement of public interest as derived from Joint Ministerial Decision 1660/06.05.2025 “Amendment of Joint Ministerial Decision 3345/2.6.2022 of the Ministers of Finance and State ‘Terms and regulations concerning the Action “Digital Transformation of SMEs” (B’ 2798)’ (Government Gazette B’ 2190/2025), by the Ministers of Economy and Finance and Digital Governance, in accordance with Article 6(1)(e) of the GDPR.
With regard to informing Users (via newsletter), this takes place only with their consent, in accordance with Article 6(1)(a) of the GDPR.

7. Transfers of personal data

The data are stored in the Government Cloud (G-cloud) of the Hellenic State via Microsoft Azure. All infrastructure is hosted in certified data centers within the European Union, specifically in the North Europe region (Ireland) and the West Europe region (Netherlands).
There is no transfer of personal data to third countries outside the EU/EEA.

8. Data retention

the purpose of protecting the public interest.

9. Rights of Data Subjects

IS S.M.S.A.. in full compliance with GDPR provisions, facilitates the exercise of all rights provided by the GDPR to Data Subjects when using the Platform. Specifically, each Data Subject has, subject to legal conditions, the right to request:

  • Access to personal data processed by IS S.M.S.A.;
  • Rectification of personal data (verification of accuracy and submission of corrected data if incomplete or inaccurate);
  • Erasure of personal data, under certain conditions;
  • Restriction of processing;
  • Objection to processing;
  • Data portability (provision of data to the Data Subject or a chosen third party in a structured, commonly used, machine-readable format);
  • Withdrawal of consent at any time, when processing is based on consent (withdrawal applies only for the future).

Requests related to these rights are examined within one (1) month of receipt. This period may be extended by two (2) additional months if the request is complex or if many requests are pending.

Data Subjects may submit their requests to the Data Protection Officer (DPO) of IS S.M.S.A. at:
Email: dpo@ktpae.gr
Phone: +30 213 1300700

10. Right to lodge a complaint with the Hellenic Data Protection Authority

Data Subjects have the right to lodge a complaint with the Hellenic Data Protection Authority (“HDPA”) concerning matters related to the processing of their personal data. Information regarding the Authority’s competence and complaint submission procedure is available on the HDPA website: www.dpa.gr.

Version: November 2025