Platform privacy policy
The company ADACOM ADVANCED INTERNET APPLICATIONS ΣΙΝΓΛΕ ΜΕΜΒΕΡ S.A. with the distinctive title “ADACOM S.A.” located at 25 Kreontos Street, Athens, P.C. 10442 (hereinafter “ADACOM”, “Company” or “We”) has as its main priority the protection of the personal data it processes. The Company collects, maintains and processes personal data in accordance with the Regulation (EU) 2016/679 (hereinafter "General Data Protection Regulation - GDPR") and the Greek legislation on personal data protection. This Privacy Policy describes the manner in which personal data are processed during the use of the website and the platform services described herein, the purposes of such processing and their use, as well as your related rights under the applicable legislation.
The Controller of your personal data, within the meaning of the GDPR, is ADACOM.
1. Definitions
The following definitions are provided for the convenience of the user and are derived from the text of the GDPR on the processing of personal data:
- “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
- “processor”: the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
- “personal data”: any information relating to an identified or identifiable natural person (‘data subject’); 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”: 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, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
2. Categories of personal data
At ADACOM we collect only the absolutely necessary data, which are appropriate and clear for the purpose for which they are intended. The data include the following:
Data of our customers' executives, suppliers and partners and data processing in the context of implementing projects and providing services:
In the context of our cooperation with our customers and suppliers, we may be provided by them with information about their executives, such as their full names, contact details and position or role of their executives, for the purpose of executing the contract between us, managing projects or the provision of services that we jointly implement. In addition, in the context of project execution, the Company may process personal data to the extent required for the provision of services, as agreed and described in the Personal Data Processing Agreements with the client.
Data when creating a user account on the platform
If you choose to create a user account on our platforms, we collect your full name and email. Moreover, depending on the platform/service you use, we collect:
- CyberGame (Training Platform): prrogress data (scores, completed labs, performance metrics) and technical data (IP address, system logs, session data);
- CyberHygiene (Awareness Questionnaires): questionnaire responses (stored in anonymized form, without linkage to identifiable individuals)
3. Purpose of processing of personal data
The collection and processing of personal data is carried out exclusively to the extent and degree necessary for the performance of the following processing purposes, as the case may be:
- To provide access to the CyberGame platform and manage user accounts
- To deliver and evaluate training activities, including tracking progress and performance
- To provide access to CyberHygiene questionnaires and analyze results in anonymized form
- To improve the quality and effectiveness of training services
- To ensure platform security, prevent misuse, and detect unauthorized access
- To provide technical support and respond to user requests
- To comply with legal obligations and enforce our legal rights
4. Recipients of the data
Access to the personal data processed by ADACOM is granted to the Company’s specifically authorized personnel, who are bound by confidentiality obligations, as well as, where required, to personnel of companies within the same group and/or external partners, depending on the nature and purpose of the processing, always in accordance with the requirements of the applicable personal data protection legislation.
In principle, we do not transfer any personal data outside the European Economic Area (EEA). If, for any exceptional reason, we need to transfer your personal data outside the EEA, we will do so only in accordance with appropriate requirements and safeguards and only to recipients that ensure an adequate level of protection of personal data and in any event in accordance with the provisions of Articles 44-49 of the General Data Protection Regulation [Regulation (EU) 2016/679 (GDPR)].
5. Lawfulness of processing
The Company processes your personal data as described above per case by virtue of:
- your consent to the processing of your data for one or more specific purposes (Art. 1 (a) GDPR).
- a contract and/or agreement you have entered into with the Company to serve the purposes of that contract/agreement (Art. 6 para. 1 (b) GDPR).
- the purposes of complying with its legal obligations (e.g. in case of compliance with warrants issued by courts or public authorities, etc.) (Art. 1 (c) GDPR).
6. Cookies
ADACOM may also collect information about you when you visit our websites using cookies. Cookies are small text files that are stored by the browser on your computer or mobile device when you visit a website. Cookies allow web applications to tailor their functions to your needs by collecting and remembering information about your preferences.
What are cookies?
Cookies are small text files that are stored by your browser on your computer or mobile device when you visit a website. The information stored on your computer may contain information about your use of the websites you visit, the date and time of your visit, the type of your browser, a random and unique user identification number etc.
Cookies are widely used to make websites work better and more efficiently. The latter is achieved because websites can store and read useful information so as to provide each user with the best possible browsing experience. In addition, through cookies we can see the performance and traffic of our website, improving its presentation and content according to the preferences of our visitors.
Which Cookies we use?
Below you can find a more detailed overview of the categories of cookies we use and for what individual purposes:
- Strictly necessary cookies which are essential for the proper operation of the website, the management of login sessions, and the safeguarding of session integrity, and which enable you to browse and use its features, such as access to secure areas. Without these cookies, the website cannot function effectively and, for this reason, they are enabled by default. Necessary cookies do not individually identify the user.
How to manage Cookies
When visiting our website for the first time, a banner appears on the lower part of the screen which informs that our website uses cookies. The banner provides a link for further information. If the user chooses to ignore the notice and continues using the website, ADACOM will not store a cookie on the hard disk of the user’s computer to register the choice, and upon the following visit to the website, the approval to the use of cookies will be asked again. Only in case of acceptance the banner will not appear when visiting the website again, without prejudicing the possibility of deleting the cookies at any time, changing the settings of the browser.
Besides the technical necessary cookies which are mandatory, all other categories require your consent prior to use. Therefore, these categories are not pre-selected and you may freely choose any category you wish in any level of cookies analysis you opt for.
Also, you may change your browser’s setting to delete cookies that have already been stored and to not accept new cookies. To learn more how to do this, visit the help pages of your browser.
7. Retention period of personal data
Your personal data is retained for the period of time provided for by the applicable legislation and for as long as there is a need to carry out actions necessary to achieve the purpose(s) of the processing. At the end of this period, your personal data will be securely deleted.
Data of ADACOM's customers and partners regarding the implementation of projects and the provision of services/products:
Personal data may be processed during the provision of our services, which will be deleted within a reasonable time after the completion of the delivery of services, unless otherwise contractually agreed or unless a longer retention period is required or permitted by law..
8. Your rights
ADACOM facilitates the management of your personal data and the exercise of your rights in accordance with the applicable national and European legislation. In particular, your rights are the following:
Right of Access: You have the right to be informed by our Company whether we process and maintain your personal data. If the answer you receive is affirmative, you may submit a request to obtain information about the processing, its purpose, the type of data, the recipients of your data, the period of retention, the existence of automated decision-making, as well as the possibility of exercising your other rights, such as rectification, erasure, restriction of processing, opposition to the processing carried out, lodging a complaint to the relevant Data Protection Authority and so on.
Right to Rectification: You have the right to request the rectification of inaccurate or incomplete personal data.
Right to erasure: Furthermore, in the event that the data we hold is no longer necessary for the purposes for which it was collected or in the event that your consent is withdrawn or, in general, if there are no longer legitimate reasons for maintaining them, you may request their erasure.
Right to restriction of processing: Where the cases of Article 18 of Regulation (EU) 679/2016 on the protection of personal data apply, you can request the restriction of processing.
Right to data portability: You may request to receive your data in a readable format or transfer your data to another controller in case this is feasible.
Right to object: You can object to the processing of your data and request its termination. Your request may be refused by the controller in the event that there are demonstrable legitimate grounds for processing that override your right to object.
Right to revoke your consent: In the event that your data is processed on the legal basis of your consent, you can revoke it at any time in order to stop the processing of data carried out on the basis of it.
You may submit your request by sending an email to [email protected] or by post to the address given below. ADACOM will respond to your request, depending on its merits, within 30 days. If for any reason we refuse to comply with your request, we will provide you with a detailed and reasoned response.
Finally, if you believe that your rights have been violated, you have the right to lodge a complaint to the relevant Data Protection Authority at the following details: Address: 1-3 Kifissias Avenue, Athens, P.C. 11523, Contact Phone: 210 6475600, Email: [email protected]
9. Data security
ADACOM implements all appropriate technical and organizational measures to ensure the protection of your personal information. We use sophisticated technologies and security procedures to protect your personal information from unauthorized access, use or disclosure. The personal information you provide is stored in a controlled, secure environment, protected from unauthorized access, use or disclosure. Moreover, our information security procedures are audited annually by an internationally recognized auditing company.
10. Links to other websites
Our website may contain links to other websites of interest. However, when you use these links and leave our site, you should note that we have no control over other sites you visit. Therefore, we cannot be responsible for the protection and privacy of the information you provide when you visit them as these sites are not governed by this Privacy Statement and are outside the sphere of ADACOM's responsibility. You should be careful and read the privacy statement for the protection of personal data applicable to that site.
11. Protection of minors
ADACOM is committed to protecting the privacy of children. Our website does not address or knowingly collect information from children under the age of 18. In the event that we determine that we have collected personal information from a child without verified parental consent, we will delete that information as soon as possible.
12. Changes to this Privacy Policy
ADACOM may modify this Privacy Policy, including the terms for coockies use, as well as its related practices at any time. We encourage you to periodically check this page for the most current information about our privacy practices. This Privacy Policy was updated on May 7th, 2025.
13. Contact Information
There are the following options if you wish to contact us, make a complaint or manage your account details:
- You can send us your request in writing to the following postal address: Kreontos Street 25, P.C. 10442 Athens, Greece.
- You can call us at: + 30 2105193700
- You can send an e-mail to: [email protected]