1          INTRODUCTION

SAINT GOBAIN HELLAS - AUTOVER is committed to protecting the privacy and security of personal data of its employees.

The Privacy Policy describes how we collect, use and maintain personal information regarding you and your employment relationship with the Company during its recruitment, employment and termination, in accordance with the General Data Protection Regulation (GDPR) and the institutional framework of personal data protection in Greece (Law 4624/2019) as well as relevant decisions and opinions, annual reports and press releases of the Personal Data Protection Authority of the Hellenic Republic.

It applies to all employees who have an employment relationship with the Company.

The purpose of this policy is to provide information to future, current and former employees of the Company regarding the retention of personal data concerning them.

Personal data are defined as information concerning a natural person and make it possible to identify him / her.

2          WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA

Elias Katopodis situated in Athens, is responsible for the processing of personal data concerning you.

3          PRINCIPLES GOVERNING THE PROCESSING

The protection of personal data is very important for SAINT GOBAIN HELLAS - AUTOVER. We ensure full compliance with the applicable Legal Data Protection Framework, including the General Data Protection Regulation (GDPR) and Law 4624/2019 and process personal data in accordance with applicable basic principles. In this context, we ensure that your personal data:

(a) undergoes lawful and lawful processing in a transparent manner in relation to the data subjects.

(b) is collected for specific, explicit and legitimate purposes and are not further processed in a manner incompatible with those purposes.

(c) is appropriate, relevant and limited to what is necessary for the purposes for which they are processed.

d) is accurate and, where necessary, up to date.

(e) is kept in a form which allows the identification of data subjects only for the period required for the purposes of the processing of personal data.

(f) is processed in such a way as to guarantee the appropriate security of personal data, including their protection against unauthorized or unlawful processing, and accidental loss, destruction or damage, by taking appropriate technical and organizational measures.

g) Provides future, current and former employees with access rights to their files; and

(h) is not transmitted to a country or territory outside the European Economic Area.

4          ON WHICH LEGAL BASIS DATA PROCESSING IS BASED

The processing of Employees' data by SAINT GOBAIN HELLAS - AUTOVER is based on one (or more) of the following legal bases:

• Contract: processing is necessary to execute the employment contract or to take action at your request prior to the conclusion of the contract.

• Legal obligation: processing is necessary to comply with the obligations imposed on us by law (not including the obligations under the employment contract). For example, we have a legal obligation to collect and disclose employee data to tax authorities.

• Legal interests: the processing is necessary for the pursuit of the legal interests of SAINT GOBAIN HELLAS - AUTOVER or the legal interests of a third party, unless the interests of the Employee prevail over these interests.

• Obligation or right under labor law and social security and social protection law: the processing of special categories of data of the Employee is necessary for the execution of the obligations and the exercise of specific rights of the Employee or SAINT GOBAIN HELLAS - AUTOVER in the field of labor law and social law and social protection, subject to the law.

• For the establishment, exercise or support of legal claims: the processing is based on our right to seek satisfaction of legal claims.

• Consent: except in cases where required by law or when none of the other legal bases apply, SAINT GOBAIN HELLAS - AUTOVER will legally process the data with the explicit and written consent of the Employee, which will be distinguished from the employment contract. Consent will be provided upon informing the Employee. The Employee will be able to choose freely and voluntarily provide his consent and will be able to withdraw it at any time without adverse effects.

5          WHAT DATA ARE WE PROCESSING?

During the recruitment process

SAINT GOBAIN HELLAS - AUTOVER during the recruitment process either through an advertisement or in collaboration with a job search service provider collects exclusively personal data from the candidate employee, which he / she discloses to us, such as his / her personal details, contact details, information regarding his / her marital status, his training and work experience for the purpose of his job evaluation.

In case the candidate's application is unsuccessful, the above personal data and any CV are kept for a period of one year, in case there is a need to fill the same job again, then they are automatically destroyed, unless otherwise provided by law.

Categories of personal data throughout the duration of employment

SAINT GOBAIN HELLAS - AUTOVER collects directly from its employees the following categories of data of its employees:

- Identification of the Employee (name, surname, name and surname of parents, date and place of birth, gender, nationality, identity card or passport or residence permit, document number and issuing authority, work permit)

- Contact details (address, phone, email)

- Information necessary to fulfill the obligations of the clinic before tax authorities, social security funds and bodies for the protection and benefits to employees and the unemployed (tax registration number, social security registration number, IKA registration number or other fund number, number unemployment and receiving unemployment benefit)

- Information about the marital status of the employee (married / unmarried, number of children)

- Information necessary for the payment of the employee's salary (bank account, number of working days and hours / leave, reasons for leave, medical certificates in case of sick leave, pregnancy or maternity leave)

-Information about the training and professional experience of the employee (e.g., previous work experience, years of service, academic degrees, certifications, seminars, knowledge of foreign languages, knowledge of computer programs)

- The IT Security Officer also has access to all the corporate e-mails that have been provided to the employees, as well as to the computers. The use of the internet and all electronic means of communication for the personal use of employees is prohibited.

6          WHO RECEIVES AND PROCESSES THE DATA

Within SAINT GOBAIN HELLAS - AUTOVER other employees have access to your data. Access is graded according to their position and tasks and is limited to the data that is necessary for the purposes of the specific processing they have undertaken.

Apart from SAINT GOBAIN HELLAS - AUTOVER, IT Security Officer has access too, as well as the manning agent(s).

Your data can also be transmitted:

- to national or international regulatory, tax or other authorities or public bodies or courts, when required by law or regulation or by lawful mandate

- to customers and / or partners when required to communicate, manage relationships and execute requested transactions

7          TIME OF RETAINING PERSONAL DATA

The above personal data is kept throughout the duration of employment. In case of termination in any way of the employee's employment relationship with SAINT GOBAIN HELLAS – AUTOVER, the above personal data (including payment receipts, OAED employee contract termination forms or form voluntary departure of an OAED employee) will remain in the Company under legislation for a period of six months to 20 years depending on the documents and for the purposes of control of the Tax Authority, Administrative or Judicial Authority, Insurance Organization in accordance with the respective legislation.

8          DATA SUBJECTS’ RIGHTS MANUAL

1. Right to information: You have the right to know what personal data we store. This allows you to understand how we use your personal data.

2. Right of access: You have the right to access your personal data. This allows you to know and verify the legality of the processing.

3. Right of Correction: You have the right to request a correction of the personal information we hold about you. This allows you to correct any incomplete or inaccurate information we have about you.

4. Right to erase (Right to be forgotten): You have the right to ask us to delete or remove personal information when there is no legal reason to continue processing it and due to your assistance in the face of a particular situation. Note that this right does not constitute an absolute "right to be forgotten".

5. Right to restrict processing: You have the right to request a restriction on the processing of your personal information. This allows you to ask us to restrict the processing of your personal information if, for example, you want to verify the accuracy of your personal data or the reason for the processing.

6. Data transfer right: You have the right to receive and reuse your personal information for your own purposes. This allows you to retrieve your data in a widely used and machine-readable structured format (i.e., a data format that can be read and processed automatically by a computer, for example CSV, JSON and XML data formats - excluding documents PDF and scanned images).

7. Right to object: You have the right to object to the processing of your data.

8. Rights related to automated decision making, including profiling: You have the right to object to profiling and automated decision making under certain conditions.

SAINT GOBAIN HELLAS - AUTOVER respects the rights you have to your personal data and facilitates your exercise. You can address any request, question or complaint regarding your personal data by contacting the via email at ilias.katopodis@saint-gobain.com.

We will respond to your request within thirty (30) days of receipt. In case an extension of the above deadline is required for the investigation and / or processing of the request we will inform you about it, explaining to you the reasons why the extension of the deadline is necessary.

SAINT GOBAIN HELLAS - AUTOVER will satisfy your request according to the conditions set by law. The possibility of exercising a right granted to you by law does not always imply the possibility of being fully satisfied, especially when there are other legal provisions that limit it. If we are not able to satisfy your request, we will inform you of the reasons.

In any case, if you feel that the protection of your personal data has been violated in any way, you have the right to appeal to the Personal Data Protection Authority. For the competence of the Authority and the way submission of a complaint, detailed information is provided on the website of the Personal Data Protection Authority (www.dpa.gr)

The policy is reviewed and revised periodically, where required, in accordance with the applicable Legislation, Circulars and Decisions of the Personal Data Protection Authority.