PRIVACY POLICY FOR THE BEST START APPLICATION

This document is aiming to provide all useful, but also necessary, information regarding the collection and processing of personal data during the installation, use and uninstallation of the Best Start application. Through this document, the data subject can be informed about all issues related to the processing of personal data within the Best Start app.

1. Who is the controller?

The Best Start application has been created on behalf of the Non-profit Organization FAINARETI, which acts as the controller for the collection and processing of personal data through the application.

FAINARETI was founded in 2006 with the aim of research and intervention for the promotion of women's and family health in Greece. Its main objective is the study, design and development of programs and actions of all kinds to promote the care and support of the pregnant woman, the new mother of the newborn and the family.

The contact details of FAINARETI, through which the user can contact it, are:

α. Postal address: 2 Korai & Omirou, Nea Smyrni, P.O. Box 11721

β. Telephone: 210-9319054

c. E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

For the best response to questions and requests, it is also recommended to contact the Data Protection Officer (DPO) of FAINARETI at the following e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it.

2. What are the purposes and legal basis of the data processing?

The Best Start app has been created to serve as an information tool on perinatal, neonatal, infant and maternal health issues. The purpose of the application is to share the scientific knowledge and experience of FAINARETI, as it has been acquired through its many years of activity.

In this context, Best Start is installed and used for free, without any charge to the user or any obligation to participate in the programs of FAINARETI. Through the application, the user can find useful information material for the case he/she is interested in, but also keep a personal file/diary on the issues that concern him/her.

In order to install and use Best Start, it is necessary to accept the terms of use and create a user account, using an email and password. No other information is required for the user to access the application material.

After creating an account, the user has the option to add personal information and enter personal notes, to which FAINARETI does not have access.

The legal basis for the processing of personal data is the execution of a contract, as it consists in the acceptance by the user of the terms of use of the service and the provision by FAINARETI of the informative content of the application. Based on the nature of Best Start, which is addressed to people interested in issues related to the prenatal or postnatal stage of a pregnancy, it is presumed that the use of the application alone may disclose health data of the user. In this context, the processing of such data is allowed, in accordance with the exceptions of Article 9 of the GDPR, on the basis of the express consent of the user, as provided at the account creation stage.

In the context of providing the services and performing the contract, FAINARETI may use the user's email address to send additional information material regarding its actions. This promotional communication is legalized, according to article 11 paragraph 3 of Law 3471/2006, in the collection of the contact data acquired during the creation of the account, provided that the user does not object to it by selecting the relevant opt-out option provided in a clear and explicit manner.

3. Which personal data are collected

The personal data that are collected during the installation of the application and the creation of an account are the user's email address and the password created by the user.

After account creation, the personal data collected optionally are personal information that the user can add to his/her account, such as name, height, weight, social security number and date of birth. Moreover, also optionally, the user has the possibility to keep personal notes on issues of concern or interest to him/her.

When using the application, general information (data logs) are collected, such as:

● Mobile phone device data, operating system, language, browser type and version, internet protocol address (IP - address), technical data, which are collected to support the operation of the application.

● Usage data, such as date and time of entry into the application, behavioral data (opening of information material) and request data such as date and time of request, content of request, which are collected to support the use of the application and the enrichment of the provided material.

These data, with the exception of request data, are not associated with personal information held on the device and are anonymised data. The request data are associated with the account identifiers (user email) and are kept for the purpose of proving the exercise and satisfaction of requests of the General Data Protection Regulation.

It should be noted that FAINARETI does not want to know the personal data entered in the application, so it does not have access to them, with the exception of the user's identifiers (email - password), which are necessary to ensure access to the account. In addition, FAINARETI does not carry out any act of correlation of these data with data already kept in its files and no act of profiling of the users of the application.

4. Who are the recipients of the data

The personal data collected through the application are managed by VIDAVO S.A., which acts as the processor on behalf of FAINARETI. VIDAVO is the company that has developed Best Start and is responsible for the technical support of its operation. Apart from VIDAVO, users' personal data are not disclosed or transmitted to third party recipients.

5. The data retention period

The personal data collected through the application are kept for as long as the user maintains his account. The user of the application has at any time the possibility to choose the deletion of his account, which automatically leads to the deletion of the personal data related to this account.

It should be noted that simply uninstalling the application does not constitute account deletion, nor does it result in the deletion of data, as its effects are reversed any time the user decides to reinstall the application and log in to his/her account.

In any case, the personal data collected through the application will be automatically deleted after six (6) months from the last login of the user to his/her account.

6. The rights of the user - data subject

The user of the application is the data subject of the data collected through its installation and use. For these personal data, the user has the rights of the General Data Protection Regulation (GDPR), which can be exercised as appropriate, either through the relevant option provided by the application, or by submitting a request to FAINARETI.

These rights are:

a. Right of access. The right of access includes the right to obtain a copy of the information held, which can be exercised and satisfied through the application.

b. Right of rectification. This right is exercised through the options to modify/complete the user's personal information through the application.

c. Right of erasure: It is the right of the user to request the deletion of his/her data. The deletion of data is exercised through the application, either by deleting specific information that the user has entered, or by using the "Delete account" option provided to the user.

d. Right to lodge a complaint to the supervisory authority.

The competent supervisory authority is the Authority for the Protection of Personal Data (1-3 Kifissia Street, 115 23 Athens, Greece).

https://www.dpa.gr/el/polites/katagelia_stin_arxi

Please note that, for the best possible fulfilment of any request or right, it is preferable to make a prior request to FAINARETI, as otherwise, the competent authority may reject the complaint for failure to follow due process.