1 Our Privacy Promise

We aim to create a culture where everyone at Vodafone has a clear understanding of how important privacy is and how to ensure it is respected. Our Privacy Promise sets out the principles that govern our approach to privacy and how we communicate with employees, partners and other stakeholders on relevant issues – such as designing products to protect privacy or assisting with law enforcement.

1.1 Principles

Vodafone’s privacy principles are:

How we operate

• Accountability: we are accountable for living up to these principles throughout our corporate family, including when working with our partners and suppliers. We have in place accountable privacy compliance measures and we monitor and enforce our compliance with these principles.
• Fairness and lawfulness: we comply with privacy laws and act with integrity and fairness. We will work with governments, regulators, policy makers and opinion formers for better and more meaningful privacy laws and standards.
• Openness and Honesty: we communicate clearly about actions we take that may impact privacy, we ensure our actions reflect our words, and we are open to feedback about our actions.
• Choice and access: we give people the ability to make simple and meaningful choices about their privacy and allow individuals, where appropriate, to access, update or delete their personal information.

How we manage and protect information

• Responsible Data Management and limited disclosures: we apply appropriate data management practices to govern the processing of personal information. We choose the partners who participate in processing of personal information carefully and we limit disclosures of personal information to such partners to what is described in our privacy statement or to what has been authorized by our employees.
• Security safeguards: we implement appropriate technical and organisational measures to protect personal information against unauthorized access, use, modification or loss.

How we design our products and services

• Privacy by Design: respect for privacy is a key component in the design, development and delivery of our products and services.

How we make decisions

• Balance: when we are required to balance the right to privacy against other obligations necessary to a free and secure society, we work to minimize privacy impacts.

2 Who we are

Vodafone-Panafon Hellenic Telecommunications Company S.A is the Data Controller of your personal data. We are a member of Vodafone Group and, among others, we manage HR operations, including the processing of personal data about the employees and candidate employees to the Vodafone Company.

Our registered office is at Halandri, Attica, Greece. We provide more details of how to contact us in the How to contact us section of this privacy statement.

3 Definitions

In this privacy statement:

• “we/us” means Vodafone-Panafon Hellenic Telecommunications Company S.A. (“Vodafone Greece”);
• “third party” means someone who is not you or us or a part of Vodafone Group; and,
• “Vodafone Group” means Vodafone Group Plc and any company or other organisation in which Vodafone Group Plc owns 50% or above of the share capital.

4 The Basics

4.1 Personal information we collect about you

4.1.1. Vodafone will process your personal information based on:

1. Taking measures, which are necessary for entry into, or the performance of a contract, we may ask you to provide personal data that is required to enter into an employment contract with Vodafone you are applying to.
2. Compliance with the law, where certain information is necessary to satisfy a legal or regulatory requirement.

4.1.2. How we collect personal information about you

We collect personal information about you when you register a general interest in careers on Vodafone’s website or when you apply for a specific role at Vodafone. Some of the information we collect about you is required to make an assessment on your application to Vodafone and contact you about your progress through the recruitment process, for example your telephone number, email address, CV. If you do not provide this information, then we will be unable to assess your application or contact you to invite you to interview or make you an offer.

We may collect information about you from other sources as well, such as recruitment agencies or from social media platforms used for business purposes, such as LinkedIn and contact you about suitable roles or evaluate your application for a specific role at Vodafone.

4.1.3. The types of information we may collect about you are, for example:

1. Personal details, such as name, personal email address, current address, telephone number.
2. Recruitment information, such as application form (in electronic or printed form), CV, résumés, interview notes of successful and unsuccessful candidates, video interviews, references from previous employer, psychometric test results.
3. Internal candidate information, such as references given by Vodafone, interview notes, internal transfer or promotion, succession-planning documents.
4. Identification information, such as proof of identity.
5. Authentication information, such as username for the recruitment portal.
6. Information collected through Cookies.

4.2 How we use information about you

We may process the personal information that we collect about you for the following purposes:

• Recruiting people into jobs, the information we collect about you will be shared with Vodafone you are applying to in order to assess and progress your job application and to make any verifications required by local law. If you apply for more than one vacancy, your information will be shared accordingly.
• Resourcing for jobs, if you register a general interest in pursuing a career with Vodafone, the information we collect about you will be retained by us and searched by people who are employed by Vodafone to help us fill future vacancies. If you apply for a specific vacancy and you are unsuccessful, the information we collect about you will be retained so that we can consider you for future suitable vacancies.
• Contacting you about other roles, where we have collected your consent to do so.
• Analytics, we may use some of the personal information you provide for various purposes including, for example, the volumes of applications made to Vodafone and related trends – you will not be personally identified from these reports.
• Screening, in certain circumstances, we will make an automatic decision on the suitability of your application based on certain criteria. For example, graduates must be proficient in English and have completed a university degree to be considered for a role at Vodafone. We will bring this to your attention wherever we collect personal information to make an automatic decision about you and you can contest a decision by exercising your rights.
• We may collect information through technical solutions, such as cookies, in order to understand how you use the careers section of the website and how we can improve your experience, where we have your consent to do so.

4.3 Who we share information about you with

We may share personal information about you with:

• Other companies in the Vodafone Group, which will process your personal information solely and only, for the purposes in section 4.2.
• Third parties, such as recruitment agencies, test providers and others who help us fill vacancies and assess the suitability of candidates and progress applications. Where we use third parties, Vodafone ensures that there is a written agreement and that they meet the same privacy and security standards as Vodafone.
• Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law.
• A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

4.4 Where we process information about you

In doing the above, we may need to transfer personal information about you to other companies in the Vodafone Group or third parties located (or whose servers may be located) in countries outside of the country where you have applied, including countries outside of the European Economic Area (EEA). If we send personal information about you to a country that is not in the EEA, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organisational measures to protect your personal information.

4.5 How long we keep information about you

We will keep your information in electronic or printed form for as long as it is necessary for the recruitment process. If you are successful, we will keep your information for the duration of your employment and for a period of time after its termination in accordance with Vodafone’s Policy, should you wish to apply for other roles within Vodafone. If we are not able to offer you a role, we may keep your information for up to 2 years to contact you about future roles that may interest you.

5 Your Rights

• Right to rectification or update information: you have the right to rectify or update the personal information we process about you, if it is not accurate. If the information we process about you needs updating, or you think it may be inaccurate, you may request their update by contacting us at AskHR.
• Right to access: you have the right to request a copy of the personal information we process about you. You can request a copy of your personal information by contacting us at AskHR.
• Right to object: you have the right to object to the processing of your personal information where we rely on our legitimate interests to do so for example, when we conduct analytics, through which you may be identified. Your objection will be assessed on the basis of our legitimate interests for processing. You may contact us at AskHR.
• Right to erasure: in certain circumstances, you may have the right to request that we erase the personal information we process about you.
• Right to restriction of processing: if you feel the personal information we process about you is inaccurate or believe we should not be processing your personal information, you may have the right to ask us to restrict processing of that information. You may contact us at AskHR.
• Right to data portability: in certain circumstances you will have the right to take the personal information you have provided to us with you. You can request a copy of your personal information by contacting AskHR.

You can exercise any of the above mentioned rights by sending an email to askhr.gr@vodafone.com. You can expect a reply to such a request within one (1) month following its receipt by Vodafone and in any case, within two (2) months, depending on the complexity of your request or the high volume of requests received.

6 Changes to Privacy Statement

This privacy statement is updated from time to time, so we would encourage you to check it regularly on your local policy portal. If we make a major change, we will let you know by email.

7 How to contact us

In case you have further questions about this privacy statement or how we process your information, please contact the Data Protection Officer of the company,

C/O Data Protection Officer, Tzavella 1 – 3 Str., Halandri, Attika, | e-mail: data.privacy.gr@vodafone.com.

8 Right to lodge a complaint

In case you deem that we have not sufficiently satisfied your request and the protection of your personal data is affected somehow, you may lodge a complaint through a special web portal with the Personal Data Protection Authority (Athens, 1-3 Kifissias Avenue, PC 115 23 | tel: +30 210 6475600). Detailed instructions for submitting a complaint are provided on the Authority’s website.