PRIVACY AND PERSONAL DATA PROTECTION POLICY

Last update: 18/7/2026

1. Introduction

The protection of your personal data is an important priority for us.

This Privacy Policy describes how we collect, use, store, transfer and protect the personal data of visitors and users of the "Smart Development of Egaleo" website, as well as of persons who:

• communicate with us,
• request information about our services,
• express interest in educational or therapeutic programs,
• fill out an electronic form,
• subscribe to our newsletter,
• interact with our social media pages.

This Policy applies to the website:

smartgrowthaigaleo.gr

as well as to any other email addresses that redirect to the same website or are officially used by Smart Development of Egaleo.

The processing of personal data is carried out in accordance with:

• Regulation (EU) 2016/679 – General Data Protection Regulation, known as the «GDPR»,
• Law 4624/2019,
• Law 3471/2006 on the protection of privacy in electronic communications,
• the Greek and European legislation in force at any time.

2. Data Controller

The controller of personal data is:

Legal name: Smart Development Egaleo O.E.

Distinctive title: Smart Development of Egaleo

Legal representative / Responsible: Maro Giannaki

Seat: Valtetsiou 11, Egaleo, P.C. 12243, Attica

VAT number: 802915603

Tax Office: KETODE OF ATTICA

Phone: 211 008 5658

Mobile 1: 693 746 5519

Mobile 2: 695 509 2075

Contact email: smartgrowthaigaleo@gmail.com

For issues concerning the protection of personal data and the exercise of your rights, you can contact the above email address, indicating in the subject of the message: "Personal Data".

3. Who is the website aimed at?

The website is primarily aimed at parents, guardians and other adults interested in our educational, support or therapeutic services.

The contact forms and the newsletter subscription form are intended for use by adults.

Minors should not send us personal data or subscribe to the newsletter without the information and, where required, the consent of their parent or legal guardian.

4. What personal data do we collect?

Depending on how you use the website or communicate with us, we may collect the following categories of data.

4.1 Contact details

When you contact us via form, email, telephone or other electronic means, we may collect:

• full name,
• email address,
• phone number,
• status, such as parent or guardian,
• content of a message or request,
• preferred method and time of communication,
• date and communication history.

4.2 Data regarding interest in services

When you request information about a service or program, we may collect:

• the service or program you are interested in,
• the child's age or school level,
• general information about educational or support needs,
• desired days or times,
• information necessary for scheduling a meeting or assessment.

Please do not enter detailed medical diagnoses, opinions, test results or other sensitive data in simple communication forms, unless this is absolutely necessary and you have been asked to do so by an authorized professional.

4.3 Special categories of data

Due to the nature of our services, such as speech therapy, occupational therapy, special education and sessions with specialists, it may, at a later stage and not necessarily through the public website, be necessary to process data relating to:

• health,
• development,
• the learning situation,
• therapeutic or educational assessments,
• opinions,
• information about special educational needs.

This data constitutes special categories of personal data and is protected by increased security and confidentiality measures.

Their processing is carried out only when necessary and when there is an appropriate legal basis, such as:

• the express consent of the parent, guardian or other legal representative,
• the provision of health services, treatment, diagnosis or support by professionals bound by professional secrecy,
• compliance with a legal obligation,
• the establishment, exercise or support of legal claims.

For data processing carried out in the context of the provision of educational or therapeutic services, separate, more specific information may be provided to the parent or guardian.

4.4 Newsletter data

When you subscribe to our newsletter, we may collect:

• your email address,
• your name, if requested,
• the date and time of registration,
• the technical IP address from which the registration was made,
• proof of your consent,
• your communication preferences,
• information about message delivery,
• information about opening or selecting links in newsletters, if relevant technologies are used and permitted by your consent choices.

4.5 Technical and navigation data

During your visit to the website, the following may be automatically collected:

• IP address,
• date and time of access,
• device type,
• operating system,
• browser type and version,
• browser language,
• pages you visited,
• residence time,
• previous website or source of visit,
• technical log files – server logs,
• cookie identifiers or similar technologies, depending on your choices.

4.6 Social media data

If you contact or interact with us through Facebook, Instagram, TikTok, YouTube or another social network, we may have access to:

• your public name or username,
• your profile photo,
• the content of your message or comment,
• information you have chosen to be public,
• information about your interaction with our page.

Data processing by the social networking platforms themselves is also governed by their own privacy policies.

5. How we collect data

We collect personal data:

• directly from you,
• when you fill out a form,
• when you subscribe to the newsletter,
• when you send us an email,
• when you contact us by telephone,
• when communicating via social networks,
• when you visit or use the website,
• by a parent, guardian or legal representative,
• by partners or professionals, only when there is a legal basis and relevant authorization.

We do not intentionally collect more data than is necessary for the purpose.

6. Purposes and lawful bases of processing

6.1 Responding to contact requests

We process your data for:

• to answer questions,
• to provide information,
• to communicate with you,
• to schedule a meeting or assessment.

The lawful basis is to take steps at your request prior to entering into a contract, as well as our legitimate interest in organizing and managing communication with interested parties.

6.2 Provision of educational or therapeutic services

We process the necessary data for:

• enrolling in a program,
• the provision of services,
• scheduling courses or sessions,
• communication with parents and guardians,
• monitoring the service provided,
• financial and administrative management.

The legal basis is the performance of a contract, the taking of pre-contractual measures, compliance with legal obligations and, where required, consent.

6.3 Sending newsletters and information messages

If you subscribe to the newsletter, we use your email to send you updates about:

• new programs,
• educational or therapeutic services,
• actions,
• camps and events,
• articles and informational material,
• offers or promotions.

The legal basis is your consent.

Subscription to the newsletter is optional and is not a prerequisite for the provision of any service.

You can withdraw your consent at any time:

• by selecting the "Delete", "Unsubscribe" or "Unsubscribe" link included in each newsletter,
• by sending a relevant request to smartgrowthzografou@gmail.com.

The withdrawal of consent does not affect the lawfulness of the processing carried out before its withdrawal.

6.4 Website security

We process technical data for:

• the secure operation of the website,
• the prevention of fraud or malicious actions,
• identifying technical problems,
• the protection of our information systems,
• creating backup copies,
• dealing with security incidents.

The lawful basis is our legitimate interest in the safe and reliable operation of the website.

6.5 Statistical analysis and improvement of the website

If you have given your consent to the respective cookies, we may use data to:

• traffic measurement,
• understanding how to use the website,
• improving content and user experience,
• evaluating the effectiveness of information or advertising actions.

The legal basis is your consent through the cookie management mechanism.

6.6 Compliance with legal obligations

We may process data for:

• compliance with tax, accounting or other legal obligations,
• responding to lawful requests from authorities,
• the fulfillment of obligations imposed by applicable legislation.

6.7 Protection of rights and legal claims

We may retain or use data when necessary to:

• the foundation,
• the exercise,
• support,
• the defense of legal claims.

7. Newsletter and commercial communication

We do not send newsletters to persons who have not registered or there is no other permitted legal basis.

When registering:

• clear information is provided about the content of the messages,
• positive action is requested from the user,
• no pre-selected consent boxes are used,
• Consent is recorded for evidence and compliance purposes.

A registration confirmation process, known as double opt-in, may be applied, during which the user is asked to confirm their registration via email.

Each newsletter includes an easy and free way to unsubscribe.

After unsubscribing, the email may be kept on a limited suppression list, only to ensure that messages are not sent to that email again and to demonstrate our compliance.

We do not sell or make available the newsletter list to third parties for their own independent advertising purposes.

8. Cookies and related technologies

The website may use cookies and related technologies, such as pixels, tags and local storage.

Cookies are small files that are stored on your device or access information stored on your device.

8.1 Strictly necessary cookies

Strictly necessary cookies are used to:

• the basic functionality of the website,
• security,
• session management,
• saving consent choices,
• the operation of electronic forms.

These cookies cannot usually be disabled through the consent mechanism, because they are necessary to provide the service requested by the user.

8.2 Functionality cookies

They are used to store options, such as language, region or other usage preferences.

8.3 Statistical analysis cookies

They are used to measure traffic and understand how visitors use the website.

They are activated only after your consent.

8.4 Advertising and social media cookies

They may be used by advertising services or social media platforms to measure the effectiveness of ads or display relevant content.

They are activated only after your consent.

You can change or revoke your choices at any time through the "Cookie Settings" option that should be available on the website.

Rejecting optional cookies should not prevent access to the basic content of the website.

More information about specific cookies, their provider, purpose and duration is provided in the Cookies Policy or in the website's cookie settings panel.

9. To whom is the data shared?

We do not sell, rent or exchange your personal data.

Only authorized persons and associates may have access, to the extent necessary.

We may share data with the following categories of recipients:

• staff and authorized partners of Smart Development Egaleo,
• teachers, therapists and professionals involved in providing the service,
• website hosting provider,
• technical managers, developers and support companies,
• email provider,
• newsletter sending and management provider,
• backup and cybersecurity providers,
• statistical analysis providers, if you have consented,
• accountants, lawyers and other professional advisors,
• public, judicial, tax, supervisory or other competent authorities, when required by law.

Partners acting as processors are contractually bound to process the data only in accordance with our instructions, to maintain confidentiality and to implement appropriate security measures.

10. Links and embedded third-party content

The website may include:

• links to other websites,
• maps,
• video,
• social media buttons,
• posts or other embedded third-party content.

Third-party services may collect data in accordance with their own privacy policies.

We do not fully control the processing carried out by independent third-party providers and we recommend that you review their privacy policies.

Optional embedded content that uses cookies should only be loaded after your respective consent.

11. Transfer of data outside the European Economic Area

Certain technical providers, newsletter providers, cloud services, statistical analysis or social networks may have facilities or infrastructure outside the European Economic Area.

When personal data is transferred outside the European Economic Area, we take appropriate measures as provided for by the GDPR, such as:

• transfer to a country for which an adequacy decision has been issued,
• use of approved Standard Contractual Clauses,
• implementation of additional technical and organizational measures,
• use of another legal transmission mechanism.

You can request more information about appropriate guarantees by contacting us.

12. Data retention period

We retain personal data only for as long as is necessary for the purpose for which it was collected and as required by law.

Indicatively:

Contact requests

Simple communication request data is retained for up to twenty-four months from the last substantive communication, unless a collaboration, contractual relationship or legal dispute arises.

Newsletter

Your email and registration details are retained for as long as you remain registered.

Upon unsubscribing, promotional messages will stop being sent immediately. Some evidence of consent or unsubscription may be retained for as long as necessary to demonstrate compliance and protect against legal claims.

Service provision data

Data related to contracts, payments or provision of services is retained for the duration of the relationship and thereafter for as long as required by tax, accounting, civil or other legislation.

Educational and therapeutic folders

The data included in educational or therapeutic files are maintained in accordance with applicable legislation, the professional obligations of the relevant professionals and the specific information provided to the parent or guardian.

Technical files

Technical logs are typically retained for up to twelve months, unless longer retention is required for security incident investigation or for legal reasons.

After the retention period expires, the data is deleted, anonymized or destroyed in a secure manner.

13. Personal data security

We take appropriate technical and organizational measures to protect data from:

• loss,
• destruction,
• alteration,
• unauthorized access,
• unlawful disclosure,
• unauthorized use.

Measures may include:

• encryption of communication via HTTPS,
• access control,
• strong passwords and multi-factor authentication, where available,
• limited access only to authorized persons,
• software updates,
• backups,
• protection against malware,
• recording actions,
• security incident management procedures,
• confidentiality obligations of staff and associates.

Although we make reasonable efforts, no data transmission over the internet can be considered completely secure.

14. Data Breach Incidents

In the event of an incident that may endanger the rights and freedoms of natural persons, we implement an assessment and response process.

Where required by the GDPR:

• we inform the Personal Data Protection Authority,
• we inform the affected persons,
• we take measures to limit the consequences,
• We keep a record of the incident and the response actions.

15. Your rights

You have, depending on the conditions of the law, the following rights:

Right to information

Receive clear and transparent information about the processing of your data.

Right of access

Request confirmation as to whether we are processing your data and receive a copy of it.

Right to correction

Request the correction of inaccurate or incomplete data.

Right to erasure

Request the deletion of your data, when the legal conditions are met.

Right to restriction

Request the restriction of processing in specific cases.

Right to portability

To receive data that you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, to request its transmission to another controller.

Right to object

Object to processing based on legitimate interest.

You have an absolute right to object to processing for direct marketing purposes.

Right to withdraw consent

When processing is based on consent, you can withdraw it at any time.

Right not to be subject to solely automated decision-making

You have the right not to be subject to a decision that is made solely by automated means and produces legal or similarly significant results.

We do not exclusively carry out automated decision-making or profiling that produces legal or similarly significant results for website users.

16. How you can exercise your rights

To exercise your rights, you can contact:

smartgrowthzografou@gmail.com

on the subject: «"Exercise of personal data rights"».

In your request please indicate:

• your full name,

• the right you wish to exercise,

• the information necessary to identify the data,

• any relationship you may have with a child as a parent, guardian or legal representative.

We may request additional information to confirm your identity or status, particularly when the request concerns data of a minor.

We will respond without undue delay and as a rule within one month. The deadline may be extended in accordance with the GDPR, taking into account the complexity and number of requests.

The exercise of rights is in principle free of charge. In the event of manifestly unfounded or excessive requests, a reasonable fee may be imposed or the request may be rejected, as permitted by law.

17. Right to complain

If you believe that the processing of your data violates the law, you have the right to file a complaint with:

Personal Data Protection Authority

You can contact us beforehand so that we can examine and address your request.

The right to complain does not limit your right to appeal to the competent courts.

18. Changes to the Privacy Policy

We may amend this Policy when:

• the services or functions of the website change,

• new technologies or providers are installed,

• the way data is processed is changing,

• the legislative or regulatory framework is amended.

The updated version will be published on the website with reference to the date of the last update.

In the event of material changes, additional information may be provided via the website or, where appropriate, via email.

19. Contact

For any questions regarding this Policy or the processing of your personal data, you can contact:

Smart Development of Egaleo

Georgiou Papandreou 19
Postal Code 15773, Egaleo, Attica

Telephone: 210 01 05 191
Mobile: 694 96 99 649
E-mail: smartgrowthzografou@gmail.com