Effective Date: 1st of May 2025

 General Information

The Société Anonyme under the corporate name "modulus Telecommunications and Informatics Company" and the distinctive title "modulus S.A.", having its registered office at 311 Mesogeion Avenue, Chalandri, Attica, Greece (VAT No. 998301677, Tax Office: K.E.F.O.D.E. Attikis), acting as the Data Controller in accordance with the applicable European and national legislative framework, is committed to protecting and safeguarding the privacy and personal data of its customers. To this end, the Company has implemented a series of measures, policies, and procedures to ensure its full compliance with the applicable legal framework.

 

Your Data is Safe with Us

At modulus S.A. (“modulus”), we value the confidentiality of your communications and personal data. Their protection is of the utmost importance to us, as we want you to feel secure when sharing information while using our services.

For this reason, we kindly ask you to take a few moments to carefully read this Privacy Policy in order to clearly understand what information we collect about you, with whom we share it, what types of processing we carry out, and what your related rights are.

Please do not access or use the Website by any means or in any manner if you do not agree with the contents of this Privacy Policy. Any access to or use of the Website constitutes your acknowledgment that you have been duly informed and your full and unconditional acceptance of its terms.

 

1. What is Personal Data?

The term Personal Data refers to any information or detail that identifies or can be used to identify a natural person. This includes cases where a person’s identity may be determined, even indirectly, by reference to a factor that is unique to their physical, physiological, genetic, psychological, economic, cultural, or social identity.

The purpose of this Privacy Policy is to inform you in detail about everything related to your personal data and its processing by modulus. If you have any further questions, please do not hesitate to contact us.

 

2. Data Controller and Data Protection Officer

The company “modulus Telecommunications and Informatics Société Anonyme” (hereinafter “modulus” or the “Company”), located at 311 Mesogeion Avenue, Chalandri, Attica, GR-15231, Tel: +30 215 215 1500, Email: info@modulus.gr, is responsible for the processing of your personal data.

You may contact the Company’s Data Protection Officer as follows:

Address: 311 Mesogeion Avenue, Chalandri, Attica, GR-15231

Phone: +30 215 215 1500

Email: gdiamantopoulos@modulus.gr. 

 

3. Which Individuals’ Personal Data Do We Collect?

We process personal data relating to our customers and prospective customers who are interested in our services. Through our website www.modulus.gr, we also process data of visitors to our website and individuals who contact us for any matter via the communication forms provided.

If you are a user of our subscribers’ portal my.modulus.gr, we also process information about you through this service. Additionally, if you express interest in working with modulus or contact us regarding any issue, we may collect and process additional personal information about you.

 

4. For What Purposes Do We Collect Personal Data?

We process your data for specific purposes, depending on the service you use and the reason we require it. For example, in order to respond to your interest in our services and to handle your requests, we need your identification and contact information.

Below, we provide detailed information about the purposes for which we collect and process your data based on your interaction with us through our services and websites. In the event of further cooperation or interaction with you, we may request additional personal information. In such cases, you will be specifically informed about the processing of your data for the relevant purpose.

We would like to clarify that we do not listen to your calls, nor do we store messages transmitted through our networks once they have been delivered to their recipient.

 

4.1 Identification Information

We may receive identification information about you when you request to register for our services or when you are already receiving services, such as when you use our subscriber portal at my.modulus.gr. Such information may include:

• Identification details and documents confirming your identity (e.g., your full name, date of birth, a copy of your ID/passport, etc.);

• Contact details (e.g., address, mobile or landline phone number, email, etc.);

• Location data (geolocation data);

• Information about your devices/terminal equipment;

• Information related to your communications;

• Details about your subscriptions with modulus.

 

We only request personal data that is strictly necessary. Without it, we cannot properly process your request or provide our services. The purpose of processing is to identify you and respond to your request to register and receive our services. The legal basis is taking steps at your request prior to entering into a contract and the performance of that contract (Article 6(1)(b) of the GDPR).

If you do not proceed with entering into a contract with us, your data will be automatically deleted after nine (9) months (or earlier if you request it). This data is not shared outside the Company for any reason. If you enter into a contract with modulus, we will process your data for the entire duration of our contractual relationship and for as long as required by applicable law following its termination.

4.2 Information Regarding the Services You Receive

Whenever you use Modulus services, we process information related to those services, such as:

• The type of service you receive, the volume of your usage, the duration of use, and the associated cost;

• Payment information, including your payment method and means, as well as related details (e.g., the last digits of your credit or debit card, the collaborating bank, etc.);

• Billing information (such as your full name, VAT number, tax office, etc.);

• The external details of your communications (e.g., date and time of communication, IP address, calling and called numbers, etc.). From such data, additional information may be derived, such as the countries you call or receive calls from;

• Your preferences regarding the services you receive, such as whether you request call blocking or other service set-tings.

 

The purpose of collecting this data is to fulfill your service agreement and respond to your requests regarding the provision of such services. The processing of your communication data is technically essential for the proper execution of the communications themselves. The legal basis for this processing is the performance of the contract to which you are a party (Article 6(1)(b) of the GDPR). The Company is also legally obliged to process certain information in accordance with Article 6(1)(c) of the GDPR and relevant telecommunications legislation in order to comply with requests from public authorities in the context of its statutory obligations. This includes, indicatively, reporting to the Hellenic Telecommunications and Post Commission (EETT) on interconnection or billing issues, pursuant to applicable law, as well as the provision of information necessary for the exercise of the Commission’s supervisory powers.

Finally, our Company has a legitimate interest in promoting its products and services to its customers (Article 6(1)(f) of the GDPR).

Recipients of this information include the Company itself and, to the extent that it is technically necessary, third-party network service providers with whom we cooperate in order to route your calls to their intended destinations. All of our suppliers and third-party network providers are bound by confidentiality and data protection agreements with respect to any information they may access in the course of their services.

In cases where we are lawfully required to do so, recipients of this information may also include public judicial and other competent authorities.

We emphasize that we do not “listen” to the content of your calls in real time. In fact, we do not interfere in any way, we do not gain access to, and we actively protect the content of your communications from any access using the most advanced tools and methods available. Under no circumstances and for no reason does modulus monitor your communications. Such authority is strictly reserved for public authorities and only under very specific legal conditions.

The duration of processing your data for these purposes corresponds to the duration of the provision of our services to you. However, your payment data and tax information will be retained for as long as required under applicable tax legislation. Specifically, the external details of your communications are retained by the Company for the period defined by applicable legislation (currently two years from the date of communication), and the legal basis for such processing is our legal obligation to retain them (Article 6(1)(c) of the GDPR). Finally, we retain some of your data for a period of 18 months in order to offer you promotions and products or services that may be of interest to you (for the purpose of direct marketing, please also refer to section 4.6 below).

4.3. Communication Data You Share with Us

4.3.1. Communication with Us

When you contact us, we collect data in order to respond to your request. If you contact us by phone, you will be informed in advance of any potential call recording. If you contact us through the contact form available on our website, we will process the data you submit via the form and the information you provide in order to respond to you in the most appropriate manner. In addition, we process the information you disclose to us via our email address telecoms@modulus.gr (e.g., questions, requests, résumés expressing interest in professional cooperation, etc.).

In any case of communication with us, we may use information such as your full name, identity card or passport number, telephone number, date of birth, email address, residential address, and tax identification number for the purposes of identifying you and communicating with you.

The legal basis for the processing of this data is your consent, which will be requested through the same means by which you communicate with us. This data is not disclosed outside the Company and is retained for as long as necessary to fulfill your request, and for an additional period of nine (9) months for promotional purposes (see section 3.6 below).

4.3.2. Customer Satisfaction Surveys

Our company may send you surveys to evaluate your satisfaction or your experience with our services, as part of our ongoing efforts to improve the quality of the services we provide and our customer support. These surveys are conducted via electronic communication, are based on the company’s legitimate interest, and relate exclusively to the assessment of the quality of our services.
Your participation in these surveys is voluntary and takes place only with your consent. The legal basis for processing the data collected through the surveys is your consent, which is requested at the time each survey is sent and may be withdrawn at any time. Such data is used solely for statistical and internal purposes of the company, is not shared with third parties, and is retained for as long as necessary for statistical purposes, unless you request its earlier deletion.

4.4 Financial Information

We may use your banking information or card details, billing information, and tax identification data to process your payments—such as when you purchase a service from us, settle an outstanding balance, or when we need to issue a payment to reimburse you. The legal basis for such processing is the performance of a contract (Article 6(1)(b) of the GDPR) and our legal obligation (Article 6(1)(c) of the GDPR). This data is retained for the duration required by applicable tax or other legislation. Recipients of this information, in addition to the relevant departments within our Company, are only those third-party providers who are required to process it, such as accounting firms that support our Company.

4.5. Browsing Data

Through your navigation of our website, we collect certain information in order to offer you a better online experience and to process website traffic statistics. For example, we may use your IP address or place cookies in your browser. The legal basis for this processing is our Company’s legitimate interests (Article 6(1)(f) of the GDPR), namely, to maintain a modern and technologically advanced website, to collect and process statistical information, and to enhance the Website’s responsive-ness to audience traffic. The above also applies to our subscriber portal at my.modulus.gr.

With regard to the installation of cookies or similar technologies, the legal basis for processing is your consent. Without your consent, we do not proceed with such processing.

Further information is available in our Cookies Policy.

4.6. Promotion

Our Company may process your personal data for the purpose of promoting its products and services. 

If you have purchased services from us, your data will be used for remarketing purposes for as long as you remain our cus-tomer, and for a period of 18 months following the termination of your contract. If you have received an offer from us, your data will be used for remarketing purposes for a period of 9 months from the date we provided the offer.

The legal basis for this processing is our Company’s legitimate interests in lawfully promoting its products and services (Ar-ticle 6(1)(f) of the GDPR). This data is not shared outside the Company, except with any suppliers who may provide us with promotional services. In such cases, we ensure that these suppliers are bound by confidentiality agreements regarding the data we disclose to them.

We may also collect your personal data from publicly accessible platforms for the purpose of promoting our services. We may use some of your personal data for remarketing purposes, for example, to display our advertisements related to your interests via our trusted partners. In this way, we may use your data to provide you with targeted and personalized advertis-ing.

If you subscribe to our newsletter, we may occasionally send you updates, promotional emails, and information about the Company and our Services. This processing is based on your consent (Article 6(1)(a) of the GDPR), which you may withdraw at any time.

In any case where you receive promotional communication from us, you have the right to opt out of receiving further promo-tional messages from our Company. Simply notify us by sending an email to telecoms@modulus.gr or click “unsubscribe” in any promotional email you receive from us. We will immediately cease processing your data for marketing and promotional purposes, without affecting any other aspect of our relationship. Additionally, your device may include a function (such as “Limit Ad Tracking” on iOS or “Opt out of Interest-Based Ads” / “Opt out of Ad Personalization” on Android) that allows you to opt out of the use of certain information collected through mobile applications for behavioral advertising purposes.

4.7. Data for the Handling of Claims

If it becomes necessary to legally manage a claim, whether initiated by us or by you, we may process your personal data re-lated to the claim, such as your payment information. In such cases, the data will be retained until the final resolution of the claim and may be disclosed to our external advisors (e.g., legal or financial consultants) and to competent services or au-thorities, as necessary.

4.8. Other Cases Where We Process Your Data

When you purchase services from us through our network of resellers, certain information about you will be shared with us in order to effectively provide you with our services. The purpose of collecting this data is to fulfill your service agreement. The legal basis for this processing is the performance of the contract (Article 6(1)(b) of the GDPR).

Recipients of this data, apart from our Company, include our suppliers, to the extent necessary to deliver the requested services to you. All of our suppliers are bound by confidentiality and data protection agreements concerning the information they access in the course of providing their services.

The duration of the processing of your data corresponds to the period during which we provide our services to you. However, some data may be retained for as long as required under applicable legislation (such as payment or tax information). The external details of your communications are retained by the Company for the period specified by applicable law (currently two years from the date of communication). In such cases, we are under a legal obligation to retain this data (Article 6(1)(c) of the GDPR).

 

5. Personal Data of Minors

We will not request or process the personal data of minors for any reason. Our website is not directed at minors and should not be used by them.

 

6.  What Happens If You Provide Us with False Information?

If you provide us with inaccurate, incomplete, or false information, we may cancel or terminate your contract or refuse to renew it. Alternatively, if the inaccurate, incomplete, or false information concerns specific services only, we may deny you access to those particular services.

 

7. How Is Your Personal Data Processed?

We use automated systems to process your personal data. This means that we operate systems that automatically collect, organize, and evaluate the data you provide to us.

These automated procedures are monitored by our analytics department, which performs regular audits to ensure that everything is functioning correctly.

Additionally, you have the ability to manage and modify several aspects of your personal information through the my.modulus.gr portal.

 

8. Apart from modulus, Who Else Has Access to Your Data?

Recipients of your data include modulus and its personnel, as well as any natural or legal person to whom modulus is obligated or entitled to disclose such information.

Recipients of the external details of your communications may include third-party network service providers, as mentioned above in section 4.2.

Your financial data may be disclosed to our external financial advisors.

Traffic data and communication data may also be shared with our suppliers who provide advertising, promotion, technical services for our websites, and other partners who assist us in delivering the services you have purchased, such as external call centers, host providers, banks, and financial institutions. All of our suppliers have signed confidentiality agreements with us or have their own policies obligating them to safeguard the confidentiality of any information to which they have access.

All your data may also be disclosed to our legal advisors, who are legally bound by confidentiality obligations.

Additionally, the Company informs you that, in the context of interconnecting its network with the telecommunications networks of other operators for the provision of interconnection services, the transmission of such personal data is necessary, even when a request for the concealment of such data has been made. These data are transmitted exclusively for the purposes of billing the services provided and for compliance with applicable legislation and regulatory decisions.

The Company may also disclose information regarding outstanding debts to debt collection agencies solely for the purpose of collecting the amounts owed on your account.

Your information may also be disclosed to:

• Public or governmental authorities (such as courts, regulatory bodies, law enforcement agencies, tax authorities, and cybercrime units), Third-party courts, and their accountants, auditors, lawyers, and other consultants and representatives, whenever we believe such disclosure is necessary or appropriate.

• The lifting of the confidentiality of communications is permitted only insofar as we are called to fulfill an obligation under applicable law.

You are also the recipient of your information through the management system of the my.modulus.gr page that we provide to our subscribers for their better service.

 

9. Are Your Personal Data Safe?

At modulus S.A. ("modulus")—the Data Controller—we value your privacy and data protection. We comply with all relevant legislation, including Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), which came into effect on 25 May 2018 and governs the protection of all personal data we process. The Company takes all appropriate technical and organizational measures to ensure the confidentiality of communications and the security of transmitted information and data of its subscribers. We have chosen to retain only the data that are strictly necessary, all of which are either encrypted and/or anonymized—partially or fully.

 

10. Transfer of Data Outside the EEA

Your personal data are stored on servers located within the European Economic Area (EEA) and, as a general rule, are not transferred outside the EEA. However, we may transfer your personal data to partner companies or service providers located outside the EEA, in accordance with the requirements of applicable legislation. Such transfer may occur, for example, if our servers or service providers are located outside the EEA or if you access our services from a country outside the EEA.

When modulus transfers data outside the EEA, we ensure that your data are adequately protected. In the event that data are transferred to third countries outside the EEA for which there is no adequacy decision by the European Commission, or to International Organizations, all appropriate safeguards as required by applicable law and by the decisions and guidelines of the competent European authorities on personal data protection will be implemented. Relevant information regarding such data transfers will be made available on our website at www.modulus.gr.

 

11. Links to Third-Party Websites

Our Website may contain links that, when clicked, will redirect you to third-party websites over which we have no control or influence. Please consult the applicable privacy policies of those websites to understand how your personal data are used. The Company bears no responsibility and is under no obligation to compensate or indemnify any affected individual for any damage or harm that may result from or be related to the processing of personal data carried out by the linked third-party websites.

 

12. What Are Your Rights Regarding Your Personal Data?

You have the right to know what data we process, why we process them, and who processes them. Specifically, you have the following rights:

• Right to information and access: You have the right to be informed whether your personal data are being processed by modulus and to receive additional details about the processing.

• Right to rectification: If your data are inaccurate or incorrect, you have the right to request their correction.

• Right to restriction of processing: Depending on the circumstances, you may limit which of your data are processed.

• Right to erasure: You may request the deletion of your data in specific cases, especially when they are no longer necessary for the purposes for which they were collected.

• Right to data portability: You may request a copy of your processed data in a structured, commonly used, and ma-chine-readable format, in order to transfer them to another provider or company.

• Right to object: If applicable, you may object to the processing of your data. Please note, however, that some data may be essential for the provision of services, and such an objection may result in the termination of your service agreement.

• Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling

• Right to withdraw consent: You may withdraw your consent for the use of your data for commercial purposes at any time.

To exercise any of the above rights, please send your request via email to dpa@modulus.gr or call us at +30 215 215 1500. We will review your request within thirty (30) days. If there are objective reasons that prevent us from fulfilling your request, we will inform you accordingly. You may exercise these rights free of charge. However, if requests are repeated frequently, we reserve the right to charge an administrative fee of up to €25.

 

13. Updating Your Information

As the accuracy of your personal data is important to us, please inform us if any of the information we hold about you requires updating, correction, or completion.

 

14. How Can You Lodge a Complaint About the Processing of Your Personal Data?

If you have any questions or concerns about the processing of your personal data, you may contact our Data Protection Officer (DPO) by email at dpa@modulus.gr or by calling us at +30 215 215 1500.

You may also contact the Hellenic Data Protection Authority (HDPA), which is available at www.dpa.gr.

 

15. What Kind of Changes Do We Make?

From time to time, we may make changes to this Privacy Policy to improve customer service and ensure compliance with applicable legal and regulatory requirements. We encourage you to periodically visit our website to stay informed about any updates. However, if we make material changes to this Policy, we will notify you via email and give you the opportunity to review the updated terms and conditions before deciding whether to accept them.