Privacy policy

1. Introduction and Data Controller Identification

Hellenic Talent (“HT”) is committed to protecting the privacy and personal data of all individuals who use our platform. This Privacy Policy explains how Hellenic Talent collects, uses, discloses, stores, and otherwise processes personal data in connection with the services we provide. We have designed this notice to be clear, transparent, and compliant with applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Greek Law 4624/2019 on the protection of natural persons with regard to the processing of personal data, and any other applicable national data protection laws.

Please read this Privacy Policy carefully before using the Hellenic Talent platform. By accessing or using the platform, you acknowledge that you have read and understood this notice. If you do not agree with any part of this notice, please do not register with Hellenic Talent or discontinue your use of the platform.

The data controller responsible for the processing of your personal data as described in this Privacy Policy is:

Hellenic Talent has not appointed a Data Protection Officer (DPO) as it does not meet the mandatory designation thresholds set out in Article 37 of the GDPR. For all data protection enquiries, please contact us using the details provided above.

2. Scope

This Privacy Policy applies to all personal data processed by Hellenic Talent in connection with the operation of its online platform. Specifically, this notice applies to:

• Freelancers who register on the platform to offer their professional services, skills, and expertise;
• Clients who register on the platform to search for, engage, and collaborate with freelancers, whether acting as natural persons or on behalf of corporate entities, businesses, or organisations;
• Visitors to the Hellenic Talent website who have not registered as users but whose data may be collected through submissions of communications request, enquiries, tracking technologies, cookies (please also refer to our Cookie Policy for further information);
• Applicants or Candidates that have contacted HT or submitted an application and/or CV through the Platform or other means, candidates who have been referred to HT by members of the HT network, clients or third-parties, candidates that have been identified by HT as possible additions to the HT network, applicants who have not yet been admitted to the HT network or applicants whose application has been rejected; and
• Any other individuals whose personal data is processed in connection with the services offered through the platform, including representatives of corporate clients and emergency contacts, subcontractors of freelancers, referees etc.

This Privacy Policy does not apply to third-party websites, services, or applications that may be linked to or accessible from the Hellenic Talent platform. Hellenic Talent is not responsible for the privacy practices of such third parties, and we encourage you to review their respective privacy policies independently.

3. Categories of Personal Data Collected

The categories of personal data we collect depend on whether you use the platform as a freelancer or as a client. We collect only personal data that is necessary for the purposes described in this Privacy Policy, in accordance with the principle of data minimisation under Article 5(1)(c) of the GDPR.

3.1 Personal Data Collected from Freelancers and Applicants

3.1.1 Identity Data

We collect data that enables us to identify you as an individual, including your full legal name, date of birth, nationality, country of residence, and a profile photograph (if you choose to provide one). As a legal company, we collect your company’s legal name and registered address, company EU tax identification number, company EU VAT number, permanent establishment and EU commercial register number.

3.1.2 Contact Data

We collect your email address, telephone number, residential or business address (city and country at minimum), tax identification number, place of birth, VAT number and any other contact details you choose to provide in your profile.

3.1.3 Professional Profile Data

We collect information about your professional background, qualifications, skills, areas of expertise, languages spoken, years of experience, company positions, internal promotions achieved at a certain company, educational credentials, professional certifications, and any professional memberships or accreditations you hold, freelancing experience and motivation for freelancing.

3.1.4 Portfolio Data

We collect samples of your work, projects you have completed, references, testimonials from previous clients, and any other materials you upload to demonstrate your skills and experience. This may include written documents, images, links to external websites, and other multimedia content. HT will never request special data that relates to racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. Persons to which this policy applies should refrain from submitting any such type of data to HT. Should any such data be voluntarily shared with HT, HT retains the right to immediately destroy and/or delete the relevant data and notify the data subject of such deletion.

3.1.5 Financial and Payment Data

We collect the information necessary to process payments to you, including your preferred hourly or project rates, banking details or payment account information (such as IBAN, SWIFT/BIC codes, or details for electronic payment services), tax identification numbers (AFM for Greek residents), and VAT registration status.

3.1.6 Platform Usage Data

We automatically collect data about how you interact with the platform, including your login session records (IP address, browser type), security logs, records of terms and policy acceptance, and other activity logs generated through your use of the platform.

3.1.7 Communications Data

We collect records of communications between freelancers and clients conducted through email, video or e-conference (upon receiving explicit consent to the recording at the start of the conference), the platform's or third-parties’ messaging systems, as well as communications between you and Hellenic Talent's support team, dispute resolution communications, and any feedback or complaints you submit. As part of the process of conducting interviews for inclusion in the HT network or for selecting candidates for a specific Client engagement or project, introducing freelancers to clients, managing timelines and status updates or any other communication, we may process data collected through recordings of video, teleconference or e-conference upon receiving explicit consent to the recording at the start of each recording session.

3.1.8 Engagement Data

We collect and process data generated throughout the lifecycle of a client engagement, including: proposals submitted and shortlisting decisions, contracts entered into, engagement milestones and deliverable timelines, project status updates and outcomes, current availability, preferred workload, unavailable periods, and any additional information provided by you. We also collect client feedback and evaluations regarding freelancer candidates identified by HT and their suitability. In case of engagement, we collect feedback on freelancer performance either through in-platform opinion/feedback form with optional free-text comment, accessible only to Hellenic Talent and the relevant client, or outside the platform, e.g. by email, telephone, video conference, or other verbal or written communication. Client satisfaction indicators, such as repeat engagement rates, referral activity, and post-engagement evaluations, may also be collected to support continuous improvement of HT’s matching process.

3.1.9 Academic Background

We collect data, such as school or university you attended, degree type and field of study, start and end date and grade.

3.1.10 References

We collect reference identity, working relationship, project context, reference contact details.

3.2 Personal Data Collected from Clients

3.2.1 Identity Data

We collect your full name, position or title (where you are acting on behalf of a company or organisation).

3.2.2 Contact Data

We collect your email address, telephone number, business or personal address (as appropriate), and other contact details you provide during registration or in the course of using the platform.

3.2.3 Company and Organisation Information

Where you register as a business client, we collect your company name, registered address, company registration number, VAT number, industry sector, website, and a description of your business activities and hiring needs.

3.2.4 Payment Data

We collect the information necessary to process payments from you, including billing address and payment authorisation information.

3.2.5 Platform Usage Data

We automatically collect data about how you interact with the platform, including login activity, job postings edits, notes on freelancers viewed or shortlisted, contracts concluded, ratings and reviews submitted, and other activity generated through your use of the platform, project details, budget and further confidential business information you may input in the Platform.

3.2.6 Communications Data

We collect records of communications between freelancers and clients conducted through email, video or e-conference (upon receiving explicit consent to the recording at the start of the conference), the platform's or third-parties’ messaging systems, as well as communications with Hellenic Talent's support and account management teams, dispute correspondence, and any feedback or complaints you submit. As part of the process of liaising with you for a specific engagement or project, and introducing freelancers to you, managing timelines and status updates or any other communication, we may process data collected through recordings of video, teleconference or e-conference upon receiving explicit consent to the recording at the start of each recording session.

3.2.7 Engagement Data

We collect and process data generated throughout the lifecycle of a client engagement, including: shortlisting decisions, contracts entered into, engagement milestones and deliverable timelines, project status updates and outcomes, and any additional information provided by you. We also collect your feedback and evaluations regarding freelancer candidates identified by HT and their suitability. In case of engagement, we collect feedback on freelancer performance either through in-platform opinion/feedback form with optional free-text comment, accessible only to Hellenic Talent and you, or outside the platform, e.g. by email, telephone, video conference, or other verbal or written communication. We may also keep internal notes on your account status, preferences or other notes pertaining to our collaboration with you. Your satisfaction indicators, such as repeat engagement rates, referral activity, and post-engagement evaluations, may also be collected to support continuous improvement of HT’s matching process.

3.3 Third Party Personal Data

Where Hellenic Talent collects personal data from sources other than the data subject — including referrals from clients, members of the HT network, or third parties, and publicly available professional profiles — the categories of data collected and the source from which the data originates will be communicated to the data subject at the time of first contact or within one (1) month of processing, in accordance with Article 14 of the GDPR.

4. Purposes and Legal Bases for Processing

The GDPR requires that every processing activity be supported by a lawful basis as set out in Article 6 (and, where applicable, Article 9 for special categories of data). The table below summarises the principal purposes for which Hellenic Talent processes personal data and the corresponding legal basis relied upon.

4.1 Legitimate Interests Assessment

Where Hellenic Talent relies on legitimate interests as the legal basis for processing, we have conducted a legitimate interests assessment (LIA) to ensure that our interests are not overridden by your fundamental rights and freedoms. In conducting these assessments, we consider: (i) the nature and purpose of the processing; (ii) the reasonable expectations of data subjects in the context of their relationship with Hellenic Talent; and (iii) whether the impact of the processing on data subjects is proportionate and whether adequate safeguards are in place.

You have the right to object to processing carried out on the basis of legitimate interests at any time. Please refer to Section 8 of this Privacy Policy for further information regarding your rights and how to exercise them.

5. Data Retention

Hellenic Talent retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The specific retention periods applicable to different categories of personal data are set out in our Data Retention Policy, which is incorporated into this Privacy Policy by reference and is available upon request by contacting us at the details set out in Section 12.

In general terms, our approach to retention is as follows:

• Account data is retained for the duration of the user's active account and for a defined period following account closure, to allow for dispute resolution and to comply with legal obligations;
• Financial and transactional records are retained for the period required by applicable tax, accounting, and commercial law, which in Greece is generally a minimum of five (5) years;
• Communications data may be retained for a period following the conclusion of a project or contract to support dispute resolution and quality assurance;
• Platform usage data collected for analytics may be anonymised or pseudonymised after a shorter retention period, once the specific analytical purpose has been fulfilled; and
• Where processing is based on consent, data will be retained until consent is withdrawn, subject to any overriding legal retention obligation.

At the end of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents reconstruction of the original data. Please refer to the Data Retention Policy for full details.

6. Recipients and Disclosures

Hellenic Talent does not sell your personal data to third parties. We may, however, share your personal data with the following categories of recipients where it is necessary to do so in connection with the purposes described in this Privacy Policy:

6.1 Other Platform Users

Profile information provided by freelancers — including name, professional details, portfolio, skills, rates, and ratings — is shared with clients using the platform for the purpose of facilitating connections and engagements. Conversely, certain profile information of clients — including company name, project descriptions, and ratings — is made available to freelancers. Users should be aware that information they choose to include in their HT profiles may be shared with other registered users of the platform and specifically Freelancer information may be shared with Clients and vice versa.

6.2 Payment Processing

We may share payment-related personal data with clients or freelancers as necessary to enable the processing of payments, invoicing, and related financial transactions. Where payment data is shared with a client or freelancer for the purpose of direct payment or invoicing between the parties, the recipient acts as an independent data controller and is responsible for its own compliance with applicable data protection law.

6.3 Cloud Hosting Providers

Our platform and associated data infrastructure are hosted by third-party cloud service providers. These providers may process personal data as data processors acting on our behalf and are subject to appropriate contractual safeguards, including data processing agreements incorporating standard contractual clauses where applicable.

6.4 Third Party Service Providers and Analytics Providers

We use third-party service providers, including Analytics Providers to help us understand how users interact with the platform and to improve our services. Where possible, data shared with third party providers is aggregated or pseudonymised. These providers are contractually bound to process data only in accordance with our instructions.

6.5 Professional Advisors

We may share personal data with our legal, financial, and other professional advisors where it is necessary for the purposes of obtaining professional advice, managing legal claims or regulatory inquiries, or fulfilling our legal obligations. Such advisors are bound by professional confidentiality obligations and contractual restrictions on use of the data.

6.6 Regulatory and Law Enforcement Authorities

We may disclose personal data to regulatory authorities, law enforcement agencies, courts, and other public authorities where required to do so by applicable law, a legally binding order, or where we have a good-faith belief that disclosure is necessary to protect the rights, property, or safety of Hellenic Talent, our users, or the public.

6.7 Note on International Transfers

Some of the recipients listed above may be located in, or process personal data in, countries outside the European Economic Area (EEA). Where personal data is transferred to a country outside the EEA, Hellenic Talent ensures that appropriate safeguards are in place to protect such data in accordance with GDPR Chapter V requirements. These safeguards may include: adequacy decisions issued by the European Commission confirming that the recipient country offers an adequate level of data protection; or Standard Contractual Clauses (SCCs) adopted by the European Commission, which impose contractual obligations on the recipient ensuring an equivalent level of protection to that provided under the GDPR. Please refer to Section 7 for full details of our international transfer mechanisms.

7. International Data Transfers

As a platform that engages with users across multiple jurisdictions and relies on global technology infrastructure, Hellenic Talent may transfer personal data to countries outside the European Economic Area (EEA). All such transfers are carried out in compliance with the EU GDPR, which governs the international transfer of personal data to third countries and international organisations.

Hellenic Talent relies on appropriate data protection safeguards, as appropriate to the circumstances of each transfer, such as Adequacy Decisions, Standard Contractual Clauses (SCCs) etc, and will perform the necessary Transfer Impact Assessments (TIAs) where applicable.

To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please contact us using the contact information below. Please note that when personal information is transferred to certain countries, law enforcement and regulatory agencies, including national security authorities, of these countries may be able to access such information in accordance with the laws of those countries.

8. Data Subject Rights

8.1 Your Rights

As a data subject under the GDPR and Greek Law 4624/2019, you have the following rights in relation to the personal data we hold about you. These rights are subject to certain limitations and exceptions as provided for under applicable law:

• Right of Access (Article 15 GDPR): You have the right to obtain confirmation as to whether Hellenic Talent is processing personal data concerning you and, if so, to obtain a copy of that personal data together with certain supplementary information about the processing, including the purposes of processing, the categories of data concerned, the recipients or categories of recipients to whom data has been or will be disclosed, the envisaged retention period, and your rights in relation to the data.
• Right to Rectification (Article 16 GDPR): You have the right to obtain the rectification of inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• Right to Erasure (Article 17 GDPR): You have the right to request the erasure of personal data concerning you without undue delay in certain circumstances, including where: the data is no longer necessary in relation to the purposes for which it was collected; you withdraw consent on which processing is based (and no other legal basis applies); you object to processing and there are no overriding legitimate grounds; the data has been unlawfully processed; or erasure is required to comply with a legal obligation. This right is subject to limitations where processing is necessary for compliance with a legal obligation, for the establishment, exercise or defence of legal claims, or for other purposes set out in Article 17(3) GDPR.
• Right to Data Portability (Article 20 GDPR): Where processing is based on your consent or on the performance of a contract, and the processing is carried out by automated means, you have the right to receive personal data concerning you in a structured, commonly used and machine-readable format, and to transmit that data to another controller without hindrance from Hellenic Talent. Where technically feasible, you may also request that we transmit the data directly to another controller of your choice.
• Right to Object (Article 21 GDPR): You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests (Article 6(1)(f) GDPR). Where you lodge an objection, Hellenic Talent will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You have an unconditional right to object to processing for direct marketing purposes at any time.
• Right to Restriction of Processing (Article 18 GDPR): You have the right to obtain restriction of processing in certain circumstances, including where: you contest the accuracy of the data (for a period enabling Hellenic Talent to verify accuracy); the processing is unlawful and you oppose erasure and request restriction instead; Hellenic Talent no longer needs the data but you require it for the establishment, exercise or defence of legal claims; or you have objected to processing pending verification of whether legitimate grounds override your objection. Where processing is restricted, Hellenic Talent will store the data and only otherwise process it with your consent or for limited purposes specified by law.
• Right to Withdraw Consent (Article 7(3) GDPR): Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal. Withdrawal of consent for marketing communications can be effected at any time via the unsubscribe mechanism included in each marketing communication, or by contacting us directly.

8.2 How to Exercise Your Rights

To exercise any of the rights set out above, please submit a written request to Hellenic Talent using the contact details provided hereinbelow. We will respond to your request within one (1) month of receipt. In the case of complex or numerous requests, this period may be extended by a further two (2) months, in which case we will inform you of the extension and the reasons for the delay within the initial one-month period.

8.3 Right to Lodge a Complaint

If you consider that the processing of your personal data by Hellenic Talent infringes the GDPR or applicable Greek data protection law, you have the right to lodge a complaint with the competent supervisory authority. The supervisory authority in Greece is the Hellenic Data Protection Authority (HDPA).

You also retain the right to seek judicial remedy pursuant to Article 79 GDPR. We nonetheless encourage you to contact us in the first instance, as we will endeavour to resolve any concerns informally and promptly.

The contact details of the Hellenic Data Protection Authority are as follows: Hellenic Data Protection Authority (HDPA), 1-3 Kifissias Avenue, 115 23 Athens, Greece; Telephone: +30 210 6475600; Website: www.dpa.gr.

9. Automated Decision-Making and Profiling

Hellenic Talent uses some automated artificial intelligence systems to support certain functions of its services, including facilitating the matching of freelancers with client opportunities. This section provides the information required under Article 22(3) of the GDPR regarding automated decision-making and profiling activities.

9.1 Algorithmic Matching and Ranking

HT uses a general-purpose AI tool as part of the preliminary suitability assessment of freelancers for each specific client project, and, on an ongoing basis, for the classification, categorisation, and evaluation of freelancer skills and experience. The AI tool analyses freelancer profile data — including skills, expertise, experience, portfolio content, and availability — to generate preliminary suitability assessments. These assessments are used by HT team members as one input among several in the shortlisting process. The AI tool does not make binding decisions, and does not autonomously determine which freelancers are presented to clients. All shortlisting and engagement decisions are made by HT team members with human oversight.

9.2 Absence of Solely Automated Decisions

Where algorithmic matching or ranking relates to decisions that have a significant legal or similarly significant effect on a user — for example, decisions that substantially affect a freelancer's access to Client Engagements— Hellenic Talent ensures that such decisions are not made solely on the basis of automated processing without human involvement, in accordance with Article 22(1) of the GDPR.

In practice, final decisions on shortlisting, hiring, contract award, and engagement are made by human users (HT team members, clients and freelancers) and not by Hellenic Talent's automated systems. Our algorithms serve as decision-support tools only.

9.3 Right to Human Intervention

If you believe that an automated decision has been made about you that has a significant effect on your use of the platform, you have the right to:

• Request human review of the automated decision by a member of Hellenic Talent's team;
• Express your point of view with respect to the automated decision; and
• Contest the decision if you consider it to be incorrect or unfair.

To exercise these rights, please contact us using the details set out hereinbelow. We will review your request and respond within a reasonable timeframe.

10. Children's Data

The Hellenic Talent platform is not intended for use by individuals under the age of eighteen (18) years. Hellenic Talent does not knowingly collect, solicit, or process personal data from individuals under the age of eighteen (18). By registering in our platform you confirm that you are at least eighteen (18) years of age.

If we become aware that we have inadvertently collected personal data from a child without appropriate consent, we will take immediate steps to delete such data from our systems. If you become aware that a minor has provided us with personal information in violation of this Privacy Policy, please contact us immediately.

11. Changes to this Privacy Policy

Hellenic Talent may update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or the services we offer. We will indicate the date on which the notice was last updated at the top of the document.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of the platform following notification of changes to this Privacy Policy will constitute your acknowledgement of the updated notice, to the extent permitted by applicable law. Where the updated notice requires renewed consent, we will obtain such consent before processing your data on the revised basis.

12. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by Hellenic Talent, including requests to exercise your data subject rights under Section 8, please contact us using any of the following means: