Privacy Policy

We collect personal data in the following circumstances:

SME network applications

When you voluntarily submit an application to join our expert network:

• Data collected: name, email address, and CV/resume file (plus any information you include in your CV)
• Purpose: evaluating SME applications, contacting candidates, and managing onboarding communications
• Legal basis: taking steps at your request prior to entering a contract (Article 6(1)(b) GDPR) and our legitimate interest in recruitment and network management (Article 6(1)(f) GDPR)

Providing this data is necessary for us to review your application.

EU Pay Transparency Directive readiness questionnaire

When you voluntarily complete our EU Pay Transparency Directive readiness questionnaire:

• Data collected: organisational information, questionnaire responses, and contact details (work email and report delivery email)
• Purpose: assessing your organisation’s readiness in relation to the EU Pay Transparency Directive, preparing your assessment results, and issuing your readiness report
• Legal basis: your consent (Article 6(1)(a) GDPR) and our legitimate interest in service delivery and aggregated/anonymised internal analysis (Article 6(1)(f) GDPR)

Information submitted through this questionnaire is treated as confidential and is not shared with third parties except where required for assessment administration or by law.

We do not sell or share personal data, except with:

• Email and hosting providers strictly for receiving and processing SME applications and PTD questionnaire responses

These providers act as data processors under GDPR.

We process your personal data inside the European Economic Area (EEA) wherever we can. Some of the providers we rely on belong to international groups and may process data outside it — in particular Microsoft, which carries our email and hosts the appointment booking page.

Where personal data does leave the EEA, the transfer is made under one of the safeguards Chapter V of the GDPR allows:

• an adequacy decision of the European Commission, including the EU–US Data Privacy Framework for certified providers in the United States; or
• the European Commission’s Standard Contractual Clauses, together with any additional technical and organisational measures the transfer requires.

You can ask us which safeguard applies to a particular transfer, and for a copy of it, at info@simulen.com.

• SME application data (including CVs) is retained only for as long as needed to evaluate your application and maintain our expert network records, unless a longer period is required by law
• PTD questionnaire data is retained for as long as needed to deliver your results and readiness report, support follow-up communications, and maintain internal assessment records, unless a longer period is required by law

This website sets no cookies. It carries no analytics, no tracking pixels, no advertising technology and no third-party scripts; even the fonts are served from our own server rather than a font network. Nothing here follows you between sites or builds a profile of you. That is why you were not asked to accept anything when you arrived: there is nothing to accept.

Two things are worth naming precisely, because “no cookies” is not the same as “nothing at all”:

• If you dismiss the Insights prompt on the home page, your browser remembers that for the rest of the session in its own session storage — a single value, cleared when you close the tab, never sent to us and unable to identify you.
• The Pay Transparency Directive tool at ptd.simulen.com shows country flags served by flagcdn.com. Loading an image from another server means that server sees your IP address and browser user agent, as it would for any image on the web; no script, cookie or identifier is involved.

Our web server keeps ordinary technical request logs, which include IP addresses, so that the site can be operated and abuse investigated. When you submit the SME application form or the PTD questionnaire, we also keep a short-lived, one-way hashed record of the submitting address so the forms can be rate-limited. Neither is used to profile you or combined with anything else.

Under the GDPR you have the right to:

• be informed about how your personal data is used — which is what this policy is for;
• access the personal data we hold about you, and receive a copy of it;
• rectification — have inaccurate data corrected and incomplete data completed;
• erasure — ask us to delete your data where one of the grounds in Article 17 applies;
• restrict processing — ask us to hold your data without using it, in the circumstances Article 18 sets out;
• data portability — receive the data you gave us in a structured, commonly used, machine-readable format, and have it sent to another controller where that is technically feasible. This applies to data you provided, processed by automated means on the basis of your consent or a contract — your SME application and your PTD questionnaire responses;
• object — object at any time to processing we carry out on the basis of our legitimate interests, on grounds relating to your particular situation. If you object, we will stop unless we can show compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for legal claims. Where we ever process your data for direct marketing, you can object at any time and we will stop, no reasons needed;
• withdraw consent at any time where processing is based on your consent. Withdrawing it does not affect the lawfulness of what we did before you withdrew it.

To exercise any of these, write to info@simulen.com. We will respond within one month of receiving your request, and will tell you if we need to extend that (by up to two further months) because the request is complex. Exercising your rights is free; we may charge a reasonable fee, or decline, only where a request is manifestly unfounded or excessive, and we will explain why.

If you believe we have handled your data badly, please tell us first so we can put it right — but you can lodge a complaint with the Hellenic Data Protection Authority at any time: https://www.dpa.gr.

For any questions regarding this Privacy Policy, please contact:

info@simulen.com