I. Digital Assistant Service Terms of Use
The public limited banking company with the corporate name “ALPHA BANK SOCIETE ANONYME”, registered in Athens (40 Stadiou Street, 10564, tel.: +30 210 326 0000), General Commercial Register (GEMI) number 159029160000 and email address CustomerService@alpha.gr (hereinafter “Alpha Bank” or “Bank”) – through its www.alpha.gr website, its digital banking networks for individuals (web banking, Alpha Bank mobile app and myAlpha Mobile) and businesses (business web banking and business mobile app) (hereinafter jointly “digital banking channels”) – offers adult users (aged over 18 years old) who are natural persons (either visitors to its www.alpha.gr, website, or subscribers to its digital banking channels, or authorised users representing and acting on behalf of a digital banking channel subscriber), a free, informative, query-solving digital assistant service (hereinafter the “Service”).
Users are kindly requested to read the following Service Terms of Use (hereinafter “the Terms”) carefully, as well as the privacy notice concerning the processing of their personal data, which follows in a separate section under II, and accept them fully and unreservedly before they use this Service. In any case, use of the Service constitutes in itself full and unreserved acceptance of the Terms governing it on the part of the users.
In case users disagree with the Terms or are aged under 18, they are obliged to stop using the Service and to refrain from using it in the future. The Terms are additionally governed by the Terms of Use of the Alpha Bank website (www.alpha.gr), the Special Terms of Registration and Use of Personal Digital Banking Services, and the Special Terms of Use of Business Digital Banking Services.
Where there is any conflict between these Terms and the Terms of Use of the www.alpha.gr website or the Special Terms for Registration and Use of Personal Digital Banking Services or the Special Terms of Use of Business Digital Banking Services, these Terms prevail since they are more specific.
It is expressly clarified that the acceptance of these terms by any user in their capacity as an authorised user of a digital banking channel subscriber shall be deemed as acceptance on behalf of the subscriber, who shall be jointly and severally liable with the user for compliance with these terms.
A. Description of the Service
The Service uses artificial intelligence technology and enables the exchange of messages with users. The Service may be used in either Greek or English. Users have been informed, acknowledge and accept that, when using the Service, they are interacting with an artificial intelligence system and not with a natural person (subject to the provisions of section E). It is expressly clarified that the Service does not provide the capability to enter into, submit orders for or execute banking transactions. The Service is designed in such a way that it operates individually for each user and, while being used by a specific user, it does not allow interference from or parallel use thereof by another user.
Via the Service users receive general information directly in real time, through message exchange, about how to navigate the www.alpha.gr website and the digital banking channels, as well as answers to questions relating to their communication with Alpha Bank and to its products and services.
The use of the Service, as mentioned above, presupposes the unreserved and full acceptance of the Terms of Use of the www.alpha.gr website, the Special Terms of Registration and Use of Personal Digital Banking Services, the Special Terms of Use of Business Digital Banking Services and these Terms.
Alpha Bank is entitled to amend these Terms at any time without notice, by posting the most recent ones on its www.alpha.gr website, as well as terminate, restrict or suspend, at any time, the users’ ability to use the Service in whole or in part, temporarily or permanently, at its unfettered discretion (by way of example, for maintenance or security purposes), simply by informing them about this through its website and/or digital banking channels.
In the context of providing information via the Service, Alpha Bank may direct users to special links to obtain information about its products and services. In this case, before using the product or service, users must accept any special terms in effect from time to time.
B. User obligations
The Service must be used exclusively for lawful purposes and in a manner which does not limit or prevent use of the Service by third parties. Users are obliged to comply with the rules and provisions of the Greek, European and international law, the accepted principles of morality, and these Terms, and to refrain from any unlawful and abusive conduct which could have an impact on other users or third parties in general, and cause malfunctioning to the Service or harm to it, and consequently malfunctioning or harm to Alpha Bank and its systems. In such cases, Alpha Bank is entitled to refuse exchanging information and data with the user and terminate their ability to use the Service in part or in whole, temporarily or permanently.
Users are obliged to refrain from any attempts to breach, alter, undermine or circumvent the operation of the Service, as well as from any interference in any manner with its technical or operational infrastructure. This includes, as an indication, actions that may cause disruption, performance degradation or security breaches of the Service, exchange of messages with illegal, unethical, false, offensive, threatening, insulting, related to trade secrets or generally confidential data, defamatory, especially concerning Alpha Bank and its personnel, and misleading content, particularly regarding the user’s identity. The content of such messages and the relevant information and data are the product of the users’ own will, relate to them and are their exclusive responsibility and/or the responsibility of the digital banking channel subscriber on whose behalf users act (in case of authorised users). Through the Service, Alpha Bank cannot check the accuracy and legitimacy of all the content in the messages posted and transmitted by users, and cannot be deemed to accept or endorse in any manner the personal ideas and views expressed by any user via the Service nor can it be deemed to be responsible for acts or omissions or for any harm or damage caused to any third party.
It is also prohibited without Alpha Bank's prior written consent to amend, publish, transmit, transfer, reproduce, distribute, present or otherwise use and exploit the content of the Service in part or in whole, in any manner or way for commercial or other purposes, otherwise users and/or the digital banking channel subscribers (in case of authorised users) accept that they shall be liable to compensate Alpha Bank and make restitution of any loss suffered by it.
Where Alpha Bank becomes involved in any dispute or is called upon to pay any manner of compensation to third parties on grounds due to breach of the user’s obligations referred to above, the user and/or the digital banking channel subscriber (in case of authorised users) shall be obliged to compensate Alpha Bank on these grounds.
C. Availability of the Service and limitation of liability
The purpose of the Service is exclusively to provide information about Alpha Bank’s products and services. Alpha Bank does not warrant the availability of, or uninterrupted or unhindered use of or access to, the Service. In addition, without providing a warranty in this regard, and consequently without being liable, Alpha Bank shall make concerted efforts to ensure that the information provided via the Service relates to questions posed by users and is complete, accurate, up-to-date, correct, suitable and clear. However, under no circumstances, including negligence as provided by law, shall Alpha Bank be liable for any errors, omissions or deficiencies relating to such information, or for any failure to keep such information up to date, for any delays, interruptions or inability to transmit the information, or for any damage suffered by users and/or digital banking channel subscribers as a result of using, being unable to use or relying on such information, or as a result of the limitations of the Service set out immediately below. The Service uses artificial intelligence technology and, therefore, the absolute accuracy, adequacy, appropriateness and completeness of its responses cannot be guaranteed. The Service may also fail to understand a query correctly or fully, or may be unable to provide a relevant or correct response. Use of the Service is optional for users and does not replace communication with the Bank's officers, where required.
Information provided via the Service does not constitute financial, legal or other advice, encouragement or exhortation to enter into any investment or other transaction and Alpha Bank is not liable for use of the Service by users who act on their own initiative. Moreover, the furnishing of information which was requested does not entail any commitment on Alpha Bank’s part to provide the relevant product or service.
The user acknowledges that Alpha Bank does not warrant and is not liable in case the information provided via the Service is through third-party apps and websites, both for the authenticity and quality of the information content and for the operation of the apps.
The user acknowledges that during its use, the Service will never ask them to disclose personal or third-party data, such as account and card details, PINs and passwords for Alpha Bank services. If a message with such content appears, the user must ignore it and immediately inform Alpha Bank by calling the Call Centre on +30 2103260000 or using any other reasonable means.
The user is exclusively responsible for having the necessary hardware, software, telecommunications equipment, as well as any other services needed to access the Service. Users are also responsible for protecting their own system from viruses and other malware and for ensuring they have selected the necessary security and privacy settings.
Use of the Service and submission of queries do not require or necessitate the entry or disclosure of users' or third parties' personal data or information covered by special banking secrecy or any other confidentiality obligations. For this reason, users are advised not to include their own or third parties' personal data or information covered by banking secrecy or other confidentiality obligations in their queries. By way of example, users are advised not to enter their full name, account details, card numbers, balances, PINs, CVVs, usernames, passwords or any other identification or security information in their queries.
D. Applicable law and jurisdiction
These Terms shall be governed by the laws of Greece and exclusively the courts of Athens shall be competent to interpret and resolve all disputes arising from use of these Terms.
E. Pilot operation of the transfer of text-based chats from the digital assistant to a human agent (Live Agent Chat Support)
Alpha Bank may, as part of a pilot and trial operation, offer the option of transferring selected chats, at its discretion, from the Digital Assistant to a human representative (Live Agent Chat Support). This functionality is provided on a pilot basis, as a supplement to the Digital Assistant Service, subject to the terms and limitations set out below. It is expressly clarified that it does not constitute a service with continuous and guaranteed availability.
During the pilot phase, Live Agent Chat Support is available exclusively through the Digital Assistant operating on the www.alpha.gr channel, for a limited period during the day. The days and hours of availability are determined by and may vary depending on Alpha Bank's business and operational needs, without any commitment to provide this functionality on specific days or during specific hours. The availability of the Digital Assistant on other channels does not imply that Live Agent Chat Support is available through those channels. Even during the periods when Live Agent Chat Support is operational on the selected channel, the option to transfer a chat to a representative is subject to the availability of representatives, the volume of service requests, technical capabilities and the fulfilment of the eligibility and chat routing criteria established by the Bank from time to time. Submitting a request to connect with a representative, even repeatedly, does not guarantee that a representative will take over the chat, nor does it guarantee any specific waiting time or time for completing the services. If a chat cannot be transferred to a representative, users may be assisted through Alpha Bank's other available communication channels.
Alpha Bank may, at any time, modify, restrict, suspend or discontinue the pilot functionality in question, including, by way of example, for organisational, technical, business or security reasons.
Live Agent Chat Support is exclusively intended for general information requests from users and do not require user identification. The provision of personal data or information covered by banking secrecy is neither necessary nor recommended when using Live Agent Chat Support, in accordance with the provisions of Section C above.
It is expressly clarified that users are informed before their chats are transferred to a representative and that, to facilitate their assistance, the necessary content of their chats with the Digital Assistant is transferred to the representative, in accordance with the provisions of the Notice on the Processing of Personal Data set out in Part II below.
The terms of this Section E apply, where applicable, in addition to the remaining Terms of Use of the Digital Assistant Service and shall be interpreted in conjunction with them. In the event of any conflict, the terms set out in Section D shall prevail with respect to the specific Live Agent Chat Support pilot functionality, as they are more specific.
II. Processing of personal data
Alpha Bank hereby informs users, in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter the “GDPR”), in its capacity as Data Controller, that, in the context of using the Digital Assistant Service (hereinafter the “Service”), it processes the personal data of users of the Service as described below.
For the provision of the Service, Alpha Bank collects and processes the questions submitted by users through the Service and the corresponding responses provided by the Digital Assistant, together with their submission timestamps (date and time). The aforementioned data is retained in text form for a period of six (6) months, after which it is immediately deleted.
Note that use of the Service through the digital banking channels for businesses and individuals results in the identification of the respective user-subscriber by the Bank.
If users accessing the Service through the Bank's www.alpha.gr website are routed to a live chat with a Bank representative, as specifically described in Section E of the Terms of Use of the Service (Live Agent Chat Support), the Bank will transmit to BARPHONE Commercial and Industrial Société Anonyme for Electronic Equipment and Telecommunications Systems, with General Commercial Registry (GEMI) number 002326501000 and Tax Identification Number 094493895, falling under the jurisdiction of the Attica Tax Procedures and Service Centre (KEFODE), acting as a data processor on behalf of the Bank, a summary of users' communications with the Digital Assistant (having first anonymised any personal data that users may have included in the chat), for the purpose of connecting users with a Bank representative and providing them with assistance. Users' chats with a Bank representative will be retained for a period of 6 months, after which they will be deleted.
The purposes of the processing of users' personal data by the Bank in the context of the Service are to respond to queries submitted by users of the Service [on the legal basis of performing the contract entered into between the Bank and users, following the latter's acceptance of the Terms of Use of the Service (Article 6(1)(b) of the GDPR)], as well as to improve and enhance the Service, investigate and resolve technical issues arising in connection with its provision, safeguard security and investigate any fraud or other breaches that may concern the www.alpha.gr website and/or the digital banking channels for businesses and/or individuals and/or the Service [on the legal basis of the Bank's legitimate interests (Article 6(1)(f) of the GDPR)].
The Bank does not use the data being processed to carry out profiling, conduct promotional activities or make automated decisions.
Note that, in the context of the Service, the Bank operates an Artificial Intelligence (AI) system with which users interact. The Digital Assistant does not retain a memory of its chats with users. Consequently, neither users nor the Digital Assistant can access their previous chats with each other.
In the context of providing the Service, Alpha Bank may evaluate users' chats with the Digital Assistant using an Artificial Intelligence (AI) system, to determine the level of service provided to users and their satisfaction with the Service. This processing aims to categorise the interactions of users of the Service (for example, as positive, neutral or negative) based on the content and tone of their communications and chats with the Digital Assistant. This chat does not produce legal effects or affect users' access to the Bank's products or services. The resulting data is used exclusively to identify areas for improvement of the Service, generate statistical reports on customer satisfaction (without users' personal data) and ensure the proper provision of the Service.
Note that data entered by users into the Digital Assistant will not be used to train the Artificial Intelligence models used by the Bank in the context of providing the Service to users.
The Bank's processing of personal data of users of the Service is governed by this Notice, which applies in parallel with and supplements the Alpha Bank Personal Data Protection Policy applicable to the Bank's websites (hereinafter the “Personal Data Protection Policy”) and is permanently available on the Bank's main website (Personal data protection | ALPHA BANK).
Specifically, for users who access the Service through the digital banking channels for businesses and/or individuals, this Notice is additionally provided and applies in parallel with (in addition to the aforementioned Personal Data Protection Policy) the general “Notice on the Processing of Personal Data” (hereinafter the “General Notice”), which concerns the processing of personal data of persons conducting transactions with the Bank in the context of its overall business activities for the provision of products and services, and is continuously available on its website (GDPR.pdf).
The recipients of the personal data processed in the context of the Service, in their capacity as data processors, are: (a) “Moveo.AI” and (b) in the event of users communicating with a Bank representative through the Digital Assistant (Live Agent Chat Support), BARPHONE Commercial and Industrial Société Anonyme for Electronic Equipment and Telecommunications Systems, with General Commercial Registry (GEMI) number 002326501000 and Tax Identification Number 094493895, falling under the jurisdiction of the Attica Tax Procedures and Service Centre (KEFODE). Any other recipients are specified in the Personal Data Protection Policy and the General Notice, respectively.
For information on the exercise of the rights of users of the Service, the details of the Data Controller and the Data Protection Officer, and other information concerning the processing and protection of the personal data of users who access the Service through the www.alpha.gr website, such users may refer to the Personal Data Protection Policy. Users who access the Service through the digital banking channels may also refer to the General Notice, respectively.
We hereby inform you that the Bank takes appropriate organisational and technical measures to ensure and continuously maintain compliance with the principles governing the processing of personal data, so that the data being processed is protected against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, and any other form of unlawful processing. By way of example, these measures include the use of dedicated, multi-layered security mechanisms to protect services provided over the internet, the protection of the Bank's systems, as well as the encryption, pseudonymisation or anonymisation of personal data, where required.
Users are advised not to enter their own or third parties' personal data when using the Service, including, by way of example, and not limited to, identity card numbers, tax identification numbers, telephone numbers, account or card numbers, transaction amounts, account balances, passwords for accessing systems and applications, PINs, CVVs, one-time passcodes (OTPs), or any details and information covered by banking secrecy or other confidentiality obligations. In the same context, users must refrain from entering special categories of personal data, including, by way of example, data concerning health, or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union memberships. The aforementioned data will never be requested by the Bank, as it is not required for the operation and use of the Service.
If users provide third parties' personal data when using the Service, they must have previously informed such persons, in accordance with this Notice, and obtained their relevant consent, where required.
Finally, note that the responses provided by the Digital Assistant will not include users' or third parties' personal data.