Effective Date – 01.11.2022
Protection of your personal data is key to us! As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact. We will process your personal information at all times in accordance with applicable privacy and data protection laws.
What is Personal Data?
Personal data (also “Personally identifiable information” or PII) includes individual information by which you as a natural person are or can be identified by, e.g., your name, address, telephone number, email address or date of birth, as well as information which does not reveal your name, but which relates to you or your device and enables you to be treated individually.
Non-personally identifiable information (also known as non-PII) is information that cannot be connected to your real identity, e.g., the number of users visiting our website or any other kind of aggregated information.
The information we collect
We may collect some or all of the following personal information in case you voluntarily provide it to us when you use this website:
- Information included in your Personal Messages
You have the right to withdraw at any time, without affecting the legality of the processing carried out based on your consent prior to its withdrawal. Please note that some parts of the Website may not function properly if the use of certain cookies is rejected.
You can also manage your cookie preferences and opt-out from the collection and management of your data through the following websites:
How and why we collect information
We collect this information through the Website. The reason why we may collect the personal data you provide to us is to deliver the specific information or service you have requested. For example, if you request to contact us via the “Get in touch with us” form or submit an enquiry in relation to a job or career opportunity through this site, we need your email or telephone in order to contact you.
How we use your information
We collect the personal data that you voluntarily provide to communicate with you and in some cases in order to provide you with information, special offers, services or information in accordance with your expressly expressed wishes.
In more detail, we may use the information you provide to us for the following reasons:
|Purpose||Legal basis of processing|
|To communicate with you.||Consent – we only use your personal information for this purpose if you have asked us to do so. You can withdraw your consent at any time.|
|To provide you with information that you have requested e.g. a newsletter.||Consent – we only use your personal information for this purpose if you have asked us to do so. You can withdraw your consent at any time.|
|To provide you with our services and to perform our contract.||Contract – if processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.|
|To improve our services and protect our business interests.||Our legitimate interests – we use your personal information to improve the services we provide to you and other Website users.|
|To serve personalized ads on our Website, to measure and optimize the performance of advertisements and the display of more relevant advertisements.||Consent – The processing will always be carried out on the condition that we have previously received your consent, which you have the right to withdraw at any time, without affecting the legality of the processing carried out based on your consent prior to its withdrawal.|
|To process and consider your job application.||Consent – we use the personal information you have provided to us to assess your job application, and to keep you updated throughout the application process.|
|To comply with our legal obligations.||Compliance with a legal requirement – We may process your personal data in order to comply with our legal obligations, arising from the provisions of the legislation, judgments, governmental regulations or decisions. We may also process your personal data in order to investigate complaints, identify and prevent fraud, assess situations relating to possible threats to the security of any person or violations of our policies or terms.|
How we store information and for how long
The information you directly provide to us is stored in our secure databases. We take the appropriate technical and operational measures to ensure that your personal information disclosed to us is kept secure and protected.
The data storage time is decided based on the following specific criteria, as appropriate on each case:
- When the processing is necessary for compliance with legal obligations under the applicable legal framework, your personal data will be stored for as long as required by the relevant provisions.
- When the processing is based on a contractual relationship, your personal data are stored for as long as is necessary to perform the contract and for the establishment, exercise or defense of legal claims in accordance with the contract.
- For marketing purposes, your personal data are stored until their withdrawal. You have the right to withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of the processing based on consent before its withdrawal.
How we secure the information
The company takes the appropriate technical and organizational measures to ensure compliance with the legislation for the protection of personal data of its customers, as well as the users of its website. The company also ensures, through the above measures that access to personal data is not given to anyone other than the appropriate authorized persons, and only for the purposes of processing, specified in this policy.
The Company recognizes the importance of the security of your Personal Data and takes all necessary measures, with the most modern and advanced methods, to ensure your maximum security. All information related to your personal information and transactions is secure and confidential. To ensure the confidentiality of data transfer, we use proper encryption protocols.
With whom we share the information
Your personal data may be accessed by the following categories of recipients:
- Our employees
Your data may be transferred to our employees who are in charge of assessing your requests, managing and performing your contract (s) with the company, meeting the obligations arising from the contract (s) and the obligations imposed by law. All of our employees have a sufficient and significant level of awareness to protect your personal data and are bound by a confidentiality clause.
- Law enforcement authorities
We may share your personal data with the competent authorities, as long as this is permitted by law, in order to identify or prevent criminal acts and other unlawful activities.
- External partners, legal consultants etc.
In the course of managing court proceedings and for the purposes of establishing, exercising and defending legal claims we may transfer your data to external lawyers in the event that their assistance is considered necessary for the management of the case and the defense of our rights.
- Third party Partners
Furthermore, we may also transfer your personal data to cooperating companies for the purpose of providing our services (such us contacting you about our products, services and offers). We always ensure that the processors we engage with fulfill the requirements and provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will ensure the protection of your rights.
In connection with the collected data, the GDPR awards you as a Data Subject the following rights, which you can exercise by contacting us.
- Right to withdraw consent: You may withdraw your consent of processing your personal data at any time.
- Right of correction/editing: You may ask us to correct your personal data.
- Right of limitation: You may ask us to restrict the processing of your personal data if:
- You question the accuracy of your personal data for the time it will take to verify the accuracy of the personal data;
- Processing is illegal and you request the restriction of processing instead of the deletion of your personal data;
- We no longer need your personal data, but you need it to support, exercise or defend legal claims.
- Right of access: You may request from us information about the personal data of yours that we retain, including information about the categories of such personal data, the purpose of their use, where it was collected from, to whom they have been made known. You can obtain from us free of charge a copy of the personal data we keep for you. We reserve the right to charge a reasonable fee for any further copy you may request.
- Right of data portability: At your request, we will transfer your data to another controller, where technically feasible, provided that the processing is based on your consent or is necessary for the performance of a contract. Instead of receiving a copy of your personal data, you may ask us to transfer the data to another controller.
- Right to delete: You may ask us to delete your personal data if:
- they are no longer necessary in relation to the purposes for which they were collected or processed,
- you wish to exercise your right to object to any further processing of your personal data,
- you withdraw your consent and there is no other legal basis for processing,
- your personal data has been unlawfully processed unless the processing is necessary (i) to comply with a legal obligation, which requires processing by us or (ii) to support, pursue or defend legal claims.
- Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interest or on legitimate interests of third parties. In such case, we shall no more process your personal data unless we can prove that such use is justified by a legal reason and a legal right of ours superseding your right to object. If you object to us processing your data you are kindly requested to clarify whether you wish that such data is deleted or limited.
- Right to lodge a complaint: In the event of an alleged breach of applicable privacy law, you may lodge a complaint with the competent data protection supervisory authority. You may contact the Cypriot Supervisory authority through the following website (dataprotection.gov.cy).
- Limitation of access: In some cases we may not be able to provide access to all or some of your personal data under legislation. If we refuse your request for access, we will inform you of the reason for this refusal. Also, in some case we may not be able to search for your personal data because the information you provide is inadequate. In such cases, where we cannot identify you as a data subject, we are unable to comply with your request to enforce your legal rights as described in this article, unless you provide us with additional information that allows you to be identified.
The applicable law is Cypriot law, the General Regulation on the Protection of Personal Data 2016/679/EU, and in general the applicable national and European legislative and regulatory framework for the protection of personal data.
We may update this policy from time to time in order to reflect changes to the functionalities or services provided by our website or for other legal and regulatory reasons.
If we make material changes to our policy, we will notify you by posting the revised policy on this website. Please check the website regularly for any changes to this Policy.
If you have questions about the privacy aspects of our website, please contact us at email@example.com or contact our DPO at: firstname.lastname@example.org.