This Policy applies to all Personal Data in our possession or under our control. Definitions of terms used in Policy:
“Data Controller” means the person or organization which determines when, why and how to process Personal Data and implements appropriate technical and organizational measures to comply with the Law;
“Data Processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller;
“Data Protection Officer” means the person who is formally appointed with the purpose of ensuring that we are aware of and comply with our data protection responsibilities and obligations according to the Law;
“Data Subject” means a living, identified or identifiable natural person about whom we hold Personal Data;
“Personal Data” means data about the Data Subject who can be identified: a. from that data; or
The Personal Data we may collect and use includes, without limitation, names and identification information such as email address, telephone numbers, copy of your passport, utility bill.
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure or destruction;
“Third Party” means the recipient of your Personal Data as defined below.
The kind of information we collect about you:
The purpose of the Processing of your Personal Data is largely based on each of our services that you have requested:
In the event that you provide us with Personal Data about other individuals (e.g. your colleague or client), you warrant to us that you have obtained such individuals’ permission to do so.
We do not collect or process Personal Data of children without prior consent from their parents or legal guardian.
Why do we process your Personal Data
The purpose of the Processing of your Personal Data is largely based on each of the services that you have requested or that have been agreed with you. In general, your Personal Data is processed, within the scope of our business relationship with you.
On what legal basis do we process your Personal Data:
We may collect and process your Personal Data for any and/or all the following purposes:
Who Receives your Personal Data:
Your Personal Data may sometimes be shared or made accessible to the following Third Parties in order for us to perform our services to the highest standard possible:
In case of an absence of your consent, your Personal Data will not be disclosed to any Third Party, other than the above-mentioned, unless the disclosure is required and/or mandatory under the provisions of any legislation, regulation or upon governmental, supervisory, competent authority request.
Our employees have signed a Confidentiality and Non – Disclosure Agreement.
When we enter into agreement with a Third Party that requires your Personal Data to be processed by that Third Party, we enter into a processing agreement with that party in order to ensure that they process the Personal Data strictly according to our instructions and to implement the appropriate administrative, physical and technical measures to protect the Personal Data from unauthorized or accidental use, collection, access, damage, loss or disclosure.
Transferring your Personal Data outside European Union (‘EU’) and/or European Economic Area (‘EEA’)
We generally do not transfer Personal Data to countries outside of EU and/or EEA (“Third Countries”), except where required by the purposes set out in this Policy. If we need to transfer your Personal Data to Third Countries for any other purpose, we always ensure that the transfer meets the relevant requirements of the Law, and we take all steps required to ensure that your Personal Data continues to receive our standards of protection.
When can Personal Data be transferred outside of the EU and the EEA:
How long will we store your Personal Data
We will cease to retain your Personal Data or remove the means by which the Personal Data can be associated with you, after seven (7) years where your relationship with us has been terminated and/or as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data were collected and are no longer necessary for legal or business purposes (except where retention is permitted or required by the Law and/or other applicable laws).
Protection of Personal Data:
To safeguard your Personal Data from unauthorized access, collection, use, damage, loss, disclosure, copying or similar risks, we have introduced appropriate administrative, physical and technical measures such as up to date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data to Third Parties. We also allow access to Personal Data only to those employees who need to know such data and they will only process your Personal Data on our instructions.
However, no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guarantee, we try to protect the security of the Data Subject’s Personal Data and we constantly review and enhance our information security measures.
What are your rights in relation to your Personal Data
Right to access
Request access to your Personal Data (commonly known as a “data subject access request“): This enables to receive a copy of your Personal Data that we hold about you at any time;
Right to rectification
Request to correct or update nay of your Personal Data which we hold. This enables you to have any incomplete or inaccurate information we hold about you corrected. We strive to retain only Personal Data that is accurate, complete and up to date;
Right to data portability
Request the transfer of your Personal Data to another party;
Right to erasure
Request to delete your Personal Data from our records. However, we may need to retain certain information for legal or administrative purposes, such as record keeping and detect fraudulent activities.
Right to restrict processing
Request to restrict the use of your Personal Data;
Right to object:
You have the right to object to the collection and use of your Personal Data (e.g. when we use your Personal Data on the basis of your consent you can withdraw that consent at anytime);
Right to lodge a complaint:
You have the right to lodge a complaint about the use of your Personal Data by contacting the Office of the Commissioner for Personal Data Protection in Cyprus at at the contact details below:
Office address: Iasonos 1, 1082 Nicosia, Cyprus
Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus
Tel: +357 22818456
Fax: +357 22304565
If you wish to exercise any of your rights, you may contact our Data Protection Officer in writing or via email at the contact details provided below:
Address: 58 Raphael Santi, Nefeli Court 11, Ground Floor, 6052 Larnaca, Cyprus Email: Data Protection Officer at firstname.lastname@example.org
The Data Protection Officer has the right to require the individual making the request to provide certain identification documents/information to be able to verify his/her identity.
The Data Protection Officer will respond to your requests within thirty (30) days after receiving your email/letter.
How do we protect your Personal Data
To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying or similar risks, we have introduced appropriate administrative, physical, and technical measures.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guarantee, we try to protect the security of the Personal Data by constantly reviewing and enhancing our information security measures.
Effect of Policy and Changes to Policy:
We keep this Policy under review, and we may modify it from time to time without any prior notice. You should review our Policy on our website periodically to ensure that you are aware of any such modifications/updates.
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