About this Policy
This privacy notice supplements any other privacy notices that we may provide to you at the point that we collect data from you and should be read in conjunction with those notices.
Postal address: 22, Elia Papakyriakou Street, 2415, Engomi, Nicosia, Cyprus
We will use reasonable efforts to promptly determine and remedy the problem or the question addressed.
By using the Website, you consent to this policy. We are registered with the Information Commissioner’s Office for this purpose.
How we collect personal data
We will collect, process and store personal data only if it is directly provided to us by you. You may do this in your capacity as the user of this Website, by enquiring in relation to our goods or services.
The term Personal Data refers to any element or information that can identify a person’s identity or contact information. This also includes cases where one’s identity can be ascertained even indirectly by reference to a factor that is unique to the physical, physiological, genetic, psychological, economic, cultural, or social identity of that individual.
It is important that the data that we hold about you is accurate and up to date. In the event that your data changes please notify us so that we can update our records, in the contact details listed above.
Use of your information
We may hold and process personal data that you provide to us in accordance with the GDPR.
The information that we collect and store relating to you is primarily used:
(a) To enable us to provide our services to you, to communicate with you and to meet our contractual commitments to you.
(b) To notify you about any changes to our business, such as improvements to our Website or service/product changes, that may affect our service or relationship with you.
(c) If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you.
(d) Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you.
(e) Where you have consented to receive our e-newsletters to provide that to you.
(f) Where we need to comply with a legal obligation.
(g) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we collect your data for marketing purposes, we will always request your consent, at the point the data is collected, to use your data for that purpose.
We will always obtain your prior consent to sharing your personal data with any third party for their marketing purposes. This may be to enable relevant third parties to advise you of products or services that may be of interest to you.
We will only use your personal data for a reason other than the purpose for which it was originally obtained if we consider that we need to use it for that other purpose and have a legitimate interest in doing so.
Disclosure of your information
There are a range of circumstances where we may disclose your data to third parties. These include:
(a) Regulatory bodies. We may disclose your data to regulatory bodies to enable us to comply with the law and to assist fraud protection and minimise credit risk.
(b) Our Suppliers. We may disclose your data to third parties that are involved in the fulfilment of our services to you.
(c) Third party marketing. Where you have consented for us to do so, we may provide your data to selected third parties who may contact you about their goods or services that you may be interested in.
Please be advised that we do not reveal information about identifiable individuals to our advertisers, but we may, on occasion, provide them with Aggregated Data (i.e., data that may be obtained from your personal data, but which does not directly or indirectly identify you. This may include Usage Data detailing how you use our Website and the features and areas that you have interacted with) about our Website visitors and customers.
If you do not want us to share your data with third parties, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data. You can do so by contacting us on the contact details listed above.
As part of the services offered to you, for example through our Website, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating outside the EEA who work for one of our suppliers, e.g., our website server host, payment processing provider, or work for us when temporarily outside of the EEA.
A transfer of your personal data may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA.
If you use our service while you are outside the EEA, your personal data may be transferred outside the EEA in order to provide you with these services.
The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site; any such transmission is at your own risk.
We have put in place security measures to prevent your data from accidental, loss or disclosure. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential. You should choose a password it is not easy for someone to guess.
In the event of a data breach, we will notify the Commissioner for Personal Data and you in the event that the breach results in any likelihood of loss or damage to you.
The length of time that we retain, and store data depends on the purpose for which it was collected. We will only store data for as long as is required to fulfil that purpose, or for the purpose of satisfying legal requirements.
It is a legal requirement that we keep certain data about our customers and suppliers for at least seven years.
Where you have requested that we provide you with marketing materials we will retain your data until such time as consent is withdrawn by you.
We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and the service that we provide to you.
The GDPR gives you a range of rights in relation to the personal data that we collect from. You have the right to:
(a) Access your personal data. This right is commonly known as the ‘data subject access request’ and enables you to receive a copy of the personal data we hold about you. You will not need to pay a fee to access your personal data unless we can justifiably demonstrate that the request is repetitive or excessive. We will respond to all legitimate data access requests within one month, but we may need to obtain further information from you in order to confirm your identity and the legitimacy of the request.
(b) Request update of the personal data. This enables you to have any incomplete or inaccurate data corrected.
(c) Erasure of your personal data. This enables you to ask us to delete personal data where there is no justifiable reason for us continuing to retain and process it. We may not always be able to delete the data such as if there is an ongoing contractual relationship between us or if we are legally required to retain the data.
(d) Object to processing of your personal data where we are relying on consent or our legitimate interests (or those of a third party) as the justification for processing the data.
(e) Restrict the processing of your personal data. This enables you to ask us to change the processing of your personal data. For example, you may wish to vary the basis on which we contact you.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, machine-readable format.
(g) Withdraw consent. Where we are relying on consent to process your personal data you may withdraw that consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise these rights at any time by contacting our DPO at the contact details listed above.
Third party links
You might find links to third party websites on our website. If you click a link to a third-party website and visit that site, you may be allowing that site to collect and share certain data about you. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
If you wish to raise a complaint regarding our use of your personal data then you can contact the Commissioner for Personal Data, which is the supervisory authority for data protection issues in the Republic of Cyprus. (http://www.dataprotection.gov.cy).
If you do wish to raise a complain then we would welcome the opportunity to discuss your concerns before you contact the Personal Data Commissioner to see if we can resolve the issue for you.
Changes to this policy
We may update these policies to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.
Version: May 2021