- explains our approach to the personal information that we collect from you and the purposes for which we process such personal information;
- informs you of the nature of your personal information that is processed by us and sets out your statutory rights in respect thereof; and
- intends to assist you in making informed decisions when using the services and/or products offered on the Website.
2. What information is processed?
- You access, browse and/or use the Website, including, without limitation, when you create an account on the Website, and/or place a purchase order with us and/or contact us through the Website, and/or when you participate in interactive features on the Website (such as product reviews), and/or when you fill out a survey on the Website;
- You use a social media platform (such as Facebook or Instagram) to communicate with us;
- You link your profile or account on the Website with any third party website or social media platform (such as Facebook or Instagram);
- You submit a request to our customer service department, including, without limitation, when you get in touch with us in relation to a purchase order that you wish to place or might have placed with us; and/or
- You otherwise interact with us, we may, depending on the circumstances and/or your request, process the following information about you:
(a) name and surname;
(b) date of birth;
(d) contact information, including, without limitation, your e-mail address, telephone number and/or registered/residential address;
(e) payment information, such as details of your credit or debit card or details of any other payment method that you have provided us with, with regard to and in connection with a purchase order that you may place or may have placed with us;
(f) tax related information such as applicable VAT number;
(g) the username and password you use to access your dedicated account on the Website;
(h) Internet Protocol (IP) address, the name of your internet service provider (ISP) depending on the configuration of your ISP connection, the date and time of your visit to the Website, the length of your session, the pages which you have accessed, the number of times you access the Website within any month, the file URL you look at and information relating to it, the operating system which your computer uses;
(i) information relating to the purchase order you have placed with us; and/or
(j) other information relevant to your request and/or provision of any services you request us to provide you with.
E-mails that we send as part of our marketing programs may use web beacons and other technologies that tell us whether such an e-mail has been opened by you.
When you provide publicly available content, such as content posted to a social media page, we may collect that information.
Further, we may collect and/or receive information about you from third parties that we work with, including, without limitation, advertising networks, analytics providers, search information providers, credit reference agencies, and fraud detection providers.
3. Why and how we process such information
We and third party processors acting on our behalf process your personal information for the following purposes:
- to allow you to safely access, browse and use the Website, including, without limitation, satisfy your request to create a profile or account on the Website;
- to process and/or satisfy any request that you submit to us, including, without limitation:
(a) to process, track and fulfil a purchase order that you place with us; and/or
(b) to liaise with you about the status of your order.
- to improve the effectiveness of the Website, including, without limitation, to:
(a) provide you with the best possible browsing experience;
(b) improve our digital presence and/or the Website;
(c) allow you to gain access to marketing material and other content that may be downloaded from and/or viewed on the Website;
- for marketing related purposes;
- for business administration and legal compliance purposes:
(a) when we are required under applicable laws and regulations to comply with an obligation imposed upon us;
(b) to maintain our internal records up to date;
(c) to protect and/or enforce our legal rights;
(d) to protect the legal rights of third parties; and/or
(e) in connection with a transaction to which we are a party to (for instance sale, merger or restructuring).
- to perform our contractual obligations towards you;
- to enforce our agreement(s) with you and/or the entity you represent; and/or
- to investigate or settle inquiries or disputes.
4. Legal bases for processing
We process your personal information in reliance on any one or more of the following legal bases:
- in order to perform our obligations in accordance with any contract that we may have with you or in order to take steps to enter into a contract with you; and/or
- that it is in our legitimate interest or in a third party’s legitimate interest to process your personal information; and/or
- it is our legal obligation to process your personal information to comply with any legal obligations imposed upon us; and/or
- on the basis that you have provided us with your explicit consent to process the personal information you have supplied us with; and/or
- in reliance on any other applicable legal basis provided under applicable laws and regulations.
5. Your rights
You have the following rights in relation to the personal information we hold about you and process:
- Right of accessYou have the right to obtain confirmation as to whether or not personal information concerning you are being processed by us.
- Your right to rectificationYou have the right to obtain from us without undue delay the rectification of inaccurate personal information concerning you. If we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
- Your right to erasureIn certain circumstances (such us when you withdraw consent), you have the right to request from us the erasure of your personal information without undue delay and we have the obligation to erase the same without undue delay.
We are not required to comply with your request to erase your personal information if the processing of such information is necessary:
(a) for compliance with a legal obligation; or
(b) for the establishment, exercise or defence of legal claims.
There are certain other circumstances in which we are not required to comply with your erasure request, although the above two are the most likely circumstances in which we would deny that request.
- Your right to objectYou can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Your right to data portabilityWhere processing is based on your consent or on the performance of a contract with you; and such processing is carried out by automated means, you have the right to ask us to provide your personal information in a structured, commonly used and machine readable format and to transmit, where technically feasible, such information to another controller without hindrance.
- Your right to restrict processing
You can ask us to “block” or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to processing thereof. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
- Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. However, you should be aware that if you choose to do so there may be potential consequences which we will tell you about at that time.
- Your right to lodge a complaint with the supervisory authorityIf you have a concern about any aspect of our privacy practices, including, without limitation, the way we have handled or handle your personal information, you can report such concern with the local supervisory authority in Cyprus, which is the Cyprus Data Protection Commissioner (www.dataprotection.gov.cy).
Where you reside outside of Cyprus you have the right to file a complaint with your local supervisory authority.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your local supervisory authority at any time.
Please note that some of your above rights may be limited where we have an overriding interest or legal obligation to continue to process your personal information or where such information may be exempt from disclosure due to confidentiality or other reasons under applicable law and regulations.
In the event you wish to exercise any of your above mentioned rights please get in touch with us using the contact details referred to in paragraph 11 below. We reserve the right to ask you for proof of your identity if you contact us as aforesaid.
6. Confidentiality and Security
All of our partners, employees, consultants, workers and data processors, who have access to, and are associated with the processing of your personal information, are obliged to respect the confidentiality and security of such personal information.
When doing so, we will comply with our legal and regulatory obligations in relation to your personal information, including, without limitation, maintaining appropriate safeguards in place.
8. Who do we share your personal information with
Any information that we collect or that you provide to us may be shared and processed by any of the following categories of third parties as may (depending each time) be necessary:
(a) sub-contractors and services providers who assist us in connection with the ways we use personal information (as set out above), including, without limitation, website hosting providers, website developers, marketing and analytics services providers, whether based within the European Union or elsewhere around the world;
(b) internally through our corporate network and offices for, inter alia, business administration purposes;
(c) third party business partners and/or affiliates in order to provide you with and/or fulfil a request and/or service that you have requested from us;
(d) public and governmental authorities, including, without limitation, regulatory authorities, tax authorities, and corporate registries;
(e) credit institutions and other financial institutions;
(f) third party postal or courier providers who assist us in delivering our documents related to a matter that concerns you; and/or
(g) any third party to whom we disclose your personal information on the basis of a legal obligation imposed upon us under applicable laws and regulations.
The above is a non-exhaustive list of persons and entities with whom we might (depending on the circumstances) share your personal information with. There may be other instances and persons to whom we may disclose your personal information.
Any transmission of your personal information, as set out above, shall, at all times, comply with applicable laws and regulations.
9. Marketing preferences
Where we have your consent to do so (i.e. if you have subscribed to our newsletter or have consented that you’d like to hear about our offers, courses, services, news and educational blogs), we will periodically send you marketing communications via e-mail in relation to courses and services that we feel may be of interest to you.
We will afford you with the possibility to “opt-out” from such communications each and every time you receive a marketing e-mail, at no cost and expense. This may be done by clicking the “unsubscribe” link in the footer or main body of each and every marketing email you receive from us or by contacting us at firstname.lastname@example.org.
10. Cookies and web analytics
Please note that we are using Google Analytics for tracking our website traffic and the user data retention period is 12 months.
11. Storage and retention
Where we no longer require your personal information we will ensure that it is either securely deleted or destroyed or stored in a way which means it will no longer be processed and/or used by us. In particular, without limitation to the foregoing, subject to any further lawful processing (including, without limitation, requirement to retain personal information for compliance with a legal requirement to which we are subject to), we will retain your personal information for at least 12 months from the date of our last interaction with you.
Retention of your information and subsequent deletion, destruction or storing in a manner that we no longer can use such information, will be in compliance with applicable laws and regulations.
12. How You Can Contact Us
(a) e-mail at email@example.com; or
(b) calling us on +357 22 000 612.
Please note that, for the purposes of applicable data protection law (including, without limitation, the General Data Protection Regulation EU 2016/679), we are the data controller and our data protection officer is Jaron Veelo.