5. What Data Do We Collect?

Depending on your use of our site and your account with us if applicable, we may collect some or all of the following data (please also see Part 14 on our use of Cookies and similar technologies):

6. How Do We Use Your Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:

• Providing and managing your Account;
• Providing and managing your access to our site;
• Personalizing and tailoring your experience on our site;
• Supplying our Services to you. Your personal details are required in order for us to enter into a contract with you;
• Personalizing and tailoring our Services for you;
• Communicating with you. This may include responding to emails or calls from you;
• Analyzing your use of our site and gathering feedback to enable us to continually improve our site and your user experience.

With your explicit permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you with information, news, and offers on our Services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and you will always have the opportunity to opt-out.

7. How Long Will We Keep Your Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. 

8. How and Where Do We Store or Transfer Your Personal Data?

We will only store or transfer your personal data within the Cyprus and the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

9. How do we secure your Personal Information? 

We have implemented reasonable technical, administrative and physical measures designed to protect the personal information in our custody or control from unauthorized access, use, modification and disclosure. 

If you are using one of our Services with an online store, we designed our online store to accept orders only from Web browsers that permit communication through Secure Socket Layer (SSL) technology, which encrypts your information while it is being transmitted to us.  Browsers that do not meet this requirement will be prevented from navigating the online store section of our Services. 

You should be aware that 100% security of data transmission or storage is not always possible. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us.

10. Do We Share Your Personal Data?

• We may sometimes contract with the following third parties to supply certain services. These may include web hosting, payment processing and other services that are essential for us to work with you. In some cases, those third parties may require access to some or all of your personal data that we hold.
• If any of your personal data is required by a third party as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9. You will be kept fully informed at all times in situations where your data may be passed to or shared with a third party.
• In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can You Control Your Personal Data?

In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our site, you are given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or by contacting us.

12. Can You Withhold Personal Information?

You may access certain areas of our site without providing any personal data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14

13. How Can You Access Your Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in Part 2. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 20 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. What are Cookies and How We Use Them

Cookies are small text files that websites place on your device as you are browsing. They are processed and stored by your web browser. In and of themselves, cookies are harmless and serve crucial functions for websites. Cookies can also generally be easily viewed and deleted.

Our site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. 

We use Cookies to facilitate and improve your experience of our site and to provide and improve our Services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

• All Cookies used by and on our site are used in accordance with current Cookie Law.

The cookies we use are essential for our site to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

• Our site uses analytics services provided by Google. Website Analytics refers to a set of tools used to collect and analyze anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our site and the services or services we offer.

The analytics service(s) used by our site uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our site, it does enable us to continually improve our site, making it a better and more useful experience for you.

• We anonymize IP addresses as part of our analytics collection to avoid any personal identification.

You can also choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our site more quickly and efficiently including, but not limited to, login and personalization settings. 

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How we would deal with a data breach

The immediate priority is to identify and isolate the breach by locking down all systems and resetting all system passwords.

We would notify all clients of the breach, explaining what had happened and what steps we had taken to prevent future occurrence.

In the event that client data had been accessed as a result of the breach of our system, we would then report the breach to the relevant authorities within 72 hours as per the GDPR requirements.

16. Changes to this privacy policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our site following the alterations. We recommend that you check this page regularly to keep up-to-date.