- 1 What Data We Collect
In simple terms, personal data is information that identifies you as an individual (“Personal Data”).
The general categories of Personal Data that we may collect and process include, but are not limited to, the following:
- data about your use of our Website, namely information about your visits to and use of this website (including your internet protocol (IP) address, geographical location, length of website visit, the time and date of website visit, page views and website navigation paths), (“Usage data”);
- information that you provide in order for us to be able to respond to your enquiry (for additional information or otherwise) or your comments or complaints in relation to our Website (including your full name, email address and phone number), (“Correspondence Data”);
- any other Personal Data that you choose to send to us.
You must not supply any other person’s Personal Data to us.
- 2 Processing of Personal Data
Personal Data submitted to us through our Website, will be used and processed for the following specified purposes:
- Usage Data:
- Legal Basis for Processing: our legitimate interests;
- Correspondence Data:
- Purpose of Processing: to enable us to respond to enquiries or complaints you may have about our Services or Website or job vacancies.
- Legal Basis for Processing: our legitimate interests;
In addition to the specific purposes described above, we may process your Personal Data to the extent permissible by applicable law, in the good faith belief that such action is necessary for:
- compliance with a legal obligation or governmental agency request,
- the defense of our rights in legal or administrative proceedings,
- our protection against legal liability.
- 3 Disclosing Personal Data
We may disclose your Personal Data to any of:
- our employees, officers, suppliers, subcontractors;
- affiliate companies (including their employees, officers, suppliers and subcontractors);
insofar as is reasonably necessary for the purposes set out in this Policy.
We will disclose your Personal Data:
- to the extent that we are required to do so by law or by public and/or government authorities;
- in connection with any ongoing or prospective legal proceedings and to comply with legal process;
- in so far as it is reasonably necessary, for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to establish, exercise or defend our legal rights whether in court proceedings or in an administrative or out-of-court procedure (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to allow us to pursue available remedies or limit the damages which we may sustain and
Except as provided in this Policy, we will not provide your Personal Data to third parties.
- 4 International data transfers
As an international group of companies, we have offices and people around the world and more predominantly in the United States of America, Costa Rica, China, Vietnam, Republic of Cyprus, Bulgaria, Malta and Nigeria.
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use and process the information in accordance with this Policy.
Information that we collect and which may be transferred to any country which does not have data protection laws (equivalent to those in force in the EEA) is protected by appropriate safeguards, namely the use of standard data protection contractual clauses adopted or approved by the European Commission or the use of binding corporate rules.
- 5 Retaining and Deleting Personal Data
We shall not keep or process your Personal Data for longer than it is necessary for the processing purpose we have specified. Depending on the processing purpose, different timelines for retention of your Personal Data will be applicable, which we shall determine based on:
- the length of time needed to provide to you our Services,
- the reasonable length of time needed to
- respond to your request for information or to your complaint; or
- whether your Personal Data is sensitive or not,
- whether you have consented to a longer retention period,
- Whether we are obliged, by law, contract or similar obligation to retain your Personal Data for a minimum specific time period.
Notwithstanding the other provisions of this paragraph, we will retain documents (including electronic documents) containing Personal Data:
- to the extent that we are required to do so by applicable law;
- if we are of the opinion that the documents may be relevant to any ongoing, imminent or prospective legal proceedings; and
- for the purpose of establishing, exercising or defending our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
At the end of the retention period, we will delete your Personal Data in a manner designed to ensure that it cannot be reconstructed or read.
- 6 Security of Personal Data
The security of your Personal Data is very important to us. We will take reasonable, technical and organizational precautions to prevent the loss, unauthorized access, disclosure, destruction, misuse or alteration of your Personal Data.
- 7 Amendments
We may revise and update this Policy at any time, without notice. This revised Policy will be effective when posted/ published on the Website. Accordingly, if you disagree with and do not want to accept this Policy, as these have been revised, you must discontinue to use our Website.
You should check this page occasionally to ensure you are happy with any changes to this Policy.
- 8 Your Rights
You have several rights in relation to the Personal Data you have shared with us. These are in line with the applicable legislation and can be summarized as follows:
- (a) Right to Access;
You have the right to request access your Personal Data that we hold including the right to be informed about the purpose of the processing and the recipients of your Personal Data. Provided the rights of others are not affected, we will supply to you a copy of your Personal Data that we hold but in doing so we may ask you to verify your identity.
- (b) Right to Rectification;
You have the right to have any inaccurate Personal Data rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed.
- (c) Right to Erasure;
Under some circumstances, you have the right to the erasure of your Personal Data without undue delay. Those circumstances can come about when:
- your Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed;
- you withdraw consent in circumstances where you had previously provided it;
- you object to the processing under certain rules of applicable data protection law;
- the processing is for direct marketing purposes;
- your Personal Data was unlawfully processed.
The right to erasure is not absolute and exclusions include circumstances where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; and/ or for the establishment, exercise or defense of legal claims.
- (d) Right to Restrict Processing;
Under certain circumstances, you have the right to restrict the processing of your Personal Data. Examples of such circumstances include cases where you contest the accuracy of your Personal Data or our need to have access to your Personal Data for the declared processing purposes. If and when processing has been restricted on this basis, we may continue to store your Personal Data but we cannot otherwise process it:
- (e) Right to Object to Processing;
If we have been processing your Personal Data on certain legal basis (such as legitimate interest) you have the right to object to such processing in certain circumstances. On the submission of such objection and unless we can demonstrate compelling legitimate grounds for the continuance of the processing which override your interests or if the processing is for the establishment, exercise or defence of legal claims, we shall seize the processing.
- (f) Right to Data Portability;
If the processing is carried and by automated means AND the legal basis for our processing of your personal data is:
- (i) consent; or
- (ii) performance of a contract to which you are party or
- (iii) preparatory work at your request prior to entering into a contract;
you have the right to receive your personal data from us in a structured, commonly used and machine-readable format, unless it would adversely affect the rights and freedoms of others.
- (g) Right to Lodge a Complaint to a Supervisory Authority;
If you consider that our processing of your Personal Data infringes applicable data protection legislation, you have a legal right to lodge a complaint with the Cyprus Supervisory Authority.
- (h) Right to Withdraw Consent:
To the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us via firstname.lastname@example.org.
- 9Third party websites
Our Website may include hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- 10Sensitive Information
We ask you NOT to send or share with us any sensitive Personal Data (such as but not limited to your government-issued or financial account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic or biometric data, criminal background or trade union membership).
- 11Our contact details
This website is owned by Everty Holdings Ltd (a Cyprus entity with registration number C374706) and operated by Everty Holdings Ltd and its affiliates.
The registered office of Everty Holdings Ltd is situated at 2 Agias Elenis street, Floor 5, Flat 501, 1060 Nicosia, Cyprus.
You can contact us by:
- post, using the postal address given above as well as the addresses published on the Website;
- using our Request Information section on our Website;
- by telephone, on the contact number published on our Website; or
- by email, using the email address published on our Website.