1. A brief welcome
2. Legal basis and relevant legislation
3. Scope of this policy and key terms
The policy also explains our privacy rights and how the law protects your own data.
All meaning of terms used here (such as “personal data”, “data controller”, “data processor”) has the meaning given to them by the legislation mentioned in (2) above. Any use, handling, storing, keeping, processing and collection of your personal data is done according to the legislation mentioned above.
This policy supplements any other policy notice(s) we may give you from time to time and does not override them. It should be read together with any other policy notice(s).
According to Law 125 (I) 2018, personal data is any information that refers to an identified or identifiable natural person (the “data subject”). Such a person is any person that can be identified, directly or indirectly, by reference to an identifier. An identifier can be various things that may point to the identity of a natural person, for example, a name, identification number, location, online identifier, or any factor or combination of factors that have to do with the physiological, genetic, mental, cultural, social or economic identity of that natural person.
According to the same law, when you register personal information with us, we become the “data controller” (or “controller”). This means that we are responsible for how your data is processed. Any such processing is done in strict accordance with the law.
4. How to contact us about privacy
If you have any comments, questions, concerns or complaints about this policy, please contact us using the information as follows:
Postal address: Amathountos 108a, 4532, Agios Tychon, Cyprus
Phone number: +357 25313691
We will make every effort to answer your questions or address any issue as soon as possible.
5. Collection of personal data
We collect personal data or information on a voluntary basis. That is, we collect only the information you want to give us as a user of our Site/ services. Sometimes, specific information will be requested as “mandatory” to carry out specific actions such as user registration. If you do not wish to give us that information, you will not be able to use our Site or services.
Note that you will need to give us specific personal information if you decide to make a contract with us at any point.
However, you do not have to give us your personal information to browse our Site, and there will be no consequences whatsoever for not giving us your personal information.
We use Google Analytics to collect and process analytical data about website users. Google Analytics tracks your interaction with the Site and stores information about IP address, operating system, web browser, pages visited, information about demographics of our website users, the device used, and where the visit originated. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
6. Data changes and need for accuracy
To maintain our policy and provide you with the best service, it is important to know of any changes to your personal data. Help us keep your data accurate by informing us of any changes. To do this, use the contact information provided in (4) above.
7. How we use your data
We at DevelopersCyprus are committed to protecting your data and will only use it in accordance with Cyprus legislation and the European Union GDPR Regulation outlined in (2) above.
Therefore, your data will be used as follows:
- To provide services, support, and communication and to fulfill our contractual obligations to you.
- To inform you about changes or improvements to our website, products, services and business procedures.
- For existing customers, to let you know about goods and services that may be of interest based on your past dealings with us.
- Where you have given us your clear and express consent to send information on products and services from third parties which we think may be relevant to your interests. We will use your data for marketing purposes if and only if you give us your clear and express consent.
- Where you have given us your clear and express consent to send you our electronic newsletters.
- To fulfill our legal obligations.
- To further our legitimate interests or those of a third party; for example, to prevent fraud or carry out an internal investigation. In such a case, we will use your data only if your own rights do not outweigh our legitimate interests.
The third parties referred to in this section are parties who are affiliated with us in some way. We do not share your data with unaffiliated third parties except as required by law or as requested by you.
We will only share your data according to your instructions. We will share your data for other purposes only to protect our legitimate interests, comply with the law, or serve the public interest as requested by law. In the first of these cases (protection of our legitimate interests), we will use your data only if your own rights and freedoms are not violated by our actions.
8. Disclosure of your data
Personal data legislation allows us to disclose your data in several ways. These include
- Law enforcement authorities, governmental and regulatory bodies. We will do this to comply with our legal obligations, defend our legal rights, comply with a court order, assist in the investigation of suspected fraudulent or illegal activities, assist in the detection of fraud, protect our own safety, or minimise credit risk.
- Affiliates, service providers or business contacts/ suppliers who may assist us in giving our services to you.
- Third-party marketing, only with your consent. Without your consent, we do not disclose any information that may identify you to third parties for marketing purposes.
- Business transfers. When we transfer, wholly or in part, our business or assets to an acquirer, your information will be transferred to the acquirer. The transfer may be because of bankruptcy proceedings. In case we transfer assets or business to an acquirer, this will be done confidentially and in accordance with the law. Also, you can protect your rights by contacting the acquirer directly.
9. International transfer of personal information
Some of our external third-party suppliers, or their servers, may be based in countries outside Cyprus or the EEA (European Economic Area). In such a case, we inform the Office of the Commissioner for Personal Data Protection, as required by law (section 17 of Law 125 (I) 2018).
As mentioned above, we do not give any information about you for reasons of marketing to third parties without your consent.
However, we may give aggregated, de-identified and anonymised information to third parties for research, marketing and advertising purposes. This aggregated information is collected in large sums of data. It is anonymous and based on broad and general characteristics that cannot identify you, for example, age group and gender (men under 30, women in an area). This information may be given to third-party advertisers to help them reach a target audience.
We have all the appropriate security measures in place and take strict precautions to prevent your data from being lost or accessed unlawfully and to prevent any security breach.
However, despite all our best efforts, it is possible that security issues may occur. We cannot guarantee the security of data. As mentioned in our Terms and Conditions, you access and use our Site at your own risk.
If there is a security breach or any data breach, we will notify the Commissioner for Data Protection and you immediately.
If you have any suspicion that the security of your data has been breached, please notify us immediately at email@example.com.
If you have chosen or been given a password for accessing any part of our Site, please treat the password as confidential and do not reveal or share it with anyone. Choose a password that is not easy for others to guess.
12. Data retention
We will not retain your data longer than necessary.
We will not retain data for marketing purposes without your express and clear consent. If you withdraw your consent, your data will be deleted.
Where the law requires us to keep certain data for a specific period of time, we will keep it for that period of time and for no longer.
A cookie is a small text file (with letters or numbers) containing information. This information cannot identify you personally. Websites you visit store cookies on your browser or the hard drive of your device. This way, you can see the information stored in the cookie (such as an advertisement). Cookies cannot be stored on your browser or hard drive without your consent.
You can block cookies by going to settings and deactivating cookies.
However, if you automatically block all cookies, you may not be able to access some parts of the website and receive full advantage of our services.
Generally, cookies help us provide you with a better service. They do not give us information about you or your device except the information you choose to share.
14. Your rights
Under the data protection legislation and EU law, you have the following rights:
- Access to your data (“data subject access request”). You have the right to know what data we keep about you and how we use it. You do not have to pay a fee to receive this information unless your request is unfounded, repetitive or excessive. In such a case, we will charge a reasonable fee. We may ask you to provide us with some information to confirm your identity and see whether we can satisfy your request.
- To ask us to correct any errors in your data or complete any incomplete information (“right to rectification”).
- You have a “right to be forgotten”; that is, you can ask us to delete and erase any information we hold about you. We will delete the data if keeping them is no longer necessary, if you withdraw the consent upon which the processing is based, and if there is no legal need for the data to remain with us.
- You may restrict how we use your personal data (“right to restriction of processing”).
- Ask us to transfer the data we have about you to you or a third party (“right to data portability”). In such a case, we will give the data to you or the third party in a structured, commonly used and machine-readable format, as required by law (Article 20 of the GDPR Regulation).
- Withdraw your consent at any time. In such a case, we will no longer be able to use the data for which you had given us consent for any reason. As a result, we may not be able to provide some of our services to you.
- Object to the use of your data in solely automated decision-making (“right to object to automated individual decision-making”).
- The right to be notified when we comply with your request to correct or delete your data or restrict the use of your data.
15. Links to third-party sites and social media
Our site may contain links to other sites and apps. This is done for your information and to provide a better experience. Third-party sites and social media have their own privacy policies, for which we are not responsible. We strongly advise you to read their privacy policies before using their sites or apps.
16. How to make a complaint
If you believe that we have kept or used your data in violation of the relevant law or that we did not satisfactorily handle a complaint about our use of your data, please contact us at firstname.lastname@example.org.
If you have reasons to believe that we have violated the law regarding privacy and personal information, you may also contact the Office of the
Commissioner for Personal Data Protection here:
17. Changes and updates to the policy
We review and update our privacy notice and policy from time to time or as the law changes. You are advised to visit our site regularly to learn about any changes.
We take every care to provide you with the best service possible. All treatment of your personal information is done in strict accordance with the law. We welcome any comments, questions or requests you may have.Thank you.