PERSONAL DATA SECURITY
S11 LTD with its official registered office located at K.PALAMA 34, 1096 NICOSIA, CYPRUS, Company ID Number: 10414323E, VAT Number: 10414323E, Domestic Taxation Office. (Hereinafter referred to as the Company) in the framework of the General Data Protection Regulation (EU) 2016/679, which entered into force on 25/05/2018, hereinafter referred to as the "GDPR" as applicable, hereby provides you with the following information on the processing of your personal data and your rights as the subject of processing. The new Regulation replaces the existing legal framework for the protection of individuals from the processing of personal data. From the above date any reference to the provisions of Law 2472/1997, is meant to refer to the provisions of the new "GDPR".
This disclosure is addressed to natural persons who engage in any transaction with the Company, including, but not limited to, Clients who have a permanent relationship with the Company or passing Clients, their legal representatives, their special or universal successors, representatives of legal entities and any natural person who in any capacity has business relations with the Company.
The processing of personal data consists of collecting, registering, organizing, structuring, storing, changing, retrieving, seeking information, using, transmitting, restricting or deleting personal data that have come to or come to the knowledge of the Company, either in the course of your business relationship with it or in the course of information received by the Enterprise from a third natural or legal person or public sector entity in the exercise of a legitimate right of it or of the Company.
The Company, in compliance with the applicable legal framework, has taken all necessary action by implementing the appropriate technical and organizational measures for the lawful maintenance, processing and safe storage of the personal data file, committed to safeguarding and protecting in any way processing your personal data from loss or leakage, alteration, transmission, or any other unlawful processing of your personal data.
These terms are formulated taking into account both the rapid development of technology, and in particular the Internet, and the existing - albeit not fully developed - network of legal provisions on these issues. In this context, any relevant regulation will be the subject of this section.
WHAT PERSONAL DATA WE PROCESS AND FROM WHICH WE COLLECT
The Company processes your personal data that you have or will be submitting to the Company by you or your legal representatives, which are necessary for the initiation, maintenance and execution of your business relations with the Company, existing or future depending on the product or service provided and its applicable procedures and policies. Your personal data that you provide to the Company must be complete and accurate and promptly updated, in every case of change or whenever deemed necessary by the Company to maintain your professional relationships or to fulfill a Company's obligation resulting from the law and the applicable regulations.
To initiate and maintain its business relationship with its Clients, the Company collects and processes the following minimum personal data: Name, address, address, business details and business address, financial data tax return, tax residence, tax number, telephone (fixed and / or mobile), and signature signature (physical or electronic). Additional information (eg, professional or student identity) may be required, as long as it is a precondition for starting or maintaining a particular business relationship.
The collection and processing of your personal data by the Company is essential for the establishment, execution and maintenance of our business relationships. Your objection to the provision or processing of your personal information may lead to the failure to start or continue your cooperation with the Company (eg refusal to process and use the e-mail address of the e-mail makes it impossible to use or continuing to provide the service via internet applications, refusing to process and use the mobile number makes it impossible to provide the SMS service).
The Company does not process your personal data such as data relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, or membership of a trade union, genetic or biometric data to identify as a subject as well as health data or data regarding your sexual or sexual orientation.
LEGALITY OF PROCESSING
The Company lawfully processes personal data if processed:
- It is necessary to service, support and monitor your business relations with the Company and the proper execution of your contracts.
- It is necessary for the Company to comply with its legal obligation or to pursue its legitimate interests arising from your dealings with the Company or other lawful rights.
- It is necessary for the fulfillment of its duty to be performed in the public interest within the framework of the current legislative and regulatory framework.
- Based on your prior explicit consent, as long as the processing is not based on any of the above-mentioned legitimate processing bases.
OBJECTIVES OF PROCESSING
Your personal data is processed:
- Serving, supporting and monitoring your business relationship with the Company, the proper execution of the contracts between us, examining requests for the provision of products / services of the Company, fulfilling the Company's obligations as responsible or performing the processing and the exercise of its legal and contractual rights.
- Record, record, and archive all your orders to the Enterprise that are provided either in writing, either electronically or by telephone, for the purpose of tracing transactions and for trade-related purposes.
- Upgrading the Products and Services Provided by the Enterprise and promoting the Company's products and services, business-to-business operations, subject to your prior consent.
- Satisfaction of any requests addressed to the Company or the examination of your complaints regarding products and services offered by the Company.
- The fulfillment of legal obligations of the Company arising from the current legal and regulatory framework (eg tax and insurance provisions).
- Defending the Company's legitimate interests, including but not limited to: (a) claiming its legitimate claims before the competent judicial authorities or other non-judicial / alternative dispute resolution bodies; (b) preventing fraud and other criminal offenses; ) the evaluation and optimization of security procedures and information systems, d) the management of operational and credit risks of the Company, e) physical security and protection of persons and property (eg video surveillance).
AUTOMATIC DECISION-MAKING AND PROFILING
The Company does not make decisions based solely on automated procedures for processing personal data.
The Company may, if your consent is previously given, process your personal data to inform you of its products and services that you may be interested in.
In any case, you have the right to oppose the processing of your personal data for the above purpose of direct marketing of the Company's products / services by sending your request to the Company's shop or via e-mail: info@s11ltd.com
DATE OF COMPLIANCE WITH DATA
The Company retains your personal data for as long as it is per case, from the applicable legal and regulatory framework and in any case for a period of twenty (20) years from the last calendar day of the end of each transaction your relationship with the Company. In case any request for your cooperation with the Company is not accepted and the contract is not completed, the data will be kept for a period of five (5) years. In case of litigation, your personal data will be respected in any case until the end of the lawsuit even if the above twenty (20) years are exceeded.
DATA RECEIVERS
Access to your personal data is provided by the employees of the Business Units of the Company, within their respective spheres of competence, as well as the Group companies in the proper execution and fulfillment of their contractual, legal and regulatory obligations as well as Certified Auditors of the Company and / or the Group.
The Company does not transmit or disclose your personal data to third parties unless it is:
- Tax authorities and accountants who process Customer data for tax purposes.
- Supervisory, independent, judicial, prosecutorial, public and / or other authorities or bodies or parties entrusted with the control / monitoring of the Company's activities within their jurisdiction.
- PayPal's online payment platform with strong TLS encryption with Secure Sockets Layer (SSL) encryption protocol.
The Company has legally ensured that the processors on its behalf fulfill the conditions and provide reasonable assurance that appropriate technical and organizational measures will be in place to ensure that your personal data is processed to protect their rights.
The Company does not transmit your personal data directly to third countries or international organizations unless the transfer is required by the applicable regulatory or legislative framework.
REVOKE CONSENT
You have the right to revoke your consent at any time, where appropriate, without prejudice to the legitimacy of the processing based on it until its revocation. Your withdrawal of consent can be made at any branch of the Company or by using the following forms:
SUBJECT RIGHTS
You are subject to the following rights as a personal data subject:
- Right of access to your personal data and subject to processing by the Enterprise as the controller, its purposes, the categories of data and recipients or categories of recipients (Article 15 GDPR)
- Right to correct inaccurate data and fill in incomplete data (Article 16 GDPR).
- The right to delete your personal data without prejudice to the Company's obligations and legal rights to retain it in accordance with the applicable laws and regulations (Article 17 of the GDPR).
- Right to restrict the processing of your personal data if either the accuracy of those data is questioned or the processing is illegal or the purpose of the processing has been omitted and provided that there is no legitimate reason to hold them (Article 18 of the GDPR).
- The right to transfer your personal data to another controller, provided that the processing is based on your consent and is done by automated means. Satisfaction of this right is without prejudice to the Company's legitimate rights and obligations to hold data and fulfill its duty in the public interest (Article 20 of the GDPR).
- A right of objection for reasons relating to your particular situation if your personal data is processed to fulfill a duty performed in the public interest or in the exercise of public authority entrusted to the Company or for the purposes of legal interests sought by the Enterprise or a third party.
PROCEDURE FOR THE EXERCISE OF YOUR RIGHTS AND THE SUBMISSION OF AN COMPLAINT
Your request regarding your personal data and the exercise of your rights must be addressed in writing to any branch of the Company or by e-mail: info@s11ltd.com
Denial of the Enterprise or unjustified delay in meeting your claims in the exercise of your rights gives you the right to appeal to the Personal Data Protection Authority as the competent supervisory authority for the enforcement of the GDPR.
In any case, you reserve the right to submit a complaint to the competent supervisory authority if you believe that your personal data is being processed in violation of any applicable law. For more information, please visit www.dataprotection.gov.cy
The Company may revise or modify this update on the basis of its current data protection policy and in the current legal and regulatory framework, which will be kept up to date on the Company's website.
RESTRICTIONS OF USE
All the elements and materials, included the code of web pages, drawings, icons, photographs, video clips, or other materials, that exists in this web site, constituting integral part of this web site and constitute intellectual property and signals deposited of this web site.
No material from this web site is allowed to copied, repeated, published, broadcasted, incorporated in other web page, posted, transported or distributed with any other way.
However the web site provide the possibility to the users of downloading anything that is allowed, in their computer, for personal only use and with no commercial aims.
In any case it is prohibited the use of material of this web site for other aims than Internet and the address of the website.
RESTRICTION OF RESPONSIBILITIES
The creators of this website are not accountable with no way and in no case, excluded even that of light negligence, for any damage, serious or not, that will befall as resulting from the use or not of any material of this web site.
ADVERTISING SERVICES
In order to receive all the information relating to the way you can be advertised through this web site you have to give the following information: Forename/Surname-Company Name-Address-Telephone number-Fax Number-email address-Name of the Person Responsible-City -Country.
The web site is not responsible for the privacy policies of the people and companies advertised on it.
NEWSLETTERS
The subscription to the mailing lists for newsletters requires you to give the following information: Email-Forename/Surname-Company Name. The web site may keep a record of all the subscribers’ email addresses in order to send to them other financial or informative messages unless the subscriber does not agree.
COOKIES
Cookies give guests/users a special, random id that are small text files, which are stored on the hard drive of a guest’s/user’s computer.
A cookie itself is not designated or intended to read any information from your computer (other than the contents of the cookie); rather, it is an identifier used by the web site that originally placed it on your hard drive.
Therefore, cookies allow us to automate and access data entry functions such as login information, correlate online ordering information for purchases you may make while at the Site (if any), tailor the Site to your preferences or interests, or customize promotions or marketing.
You may adjust your web browsers to either alert you of the use of cookies or refuse to accept cookies entirely. The guest/user should be aware that if he/she elects not to accept cookies, some parts of the site may not function properly or permit access.
IP ADDRESSES
The IP Address that locates the guest’s/user’s location of computer on the Internet is used only for the collection of statistical data.
LINKS TO OTHER SITES
The web site includes links to other websites that are not controlled by this web site or its affiliates (natural-legal entities). The web site is in no circumstances responsible for the Privacy policies of these websites.
GENERAL GUIDELINES
The web site treats all personal information as confidential and may not disclose such information to third parties (natural-legal entities) with the exception of the relevant provisions of the law that concern forwarding information to the relevant authorities.
The web site records personal information that has been forwarded for communication, financial and tax reasons.
The guest/user may contact the relevant department of this web site in order to check for the existence of a personal record and correct, change or ask for its deletion.
Guests/users that are under the age of consent can only access the services of this web site if they have gained parental consent and they are not asked to give any personal information. However, if such information is provided will be automatically deleted.
It is possible that the web site’s marketing department will process the entire or part of your personal information in order to develop the existing services and for statistical and financial reasons.