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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:

• Request to send a personal data report (ΑR.15 - GDPR)
• Request to delete personal data (ΑR.17 - GDPR)

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.

PRELIMINARY PROVISIONS

These Business Terms and Conditions govern the purchases of goods made via the e-shop located on the website www.s11ltd.com (Hereinafter referred to as the Website), which is operated by the Seller (as defined below).

By submitting an online order, you accept that you are bound by the terms and conditions (hereinafter, the “Terms”) governing all products advertised on our Website. Please read these Terms carefully. It is also recommended that you print a copy of these Terms for future reference. If you do not accept these Terms, you will not be able to place any orders on our Website.

By placing an order on our Website, you declare and warrant that you are legally capable of entering into binding contracts and that you are over the age of 18.

Any order you place is considered only an offer, and is only binding for us once we accept it. When your order is accepted, you will receive an email confirming that your order has been received. This email will also include the payment date and the amount due.

These Business Terms and Conditions define and specify in more detail the rights and obligations of both the Seller (as defined below) and the Buyer (as defined below)

DEFINITION OF BASIC TERMS

• Seller: S11 LTD, with its official registered office located at K.PALAMA 34, 1096 NICOSIA, CYPRUS, Company ID Number: 10414323E, VAT Number: 10414323E (Hereinafter referred to as the Seller)
• e-shop: The internet shop operated by the Website.
• Purchase Agreement: For the purposes of these Business Terms and Conditions, the Purchase Agreement is understood to be an agreement for the purchase of goods.
• Buyer: Any e-shop customer who purchases the Seller's goods (Hereinafter referred to as the Buyer).
• Business Terms and Conditions: These Business Terms and Conditions, always in the valid version published as of the day an Order is placed via the e-shop on the Website.
• Order: An order placed by the Buyer via the Website (Hereinafter referred to as the Order).
• Consumer: A consumer is any individual enters into an agreement or otherwise deals with the business entity outside of the framework of business activities or the performance of their trade.
• Goods: Any of the digital items, consisting primarily of images, videos, e-books offered for sale via the Seller's e-shop, which the Seller sells to the Buyer (Hereinafter referred to as the Goods and Services).

PURCHASE AGREEMENT

Purchase Agreement originating at the time the Buyer places an Order: The Seller advertises its Goods and Services on the e-shop Website. A Purchase Agreement originates at the time the Buyer submits an Order and this Order is accepted by the Seller. The Seller shall confirm the acceptance of the Order by means of a confirmation sent to the Buyer's e-mail address as specified in the Order. The Purchase Agreement may be modified or cancelled only on the basis of a mutual agreement between both parties or for legal reasons.

Prior to the submission of the Order to the Seller, the Buyer has the opportunity to check and modify the information that they have entered on the Order, including the ability of the Buyer to identify and correct any errors made at the time that the data was entered.

The Buyer agrees that remote communication shall be used at the time the Purchase Agreement is made. The costs incurred by the Buyer for using any means of remote communication associated with entering into the Purchase Agreement (namely the cost of an internet connection and the cost of phone calls) shall be borne by the Buyer.

All of the presentations of the Goods and Services published on the website are for informational purposes only and the Seller is not obliged to enter into a Purchase Agreement for these Goods and Services.

Binding Nature of the Business Terms and Conditions. The Buyer is bound by these Business Terms and Conditions immediately starting at the moment the completed Order is submitted. At the time the Purchase Agreement is made, the Buyer is always (re)acquainted with the valid version of the Business Terms and Conditions, and the Buyer must express their consent with the Business Terms and Conditions prior to submitting their Order. By confirming and submitting the Order, the Buyer declares that they are familiar with the valid Business Terms and Conditions.

ORDER CANCELLATION

The Seller reserves the right to refuse to accept or to cancel an Order or a part of an Order in the following situations:

• The Goods and Services are no longer produced or delivered
• The Goods and Services cannot be delivered due to a force majeure event
• The customer has not paid the purchase price as specified on the Order
• The order could not have been firmly acknowledged (incorrect phone No., not available, do not respond to e-mails, etc)

In case such event occurs, the Seller shall immediately notify the Purchaser to agree the next steps. Should the Purchaser already pay the partial or the whole amount of the purchase price, then the given amount shall be transferred back to his account or address within 5 calendar days.

The Buyer has right to cancel the order without any reason whenever before its binding acknowledgment. Once the order was placed as a firm order, only in case that the Seller shall not meet agreed delivery terms. In case the acknowledged order is cancelled, the Purchaser must indemnify damage arising out of such negotiations. The Seller shall set up a claim for damage compensation especially if the goods are purchased "made-to-order" which had to be arranged at customer's request or in case that due to goods arrangement provable costs were already incurred. Cancellation fee may be up to 75% of the total price for goods. The order may be cancelled by e-mail.

PURCHASE PRICE AND RESERVATION OF OWNERSHIP RIGHTS

The current price of the Goods and Services, inclusive of VAT, is always specified on our Website. The price of the Goods and Services specified on the Seller's website on the day the Order is placed is always used to determine the final price of the Goods for the final Buyer. Buyer acquires the ownership rights to the delivered goods only after the purchase price for the Goods has been paid in full.

The Goods and Services sold on our Website are available at the indicated price in Euro. At the last stage of the ordering process, and just before you submit your order, you will have the opportunity to review the total cost of your purchase, as well as any delivery fees and/or fees for payment in cash upon delivery and/or discounts you may be entitled to.

The Seller may modify the prices of its Goods and Services by updating its Website.

Each time, the Buyer will be charged with the applicable price for the Godds and Services at the time of the order.

PAYMENT TERMS

The Seller reserves the right to change the price of the Goods and Services. The price valid at the time the Order is placed (i.e. the current price specified at that time on the Seller's website) remains valid until such time that the Purchase Agreement is made. The Buyer (final Buyer) is obliged to pay the purchase price for the Goods and Services by no later than the day on which the Goods are taken over.

PAYMENT METHODS

• PayPal/Credit Card

  

  The collection of the card details, it's verification and charging are performed in a secure environment (SSL) of PayPal. Therefore this Website do NOT handle or store any of those details.

• Deposit at a Bank Account

  The Order Number must necessarily be provided as the deposit scope and can optionally be accompanied by your full name.

  BANK ACCOUNTS

  • Bank of Cyprus   IBAN: CY03002001950000357034537416   SWIFT: BCYPCY2N

DELIVERY

Upon the completion of the Buyer's online order, the Buyer will receive a confirmation e-mail of his order at our Website.

The Seller will make any reasonable effort to verify and complete the Buyer's online order within a reasonable time.

If the Buyer selected a deposit at a bank account then the completion of this order will only be made after the confirmation of the payment.

After the verification and the completion of the online order, the Buyer will soon receive a new e-mail with complete instructions for accessing its order files.

If the Buyer did not receive the activation email of the online order, the Buyer may check its junk folder otherwise the Buyer can contact us at info@s11ltd.com

MEMBERSHIP

Your membership entitles you to special Services, such as updates on new products and services offered by the Seller, participation in contests, updates on offers and so on

Your membership ID will be indicated on the invoice you will receive. For optimal service, please make sure to have this ID available for future orders.

Your membership cannot be transferred to any third party

It is your responsibility to take all necessary actions to ensure that your contact details in the Website are always up to date

LIABILITY

In respect to our Products and Services, Seller’s liability is limited to what is explicitly stated in these terms of sale. To the extent permitted by the law, all other liabilities are excluded.

PRIVACY

All personal data and other information of personal nature submitted to the Website are governed by our Privacy Policy

GOVERNING LAW

The law requires that certain communications are only performed in writing. You hereby accept that the Seller may contact you by email or mail, and that such communication falls under the legal definition of written communication.

Our agreements will be governed by the Cyprus law, and the Cyprus courts will have sole jurisdiction.

The Seller may amend these Terms from time to time. It is noted that any amendments to these Terms will not apply to the orders submitted prior to such amendments.

Any and all notifications in writing addressed to the Seller must be sent by mail to 34, K.PALAMA Street, 1096 NICOSIA, CYPRUS or by email to info@s11ltd.com

The European Consumer Center of Cyprus has been designated as the national contact point for Online Dispute Resolution. Contact details: http://www.ecccyprus.gov.cy

ACCEPTANCE OF THESE TERMS

You acknowledge that you have read this Agreement and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Agreement. If you do not agree to abide by the terms of this Agreement, you are not authorized to use or access the Website and its Services.

CONTACT US

We want to make sure your visit is as easy and comfortable as possible, but if you have any queries or would like to consult one of our technical experts, don’t hesitate to contact us at info@s11ltd.com

We will be glad to help.

COOKIES POLICY

We use cookies on our site for a number of purposes. They help us to provide you with a good experience when you browse our website, and also allow us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them below.

FIRST-PARTY COOKIES

This website will set some cookies that are essential for the website to operate correctly. These cookies, none of which capture personally identifiable information, are as follows:

• Visitor ID – this cookie is a numeric value that identifies unique visitors and provides coherence and consistency to a site visit;
• Page ID – this cookie identifies the page you are on;
• Session ID – this cookie identifies your website session;
• Member ID – this cookie enables a member to log into secure areas;
• Client ID – this cookie identifies your transaction session;
• Filter ID – this cookie enables certain views of our products catalog;
• Lang ID – this cookie enables the selection of your preffered language;
• cookieconsent_status - this cookie identifies your consent or not about our Cookies policy;

THIRD-PARTY COOKIES

Our website will the following types of third-party cookie, and we do not control the operation of any of them. The third-party cookies which may be set include:

• Maybe there are other third party cookies (Facebook, Twitter, Youtube, etc.) that may be installed on the your computer but which require a prior action performed intentionally by you such as clicking on a link to the third party domain and the cookie is installed from the domain of said third party, not from our site.
• WARNING: all third-party cookies listed above ARE NOT installed on your computer, except with your explicit consent by selecting the ALLOW button in the box at the bottom of the page when you are visiting our site for the first time.
• Google Analytics - we use Google Analytics to collect data about using the site. We use these cookies for the sole purpose of analyzing traffic and improving the performance of our website while at the same time we take appropriate technical measures to securely process your data through the anonymization of the IP address.
  

  The Google Analytics service is owned by Google Inc., which has been certified in the Privacy Shield, which provides adequate safeguards to comply with European data protection law. In the Google Analytics service, our website uses the IP anonymization. With this feature, your IP address is limited by Google and is anonymized when accessing our website.

  You can view the Google Privacy Policy here: policies.google.com/privacy

  Technical information about Google Analytics cookies is available here: developers.google.com/analytics

  You can totally block your data collection through Google Analytics by installing the plug-in in your browser: tools.google.com/dlpage/gaoptout

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.

To manage and disable cookies, follow the instructions for each browser:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari
• Opera Browser

For any information regarding the use of cookies on behalf of our website, you can contact us at info@s11ltd.com

REQUEST TO SEND A PERSONAL DATA REPORT

To request a report under the General Data Protection Regulation (GDPR - Article 15), submit the e-mail address you used on our application.

Once we certify that e your e-mail and your personal data are in use at our database, we will send a full report of your personal data by e-mail.

REQUEST TO DELETE PERSONAL DATA

To request the deletion of your personal data in accordance with the General Data Protection Regulation (GDPR - Article 17), submit the email address you used on our application.

Once we have verified that your e-mail and your personal data are in use at our database, the application will convert your data into anonymous and will delete all data required by the procedure in accordance with the General Data Protection Regulation.