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<div class="terms-conditions">
<div class="container">
<div class="terms-conditions__title titleM">
<h1>PRIVACY POLICY</h1>
</div>
<div class="terms-conditions__term">
<p>
<strong>At Quadcode</strong> we understand that your privacy is
important to you and that you care about how your personal data is
used. We will only collect and use personal data in ways that are
described here, and in a way that is consistent with our
obligations and your rights under the applicable local
legislation, the Data Protection Legislation and the Privacy and
Electronic Communications (EC Directive) Regulations 2003 and the
EU Regulation No. 2016/679 the General Data Protection Regulation
(collectively “<strong>GDPR</strong>”). This Privacy Policy sets
out the basis on which we may collect, use or otherwise process
personal data via our website
<a href="https://www.quadcode.com" target="_blank"
>www.quadcode.com</a
>
(<strong>Website</strong>), downloadable software, mobile
applications, desktop applications, content, features, function
and/or via any other services provided by us and on which a link
to this Privacy Policy is displayed, and/or all other
communication with you through written or oral means, such as
email, chat or phone (collectively the
“<strong>Services</strong>”) when you use our Services and the
choices you have associated with that personal data.
</p>
<p>
Please note that this Privacy Policy is addressed to our
prospective, current and former clients. If you are, were or may
be a potential, QuadCode employee your personal information will
be used in connection with your employment in accordance with our
separate policy which are available at
<a href="https://jobs.quadcode.com" target="_blank"
>jobs.quadcode.com</a
>.
</p>
<p>
We use your personal data to provide and improve our Services.
Your acceptance of this Privacy Policy is deemed to occur upon
your first use of our website and any of the Service.
</p>
</div>
<div id="Title1" class="terms-conditions__term">
<h2>1. Who We Are</h2>
<p>
QHL QUAD CODE HOLDING LIMITED, a limited liability company part of
the QUAD CODE Entities, incorporated and registered in the
Republic of Cyprus under company number HE390331 and have our main
business office at 82nd road, 4 Kato Polemidia, 4153, Limassol,
Cyprus (hereinafter “<strong>Quadcode</strong>”). Quadcode is the
Controller and responsible for the personal information you
disclose to us to make use of our Services.
</p>
<p>
This Privacy Policy is issued on behalf of the Quadcode Group. The
Quadcode Group is active across the world. We have offices and
entities located in Cyprus, Gibraltar, Australia, Bahamas, the
United Arab Emirates and the United Kingdom together with their
respective affiliated companies, (collectively referred to as the
“<strong>Quadcode Group</strong>”)so when we mention “Quadcode”,
“Company”, “we” or “us” in this Privacy Policy we are referring to
the relevant company within the Quadcode Group responsible for
collecting and/or processing your
<strong>personal data</strong> when you use the Services. Quadcode
respects your privacy and therefore all the companies within the
Quadcode Group are committed to protect your data, which it
collects and/or has access to.
</p>
</div>
<div id="Title2" class="terms-conditions__term">
<h2>2. DATA COLLECTIONS AND PROCESSING</h2>
<p>
We collect, process, store and transfer different kinds of
personal data about you for various purposes in order to be able
to provide and improve our Service to you. Depending upon your use
of the Service we may collect some or all the personal data set
out below as follows. Please also see Cookies Section for more
information about our use of Cookies and similar technologies.
</p>
<ul>
<li>
<strong>Identity Data</strong> includes first name, last name,
and patronymic (if available), date of birth gender, passport,
ID, Driver’s number, and copy of photo.
</li>
<li>
<strong>Contact Data</strong> includes billing address, email
address and telephone numbers.
</li>
<li>
<strong>Technical Data</strong> includes internet protocol (IP)
address, your login data, browser type and version, time zone
setting and location, browser plug-in type and versions,
operating system and platform, and other technologies on the
devices you use to access the Website and use of cookies stored
on your device.
</li>
<li>
<strong>Usage Data</strong> includes information about how you
use Website, products and Services and IP history.
</li>
<li>
<strong>Data in KYC (Know your customer)</strong> includes
identity document information, including copies of recent dated
Utility Bills, Identity Card, Passport, and/or Driver’s License,
Tax Identification Numbers (TIN).
</li>
<li>
<strong>Location Data</strong> includes details on your actual
location when interacting with our Website (for example, a set
of parameters that determine regional settings of your
interface, namely residency country, time zone, and the
interface language)
</li>
<li>
<strong>Audio Data</strong> includes full voice recordings of
calls that you receive from us or make to us.
</li>
<li>
<strong>Aggregated Data</strong> includes statistical or
demographic data for any purpose. Such data can be derived from
your data but may not be considered personal data in law as it
will not directly or indirectly reveal your identity. An example
of such Aggregated Data could be that we aggregate your Usage
Data to calculate the percentage of users accessing a specific
website feature and/or services/product preference.
Notwithstanding the above, if Quadcode combines Aggregate Data
with data in a way that the end result can in any way identify
the data subject, Quadcode shall treat such combined data as
data which will be treated as per the provisions herein
contained. (the above collectively referred to as “<strong
>personal data</strong
>”)
</li>
</ul>
<h2>
3. Our Website is not intended for children and we do not
knowingly collect data relating to children. As we do not allow
users under the age of 18 to use our services, we need to obtain
your birth date in order to confirm the Clients’ age checks.
</h2>
</div>
<div id="Title3" class="terms-conditions__term">
<h2>4. PROCESSING OF YOUR DATA</h2>
<p>
Processing of your Data is carried out by Quadcode following the
principles of lawfulness, fairness, transparency and always
adhering to the intended purpose of data processing, the principle
of data minimization, accuracy, limited data storage, data
integrity, confidentiality and accountability. Quadcode may
process your personal data for any of the following reasons:
</p>
<ul>
<li>To perform its contract with you,</li>
<li>
To comply with its legal and regulatory obligations, including
without limitation to the,
</li>
<li>
To perform compliance checks, such as verification of your
identity, and helping to detect fraudulent or malicious activity
on our site or services,
</li>
<li>To maintain our accounts and records,</li>
<li>
To manage our business needs, such as monitoring, analysing, and
improving the Services and the Website’s performance and
functionality,
</li>
<li>
To comply with all applicable laws and regulations; and/or
</li>
<li>
For the purposes of safeguarding our legitimate interests and
your interests and fundamental rights do not override those
interests.
</li>
</ul>
</div>
<div id="Title4" class="terms-conditions__term">
<h2>5. DATA RETENTION</h2>
<p>
We will not keep your personal data for any longer than is
necessary considering the reason(s) for which it was first
collected in accordance with this Privacy Policy. To determine the
appropriate retention period for your personal data, we consider
the amount, nature and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal
data and whether we can achieve those purposes through other
means, and the applicable legal, regulatory, tax, accounting and
other requirements.
</p>
<p>
To comply with the applicable legal, regulatory, tax, accounting
requirements we keep your personal data for a minimum period of 5
years from the date our business relationship is terminated. We
may need to retain your information for a longer period where we
need the information to comply with regulatory or legal
requirements or where we may need it for our legitimate business
purposes, such as to respond to queries or complaints, fighting
fraud and financial crime and responding to requests from
regulators.
</p>
<p>
At the expiration of the personal data retention period the
personal data is erased by irreversible destruction and we also
inform all third parties, to whom the personal data was
transferred, regarding such erasure and request implementation of
similar actions on their part.
</p>
</div>
<div id="Title5" class="terms-conditions__term">
<h2>6. DATA SECURITY</h2>
<p>
We protect your data by adhering to industry standard regulations
on data protection by categorising them into data types (e.g.
technical, personal data, cookie data, etc) while applying
relevant protection processes and due diligence procedures.
Therefore, we apply appropriate technical and organisational
controls to protect your data, including secure computer systems
adopting least privilege access in order to prevent unauthorised
access, disclosure, modification, or destruction of personal data.
Any hard copy documents are locked in a secure cabinet, and
destroyed once no longer required.
</p>
<p>
<strong>Encryption of your data in transit</strong>. Encryption
provides a high level of security and privacy for your personal
data. When personal data in provided when using our Services, we
use strong encryption technologies (such as Transport Layer
Security) to protect the personal data during transmission from
your devices to our servers.
</p>
<p>
For providing more trust and security we use digital EV (Extended
Validation) Certificates issued by trusted Certificate
Authorities. You can see the ‘Green Bar’ in the supported browser
versions which confirms what all transmitted personal data is
secure.
</p>
<p>
<strong
>Protection of your personal data in our infrastructure</strong
>. We make it a priority to develop Services that are secure "by
default". The "default" security of our Services means that every
new services and features are designed with strict security
requirements in mind before we even begin development. This is the
key to guaranteed protection and privacy of all personal data that
our Services handle and store, once the service or new feature is
released.
</p>
<p>
To secure personal data, we use the pseudonymisation which allows
most of our Services to operate without using your actual data.
Instead of that, our services use a system ID that can't be traced
back to identify you.
</p>
<p>
Quadcode is always vigilant about the Security of the personal
data stored in our infrastructure. Because of that we locate all
our equipment used for your personal data processing in secure
personal data centres. Network access to this equipment is
isolated from the Internet. We use network segmentation for
isolation of Services which need different level of security from
each other. In addition, we restrict logical access to the
personal data for our employees on "need to know" basis. So, only
personnel, who really require access to the personal data for the
purpose of providing you with our best Service, will have access
to it.
</p>
<p>
<strong>Threats protection</strong>. Quadcode is highly
knowledgeable about modern threats to personal data security and
privacy, and we are well prepared to combat them. All events that
occur in our infrastructure are continuously monitored, analysed
and responded, which allows us to ensure proper protection of your
personal data, keeping it safe from threats, vulnerabilities, and
the effects of malware.
</p>
<p>
In the event of a failure that affects the accessibility of your
personal data, we have personal data backup and recovery
procedures in place that will help us to restore your personal
data in a short time. For further guarantee the quick recovery we
use high availability mode enabled for most critical databases
which allows us to minimise downtime.
</p>
<p>
<strong>Employee awareness of data security</strong>. Our
employees may handle your personal data in order to provide you
with the first-class Service. To guarantee the security and
confidentiality of your personal data, we monitor all employees’
actions with access to your personal data in our systems and grant
access strictly on a "need to know" basis: only employees who need
access will receive it. We hold regular training sessions to make
sure that each employee understands the principles that Quadcode
follows to achieve robust data security and privacy.
</p>
<p>
<strong
>If you choose not to give your personal information</strong
>. In the context of our business relationship we may need to
collect data by law, or under the terms of a contract we have with
you. Without this data, we are, in principle, not in a position to
close or execute a contract with you. If you choose not to give us
this data, it may delay or prevent us from meeting our
obligations. It may also mean that we cannot perform the Services.
</p>
<p>
<strong
>To what extent we carry automated decision-making and
profiling</strong
>. In establishing and carrying out a business relationship, we
generally do not use automated decision-making. If we use this
procedure in individual cases, we will inform you of this
separately. In some cases, we may proceed with profiling in order
to evaluate certain personal aspects. We shall inform you
accordingly in case we perform any profiling. In general, any data
collection that is optional would be made clear at the point of
collection.
</p>
</div>
<div id="Title6" class="terms-conditions__term">
<h2>7. DATA COLLECTIONS</h2>
<p>
We use different methods to collect data from and about you
including through:
</p>
<p>
<strong>Direct Interactions</strong>. You will provide to us your
Identity, Contact and Financial Data online through the Website
and/or by completing and filling online forms and/or by
corresponding with us by emails or otherwise.
</p>
<p>
We require to collect the above data in order to that we are able
to (i) provide our services efficiently, (ii) to comply with our
ongoing legal and regulatory obligations, including, inter alia,
(a) to prevent fraud and money laundering acts and/or (b) conduct
the assessment of suitability and appropriateness test.
</p>
<p>
If you fail to provide the data when requested we may not be able
to perform the contract we have or trying to enter into with you
(for example, to provide you with our Services). In this case, we
may have to cancel a Service you have with us but we will notify
you if this is the case at the time.
</p>
<p>
It is important that the data we hold about you is accurate and
current. Please keep us informed if your data changes during your
relationship with us.
</p>
<p>
<strong>Automated Technologies or Interactions</strong>. When
using our services, your device automatically transmits to us its
technical characteristics. Locale (a set of parameters that
determine regional settings of your interface, namely, residence
country, time zone and the interface language) is used for the
purpose of providing you with the best possible service within our
platform.
</p>
<p>
Using the information about IP address, cookies files, information
about browser and operating system used, the date and time of
access to the site, and the requested pages addresses allows us to
provide you with the optimal operation on our web application,
mobile and/or desktop versions of our application and monitor your
behaviour for the purpose of improving the efficiency and
usability of our Services.
</p>
<p>
We use web analytics tools to track performance of our website and
marketing source of user by cookies in order to optimize our
marketing costs and provide users with better experience.
</p>
<p>
You may at any time request that we refrain from any such
transmissions (to the degree this is possible and subject to any
of our legal obligations) by sending your request to the DPO using
our details in the OUR CONTACT DETAILS below using the registered
email address you disclosed and registered with us. We will
address your request within 30 business days.
</p>
<h2>8. COOKIES</h2>
<p>
A cookie is a small amount of data that often includes a unique
identifier that is sent to your computer or device browser from a
website's computer and is stored on your device's hard drive for
tracking site usage. A website may send its own cookie to your
browser if your browser's preferences allow it, but, to protect
your privacy, your browser only permits a website to access the
cookies it has already sent to you, not the cookies sent to you by
other websites. 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 Website and to provide and improve
our products and Services. We have carefully chosen these Cookies
and have taken steps to ensure that your privacy and personal data
is always protected and respected.
</p>
<p>
By using our Website, you may also receive certain third-party
cookies on your computer or device. Third-party cookies are those
placed by websites, services, and/or parties other than us. For
more details, please refer to the table below. All Cookies used by
and on our Website are used in accordance with applicable
legislation on the use of cookies
</p>
<p>
Our Website uses analytics services, which are a set of tools used
to collect and analyse anonymous usage information, enabling us to
better understand how our Website is used. This, in turn, enables
us to improve our Website and the Services offered through it. 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 Website, it does enable us to continually improve our
Website, making it a better and more useful experience for you.
</p>
<p>
You will be required to provide cookie consent by acknowledging
the privacy and cookie policies during registration of your
account. By giving your consent to the placing of Cookies you are
enabling us to provide the best possible experience and service to
you. You may, if you wish, deny consent to the placing of Cookies;
however certain features of our Site may not function fully or as
intended.
</p>
<p>
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 Website more quickly and efficiently including, but not
limited to, login and personalisation 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.
</p>
<p>
You can instruct your browser to enable or disable cookies, refuse
all cookies or to indicate when a cookie is being sent. Please
note that by doing so you may not be able to use all the provided
functions of our Website and/or Services in full.
</p>
<p>We use the following cookies:</p>
<table class="terms-table">
<tbody>
<tr>
<td>
<strong> Strictly Necessary Cookies </strong>
</td>
<td>
These are cookies that are required for the operation of Our
Site. They include, for example, cookies that enable you to
log into secure areas of our website.
</td>
</tr>
<tr>
<td>
<strong> Analytics and Performance Cookies </strong>
</td>
<td>
We use third party analytics providers, such as Google
Analytics to collect information about the usage of our
services and enable us to improve how these services work,
for example, by ensuring that users are finding what they
are looking for easily.
</td>
</tr>
<tr>
<td>
<strong> Functionality Cookies. </strong>
</td>
<td>
These are used to recognise you when you return to Our Site.
This enables us to personalise our content for you and
remember your preferences (for example, your choice of
language or region).
</td>
</tr>
<tr>
<td>
<strong> Targeting Cookies </strong>
</td>
<td>
We use third party targeting tools, such as LinkedIn
Insights and ads tags. These cookies record your visit to
our website, the pages you have visited and the links you
have followed. We will use this information to make our
website and the advertising displayed on it more relevant to
your interests.
</td>
</tr>
</tbody>
</table>
<p>
Please see our <a href="cookie-policy.html">cookies policy</a> for
further details.
</p>
</div>
<div id="Title7" class="terms-conditions__term">
<h2>9. DISCLOSURE OF DATA</h2>
<p>
We strive to maintain discretion with respect to client related
matters and assessments of which we acquire knowledge. We may
disclose data that concerns you only if (i) we are legally
required to do so; (ii) if required when you expressly order us to
process a transaction or any other service and (iii) it is
required for the provision of our services under our contractual
relationship and/or (iv) protection of our legitimate interests,
in accordance with the provisions of the GDPR and applicable local
legislation as amended from time to time.
</p>
<p>
We may share your personal data in the following circumstances,
the following are examples of where and how your information may
be transferred, but please note this is not an exhaustive list and
that due to ongoing changes in our IT and operational
infrastructure this may change at any time:
</p>
<ul>
<li>
We may share your data between the Quadcode Group on a
confidential basis in order to provide you with our Services.
</li>
<li>
We may have to share your personal data with third parties
service providers, processing data on our behalf, who help us
with our business operations. When your personal data is shared
with a third party, we will take the necessary 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. We ensure that our contracts
with those third parties contain the appropriate GDPR model
clauses and that all our third parties are also compliant with
the GDPR, this affords your data the same protection away from
our organisation, as it does within it. Your personal data is
shared with third party organisations/entities including but not
limited to:
</li>
</ul>
<ol type="A">
<li>
<strong>Service Providers</strong>. We may share your personal
data with our trusted third party service providers, who, on our
behalf, operate, maintain, and/or support our IT systems and IT
infrastructure, our websites, manage our payment solutions,
perform statistical analysis, marketing and advertising
purposes, sending newsletters, provide customer support and
perform other important services for us. We will store and
process your data following industry best practice and security.
Some of that processing takes place at our offices and data
centres in Amsterdam and Frankfurt.
</li>
<li>
<strong>Regulator and state authorities</strong>. The Company
will make such disclosure only if required to be disclosed by
the Company by applicable law, regulation or court order and to
the minimum required extent.
</li>
<li>
<strong>Other disclosures</strong>. In addition to where you
have consented to a disclosure of the data or where disclosure
is necessary to achieve the purpose(s) for which, it was
collected, data may also be disclosed in special situations,
where we have reason to believe that doing so is necessary to
identify, contact or bring legal action against anyone damaging,
injuring, or interfering (intentionally or unintentionally) with
our rights or property, users, or anyone else who could be
harmed by such activities, or otherwise where necessary for the
establishment, exercise or defence of legal claims. Where
reasonably possible, management shall ensure that third parties
collecting, storing or processing personal information on behalf
of the Company have:
<ol type="a">
<li>
Signed agreements to protect personal information consistent
with this Privacy Policy and information security practices
or implemented measures as prescribed by GDPR;
</li>
<li>
Signed non-disclosure agreements or confidentiality
agreements which includes privacy clauses in the contract;
and/or
</li>
<li>
Established procedures to meet the terms of their agreement
with third party to protect personal information.
</li>
</ol>
</li>
<li>
<strong>International Transfers</strong>. We process data within
the EEA and countries deemed by the European Union as having
adequate safeguards for protecting personal data. These
countries are recognised by the EU as having suitable safeguards
for the rights and freedoms of individuals and recourse
processes by which data subjects can exercise their rights.
</li>
</ol>
<p>
Should there be a business need to transfer or process your data
to company(ies) and/or third parties might imply a transfer of
your data to third countries, which may not fall within ambit of
the GDPR (so called <strong>Third Countries</strong>) we will
ensure that they are subject to appropriate security measures and
safeguards as deemed appropriate under GDPR and other relevant
national and international data protection laws. This may include
entering into the appropriate contractual agreements to regulate
any such transfers and safeguard any personal information
transferred to them. A transfer to a company and/or third party
based in a Third Country would only take place where one of the
following applies:
</p>
<ol>
<li>
The individual has given consent to the transfer of information
</li>
<li>
The transfer is necessary for the performance of a contract
between the individual and the Company, or the implementation of
pre-contractual measures taken in response to the individual’s
request.
</li>
<li>
The transfer is necessary for the conclusion or performance of a
contract concluded in the interest of the individual between the
Quadcode group company and a third party.
</li>
<li>
The transfer is necessary or legally required on important
public interest grounds or for the establishment, exercise or
defence of legal claims.
</li>
<li>The transfer is required by law.</li>
<li>
The transfer is necessary in order to protect the vital
interests of the individual.
</li>
<li>The transfer is made under a data transfer agreement.</li>
<li>The transfer is otherwise legitimised by applicable law.</li>
</ol>
<p>
Remedial action shall be taken in response to misuse or
unauthorized disclosure of personal information by a third party
collecting, storing or processing personal information on behalf
of Quadcode.
</p>
<p>
If you want to obtain further information on any data transfers
mentioned above please contact us using the registered email
address you disclosed to us through the points of contact listed
in the Section OUR CONTACT DETAILS.
</p>
</div>
<div id="Title8" class="terms-conditions__term">
<h2>10. YOUR RIGHTS</h2>
<p>
Under certain circumstances in accordance with GDPR and the
applicable local legislation as amended from time to time you have
rights, which we will always work to uphold. Some of the rights
are rather complex and include exemptions, thus we strongly advise
you to contact us (at the contact details listed in the section
OUR CONTACT DETAILS below) and/or seek guidance from the
regulatory authorities for a full explanation of these rights. You
can find a summary of your rights below in this section:
</p>
<ol type="a">
<li>
The right to be informed about our collection and use of your
personal data. This Privacy Policy should tell you everything
you need to know, but you can always contact us to find out more
or to ask any questions.
</li>
<li>
The right to access the personal data we hold about you. Upon
request and verification of your identity, we will send you a
copy of the personal data we hold about you.
</li>
<li>
The right to have your personal data rectified if any of your
personal data held by us is inaccurate or incomplete. It is
important that your personal data is kept accurate and up to
date. If any of the personal data we hold about you changes,
please keep us informed if we have that data.
</li>
<li>
The right to be forgotten, i.e. the right to ask us to delete or
otherwise dispose of any of your personal data that we hold. We
may not always be able to comply with your request of erasure
for specific legal reasons, for which you will be notified.
Please note that retention requirements supersede any right to
erasure requests under the data protection laws.
</li>
<li>
The right to restrict (i.e. prevent) the processing of your
personal data. Please note that any requests in relation of the
processing of your data means that we may not be able to provide
you with the service, in which case you will be notified.
</li>
<li>
The right to object us in using your personal data for a
particular purpose or purposes.
</li>
<li>
The right to withdraw consent. This means that, if we are
relying on your consent as the legal basis for using your
personal data, you are free to withdraw that consent at any
time.
</li>
<li>
The right to data portability. This means that, if you have
provided personal data to us directly, we are using it with your
consent or for the performance of a contract, and that data is
processed using automated means, you can ask us for a copy of
that personal data to re-use with another service or business in
many cases.
</li>
<li>
Rights relating to automated decision-making and profiling. We
do not use your personal data in this way.
</li>
</ol>
</div>
<div id="Title9" class="terms-conditions__term">
<h2>11. CONTACT US</h2>
<p>
Quadcode only processes your personal data in compliance with this
Privacy Policy and in accordance with GDPR, while meeting highest
possible data protection standards, and as such, we treat data
protection complaints with all seriousness. So, should you have
any reservations or complaints as to how we process(ed) your
personal data, you can contact us through the following address:
</p>
<table class="terms-table-two">
<tbody>
<tr>
<td>Full Name of Legal Entity:</td>
<td>QHL QUAD CODE HOLDING LIMITED</td>
</tr>
<tr>
<td>Email Address:</td>
<td>
<a href="mailto:dpo@quadcode.com">dpo@quadcode.com</a>
</td>
</tr>
<tr>
<td>Postal Address:</td>
<td>
82nd road, 4<br />
Kato Polemidia, <br />
4153 Limassol, <br />
Cyprus
</td>
</tr>
</tbody>
</table>
<p>
To enable us to process your request, please contact us using the
registered email address you disclosed and registered with us. We
may require that you provide us with proof of your identity, such
as by providing us with a copy of a valid form of identification.
This is to ensure that we appropriately protect the personal data
we hold from unauthorised access requests and comply with our
security obligations.
</p>
<p>
If you have any questions, or want more details about how we use
your data, you may contact us at the above contact details and we
will be happy to provide you with further details.
</p>
<p>
If following your request to us we are unable to provide you with
a satisfactory answer then you may lodge a complaint with the
local data protection supervisory authority. The data protection
supervisory authority in Cyprus is: Commissioner for Data
Protection P.O. Box 23378, 1682 Nicosia, Cyprus-
www.dataprotection.gov.cy
</p>
<p>
We would however appreciate the chance to deal with your concerns
before you approach the GRA, so please contact us in the first
instance.
</p>
</div>
<div id="Title10" class="terms-conditions__term">
<h2>12. CHANGES TO THIS PRIVACY POLICY</h2>
<p>
We may provide links to third party websites in our Website. These
linked websites are not under our control, and we therefore cannot
accept responsibility or liability for the conduct of third
parties linked to our websites, including without limitation to
the collection or disclosure of your data. Before disclosing your
data on any other website, we encourage you to examine the terms
and conditions of using that website and its privacy policies.
</p>
</div>
<div id="Title11" class="terms-conditions__term">
<h2>13. CHANGES TO THIS PRIVACY POLICY</h2>
<p>This Privacy Policy was last updated on 30th of August 2023</p>
<p>
We have the right, at our discretion, to 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 and in order to ensure that the
information herein provides relevant and adequate information
about our collecting and processing of your data
</p>
<p>
n case of any changes will be posted on the revised Privacy Policy
on our Website Changes will take effect as soon as the revised
version is made available on our website above. Thus, we recommend
that you check the Website regularly to keep up-to-date. Your
comments and feedback are always welcome. You may contact us at
any time through the points of contact listed in the Section OUR
CONTACT DETAILS.
</p>
</div>
</div>
</div>
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