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<div class="terms-conditions">
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<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 Spyrou Kyprianou
& Evgeniou Voulgareos 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>
Spyrou Kyprianou & Evgeniou Voulgareos, <br>
Kato Polemidia, <br>
4153 Limassol, <br>
Cyprus
</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>
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