1.    INTRODUCTION

1.1.    Benjo Limited, a company registered under the laws of the Republic of Cyprus, with registration number HE436242 and registered office located at Arch. Makariou III, 66, CRONOS COURT, 8th floor, Office 82, 1077 Nicosia, Cyprus (hereinafter the “Company” “we”) is the controller of the personal information of website visitors (hereinafter the “Visitors” or “you”) collected or provided within the scope of its services or where any personal data is supplied to us through this website (hereinafter called the “Website”).

1.2.    The purpose of this Privacy Policy (the “Policy”) is to provide adequate safeguards for the processing of Personal Data by the Company in accordance with General Data Protection Regulation (GDPR) and any other EU or Cypriot applicable privacy laws as amended from time to time.

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1.3.     This Policy sets out how the Company collects and processes your personal information through your interactions with the Website and/or through the your use of our Services. The Company is committed to ensuring that your privacy is protected.

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1.4.     The Company reserves the right to update this Policy at any time. It is your responsibility to check if any changes have been made to this Policy. We may also notify you in other ways from time to time about the processing of your personal information.

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1.5.     It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.

2.    DATA THAT WE COLLECT

2.1.    The personal data collected from you, when visiting the Website or by using the Company’s services  includes but are not limited to, the following:

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i.     Your identity such as your name/ surname.

ii.    Your contact information (email address and phone number)

iii.    Usage Data (through cookies) which includes information about how you use our website, products and services.

iv.   Your IP address, a unique identifier for your computer or other access devices.

v.  We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal in law, as this information will not directly or indirectly reveal your identity. For example, the Company may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

 

2.2.    The Company does not collect any Special Categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor does the Company collect any information about criminal convictions and offences.

 

2.3.    The Company does not collect any kind of personal information related to any individuals under the age of eighteen (18) (hereinafter “Minors”). In the event that the Company becomes aware that personal information relates to Minors, the Company shall proceed immediately with their deletion. 

 

2.4.    Where we need to collect personal information by law, or under the terms of providing you with the Company’s services and you fail to provide that information when requested, the Company may not be able to provide you with its services.

3.    USE OF YOUR DATA

3.1.     The Company shall collect and process your personal data on one of the following legal basis:

 

3.1.1.    Your consent.

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3.1.2.   Processing is necessary to provide you with the Company’s services.

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3.1.3.   Processing is necessary to comply with a legal obligation.

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3.1.4.   Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child

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3.2.   The Company shall process the personal data collected for the following purposes (the “Purpose”):

-    To contact you in response to a specific enquiry.

-    To provide you with the Company’s services.

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-   To improve the Company’s website and the quality of the experience of the i Website’s user(s), inter alia statistics on the frequency of visitors visiting the Website, use of the website.

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-   Following your consent to communicate with you about products or services that you have expressed your interest to receive further information either from the Company, and/or its clients.

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-    To detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.

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-   To enforce the terms and conditions set herein and/or the Website’s Terms and Conditions and/or any other agreement or document signed between the Company and you.

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-  For the Company to comply with any applicable legal obligations as these may derive from the applicable laws or regulations or requests by legal and/or public authorities.

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-    For any other purpose that you have provided the Company with your consent.

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3.3.    The Company shall collect only personal data about you that is absolutely necessary to be able to achieve the Purpose and any processing of personal data shall be restricted solely to the achievement of the Purpose.

3.4.    We will not collect, process or transfer your personal data, for any other Purpose, without your prior consent.

3.5.    Furthermore, unless we are obliged to comply with any law, regulation or court order, we shall not transfer or transmit to any third party any of your personal data, collected through the Website or provided by you, without your prior consent.

3.6.   All personal data communicated to the Company are kept within its own records in accordance with all applicable laws and regulations.

4.    SECURITY 

4.1.  The Company process personal data in a manner that ensures appropriate security and confidentiality, including preventing unauthorised access to or use of your personal data; furthermore, the Company undertakes necessary measures to protect all personal data from any loss, misuse, unauthorised access or disclosure, alteration, or destruction.

4.2.   The Company maintains policies and procedures and has organisational and security measures in place, to ensure high levels protection of personal data which includes but is not limited to, appropriate restrictions on permissions of access to personal information.

4.3.    All employees and providers of the Company are required to follow privacy and security policies and procedures. The Company with regards to links on websites controlled or offered by third parties, which may appear on the Website, hereby waives any responsibility for the security and privacy of any Third Party and/or Social Networking services or any information collected by them. The User should always review the privacy policies of any such Third party or Networking service.

5.    HOW LONG WE KEEP YOUR PERSONAL DATA:

5.1.   As long as there is no predetermined retention period required by law to retain any of your personal information, the Company will only retain your personal information for as long as it is necessary to achieve the Purpose or as required for legal purposes considering local applicable laws and regulations. When information is no longer needed, we immediately delete the data.

6.    YOUR RIGHTS: 

6.1.    Under data protection laws and under certain circumstances, you have the below rights in relation to your personal data:

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i.     Right to access your personal data: You may request from us a copy of your personal data we hold and check that we are lawfully processing it. The Company hereby reserves the right to charge a relevant fee for providing such record of personal data to the person requesting this, except where this is not allowed under local legislation.

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ii.    Right to correction of the personal data in our records: You may request us to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.

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iii.    Right to erasure of your personal data: You have the right to request that we erase or remove your personal data under certain circumstances. This applies where there is no good reason for us to continue to process it, or where you have successfully exercised your right to object to processing (as per below), or where you believe we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

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iv.   Right to object to the processing of your personal data: Where we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object.

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v.    Right to request restriction of processing of your personal data: You have the right to request that we restrict and/or suspend the processing of your personal data under certain circumstances: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you prefer us to restrict our processing of it rather than erasing it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have superseding legitimate interest to use it.

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vi.    Right to request the transfer of your personal data to you or to a third party: Upon your request we can provide you with your personal data or provide these to a third party of your choice.

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vii.   Right to withdraw consent at any time: Where we have obtained your consent to process your personal data, you may withdraw your consent at any time. Note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.

7.    COOKIES: 

7.1.   Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

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7.2.   Our Website uses cookies when you visit our Website. The use of Cookies allows the Company to improve the use and functionality of the Website and to better understand how visitors use our Website and the tools and services offered on it. Cookies help the Company to, inter alia, improve the Website’s user-friendliness, improve the content and the services.

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7.3.   Our Website uses cookies to help identify your computer, so as to tailor your user experience. You can control and/or delete cookies at any time and as you wish directly from within your own internet browser or mobile device and prevent any installation. You can disable any cookies already stored on your computer, but these may stop our Website from functioning properly. By accepting our Privacy Policy, you are, accepting the data processing and collecting provisions set forth herein and you are giving your consent to the processing of your personal data as set forth in this Privacy Policy. You can read more about the cookies we use in our Cookies Policy

8.    MODIFICATIONS TO THIS PRIVACY POLICY: 

8.1.   The Company is entitled to unilaterally modify this Privacy Policy at its sole discretion. This Privacy Policy may be amended from time to time, and you should refer to our Website regularly to stay up to date.

9.    ACCEPTANCE OF THESE TERMS:

9.1.    By continuing browsing and/or using the Website and/or using or subscribing to the Company’s services and/or by contacting the Company through the Company’s official communication channels, you consent to such processing, and you warrant that all personal data and information you provided to us is accurate and up-to-date.

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9.2.    By using this Website, you are also agreeing to all terms and conditions provided in this Privacy Policy as well as other information found in this Website. You, therefore, agree to waive all rights to holding the Company liable for any claim arising out of, or in connection with the processing of your personal data, as mentioned herein, unless such data has been fraudulently or negligently processed, as against the terms laid down in this Privacy Policy.

10.    HOW TO CONTACT US: 

10.1.    Should you have any questions about this Privacy Policy and/or how the Company handles your personal data and/or you wish to exercise any of your rights please contact us at privacy@benjo.services.