This Privacy Notice will inform you as to how “I-SPIRAL IT SOLUTIONS LTD” (hereinafter referred to as the “Company”, “we”, “us” and “our”) collects and processes information about you and in particular your personal data and is respecting your privacy. We hereby assure you through this Privacy and Personal Data Protection Policy (“Policy”) that we fully respect and comply with the EU Regulation 679/2016 (“Regulation”) and the relevant Law 125 / I / 2018 of the Republic of Cyprus.
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, indicatively by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
We are the Controller in those cases where we determine the purposes and means of the processing of personal data. In those cases, the Controller is the legal person I-SPIRAL IT SOLUTIONS LTD, address 178 Omirou str., 1st Floor, 7102, Aradippou, Larnaca, Cyprus, tel: +357 24 531 975, email: email@example.com.
Principles we adhere to
At I-SPIRAL IT SOLUTIONS LTD, we are committed to and adhering to the following principles of processing personal data in accordance with Article 5 of the Regulation. The personal data are:
- processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of ‘lawfulness, fairness and transparency’);
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (principle of ‘purpose limitation’);
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of ‘data minimisation’);
- accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (principle of ‘accuracy’);
- kept in a form which permits identification of data subjects for no longer than it is necessary or as required by relevant Laws (principle of ‘storage limitation’);
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (principle of ‘integrity and confidentiality’).
Finally, we are able to demonstrate compliance with the aforementioned principles (principle of ‘accountability’).
Collection of Personal Data
We as the Controller collect your Personal Data in the following cases:
- When you contact us directly or indirectly (e.g., through our webpage and/or email, or through our collaborators, or through our Social Media accounts, etc.), in order to be informed regarding our services or ask relevant information, or to request an offer regarding our services;
- If you receive our services signing a contract or agreement with us as well as during the pre-contracting period, if you cooperate with us, or when you are involved in events related to the offer of our services;
- If you fill in any of our documents or you lodge a grievance with us;
- When your personal data is disclosed to us by third parties – partners under contracts or agreements;
- When you are connected to our Wi-Fi or webpage;
- When you are an employment candidate;
- When you are one of our employees.
In addition, it is noted that we process personal data, which third parties, usually legal persons, disclose to us if we have the role of Processors on their behalf. In such case these Legal Persons hold the responsibility to properly inform you.
Minors’ Personal Data
We do not collect and process minors’ personal data without verifiable parental consent in cases when we are able to control it. For example, it is not possible to control information that is communicated to us online or without physical presence. In any event, if we find that we have collected any personal information from a minor without verifiable parental consent (in accordance with Article 8 of the Regulation), we will immediately delete the information from our records. If you believe we may have collected information from a minor, please contact our company.
Categories of Data Subjects
The categories of data subjects when we process your personal data as the Controller include:
- Natural persons or legal persons’ executives interested in our services;
- Persons receiving services or are related to the delivery of our services or natural persons and employees of our suppliers and other legal persons cooperating with us;
- Candidates for employment;
- Visitors of our infrastructure, our webpage and our social media accounts;
- Our staff.
Regarding the Categories of data subjects and the personal data we process when we have the role of the Processor, the Controller holds the responsibility to appropriately inform you.
Kind of Personal Data we may collect about you as the Controller
Data from the following categories of personal information about you (and when it is necessary by the institutional framework of your dependents) may be collected and processed per case in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:
- Contact details with you or of a natural person you may indicate instead of you (name, surname, address, telephone or fax number, email);
- Occupational information (occupation, company, position);
- Identification information such as identification card or passport or ARC number, date and place of birth, date of issue of the passport and it’s expired date.
- Payment and transaction details (IBAN, account number, tax number, desired payment method, terms of payment etc.);
- Incident investigation data, such as incident details, data of persons involved and related information;
- Your photograph if under your specific consent it is uploaded on our website or social media accounts;
- Client history (satisfaction, transaction details, claims, problems, terms) and information related to assessing persons and situations;
- Apps / websites / social media related data (cookies, IP address, full name or nickname, information you publicly disclose and comments on social media, or email attachments);
- IP & MAC address, when you are connected to our Wi-Fi;
- Employment data and/or data referred within your Curriculum Vitae and data related to studies, competencies or previous working experience if you disclose this information to us as candidates.
It is noted that we collect some more kind of personal data about our employees; they are informed through documents, manuals, policies and procedures and information internally provided.
Purposes of Processing & the Legal Bases of Data Processing
The processing of personal data from us as the Controller is based on one of the “legal bases” as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data).
The legal bases on which the collection and processing of personal data is based (in most of the cases) are, the consent, the compliance in performing our contractual obligations, the compliance with our legal and statutory obligations, and the safeguarding of our legitimate interests. For special categories of personal data, the explicit consent, the performance of obligations and the exercise of specific rights of the controller or data subject in the field of labour law and social security / social protection law and for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment. The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: when you communicate with us in any way directly or indirectly as interested in our services, when you are interested in working to or cooperate with us, when you fill in our documents, when informing you about our services in the context of our promotions, when you make a complaint, when you visit our webpage or social media accounts, when you are connected to our wireless network, when you give us your business card.
Commitment to perform our contractual obligations: when you have agreed to receive our services, when you are our employee or collaborator, during the payment of our liabilities or when we are contacting you in the framework of a contract.
Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.
Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, or for the assessment of persons and situations.
Our employees are informed about the processing purposes and the legal bases under specific documents internally.
Retention of Data Period
We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose.
Data collected on the basis of contractual and legal obligations shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework.
Personal Data included in offers that does not lead to a cooperation agreement is kept for 12 months.
Cookies are stored depending on their categories as you may be informed in our cookies policy.
Data collected from our Wi-Fi e.g., IP and MAC address are retained 3 months.
Personal data you disclose to us as candidates are stored for 12 months.
Data that may be needed for our legitimate interests as a Controller shall be kept until the reason for storing such data ceases.
Specifically, for the data we process based on your consent, these are kept from obtaining the consent until it is revoked or there is no longer need to store it.
Information that is no longer necessary is safely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for the specific purpose.
How we ensure the security of Personal Data
We have received reasonable organisational and technical measures to protect the personal data we collect and process, and in particular any specific categories of personal data. We follow international standards (such as ISO 27001 Information Security Management) and practices to ensure the security of our networks. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:
- Access to personal data is restricted to a limited number of authorised employees under a need-to-know basis, and the necessary data transfer is done by secure procedures.
- Our employees are bound by confidentiality rules and agreements, with limited classified access to the necessary data only.
- We select trusted collaborators who are bound in writing, in accordance with Article 28 of the Regulation, with the same obligations regarding the protection of personal data. We reserve the right to audit them in accordance with Article 28 (3) (h).
- In our ICT systems used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access or other illegal processing.
In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.
Some of the security measures we take are not announced for obvious reasons.
To whom the Data may be disclosed
We take measures to ensure that the recipients of personal data are kept to a minimum. The personal data we process as Controller are disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully process as the Controller, may be accessed by (or disclosed to) on a case-by-case basis by:
- Any relating supervisory authority within its role;
- Any public or judicial authority where required by law or judicial decision.
- The auditor of the company, and only in relation to necessary financial data.
- The advocate, for whatever data is required in legal cases, under confidentiality.
- Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
- The training or systems consultants and the Accreditation organisation, the trainer and HRDA (Authority for the human resource training) for training or systems control issues and only for the necessary parts of information and data.
The personal data we collect is processed within the European Economic Area (EEA).
Your rights as a Data Subject and how you can exercise them
You have the right to be informed, the right of consent if it is the legal basis for the processing, the right of access to your personal data, the rights of rectification and erasure (in cases it is permitted), the right to restriction of processing, the right to data portability, the right to object. If processing is based on your consent, you may withdraw it at any time.
The right to be informed is exercised through this privacy and personal data protection notification. In some cases, it is also mentioned on documents and forms we are using. You may ask a hard copy of our policy by communicating with us.
The right of consent is provided by design as we have reviewed all processing activities and ask your consent when the case.
We inform you that we as the Controller are not using software of decision making solely based on automated processing including profiling. More specifically, you have the following additional rights, provided that you will exercise them in writing and after the verification that you are the data subject.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data are being processed as well as other relevant information, and, where that is the case, access to your personal data.
Right of rectification: you have the right of rectification of your inaccurate personal data as well as to have incomplete personal data completed by providing a supplementary statement.
Note: Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process.
Right to erasure (‘right to be forgotten’); we have to answer such right when:
- your personal data are no longer necessary in relation to the purposes for which we collected it;
- withdraw your consent on which the processing is based and where there is no other legal basis for the processing;
- your personal data have been unlawfully processed;
- personal data have to be erased for compliance with a legal obligation we are subject to;
- personal data have been collected in relation to the offer of information society services.
We reserve the right to refuse this right if the processing is necessary for compliance with any legal obligation, we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according Article 17 § 3).
Right to restriction of processing; you have the right to restriction of processing when:
- you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
- you objected to processing pending the verification whether our legitimate grounds override those of yours.
Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and under an explicit request such data to be transferred to both you and another natural or legal person who will process it.
Right to object: you have the right to object to the processing of your data at any time when the reason for the processing relates to direct marketing.
All the above describe your rights where we are the Controller. In cases we are the Processor then your rights related requests should be addressed to the Controller.
In the event that you make such request in a written or electronic form regarding any of the above rights, we will assess your request and respond within one month of its receipt, either for its satisfaction or to provide you with objective reasons preventing it from being satisfied, or, given the complexity of the request and the number of requests at the given time, request an extension of response for a further two months period (according Article 12.3 of the Regulation).
The exercise of your rights is free of charge. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to answer or charge you an administrative fee.
If you are dissatisfied with the use of your data by us, or our response after exercising your rights, you have the right to lodge a complaint with a supervisory authority.
Personal Data Breach
In the event of a breach of the security of the personal data processed, we will take the following measures (in accordance with Article 33 and 34 of the Regulation in case we are the Controller) and we will:
- Assess it in order to implement the appropriate procedures needed to limit the breach;
- Examine the extent of the breach and the sensitivity of the data included;
- Evaluate the risk and its impact on your rights and freedoms;
- Endeavour to reduce as much as possible the damage that is or may be caused;
- Notify within a time limit of 72 hours of becoming aware of the breach, the National Personal Data Protection Authority, if required;
- Assess the impact on your privacy and take appropriate measures to prevent the repeating of the incident.
In the event we are the Processor, we will inform the Controller as soon as possible.
Links to other Websites
By following this link you will be informed on our cookies policy.
Contact details with the National Data Protection Authority
Cyprus Personal Data Protection Authority, 1 Iasonos Street, 1082 Nicosia, telephone +357.22818456, e-mail: firstname.lastname@example.org.
Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=celex%3A32016R0679.
Contact with us
If at any time you want to contact with us or to make a request regarding your rights or any other matter relating to the protection of personal data you may contact with our Chief Information Security Officer: address 178 Omirou str., 1st Floor, 7102, Aradippou, Larnaca, Cyprus, tel: +357 24 531 975, email: email@example.com.
This policy was updated and is effective from May 20, 2021 and will be reviewed when there is a significant change. This review will be available on our website, with a note of the effective date. You may find a hard copy of this policy at our premises or may be dispatched at your request.