D.A. STROMAN Limited (hereinafter referred to as “the Company”, “we” “us”, “our”) takes the protection of your personal data and privacy very seriously when collecting and processing your personal data. We ensure you that we fully respect the EU 679/2016 Regulation “on the protection of natural persons with regard to the processing of personal data and on the free movement of such data” as well as the National Law 125/I/2018 accordingly.
– 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, in particular by reference to an identifier such (indicatively) 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.
– 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.
– 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 the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
– Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
3.WHO IS THE CONTROLLER
4.PRINCIPLES WE COMPLY
We in D.A. STROMAN Limited comply with the following principles according to Article 5 of the Regulation:
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’).
Principle of Accountability: We in D.A. STROMAN Limited are able to demonstrate compliance with the aforementioned principles.
5.WHEN WE COLLECT PERSONAL DATA
• When you contact us directly, or through our representatives and affiliates, or when connecting to our website or social media accounts, when contacting us in order to be informed or to request information about the products and services we offer;
• If you purchase products and services from us or when you are involved in events related to the sale of our products and services;
• When you fill in any of our physical or electronic forms or when we fill in such forms in our information system at your suggestion and guidance;
• If your personal data are transferred to us by collaborating companies in the framework of a contract you have sign with those collaborating companies or a contract we have with those companies;
• When you enter our infrastructure and in case in this infrastructure a CCTV system is in operation or if you are connected to our Wi-Fi;
• When you contact us in any way as an employment candidate and sending your CV.
• When you are employed by us.
We process your personal data for the purposes set out in detail below.
6.MINORS’ PERSONAL DATA
We do not collect minors’ personal data without verifiable parental consent in cases where we are able to verify it. For example, it is not possible to verify information that is online disclosed to us. In any case, if we become aware having collected any minor’s personal data without verifiable parental consent, we will directly erase such information (according Article 8 of the Regulation). If you are aware that we may have collected minor’s personal data, please contact us.
7.CATEGORIES OF DATA SUBJECTS
The categories of data subjects regarding personal data we process include:
• Natural persons interested in our products and services as well as visitors of our premises;
• Our clients or clients of our corporate collaborators;
• Third natural persons involved in events related to the sale of our products or the provision of our services;
• Suppliers or collaborators who are natural persons, or even natural persons in their capacity as employees, managers or partners in a legal entity connecting as a supplier or affiliate with us;
• Employment candidates;
• Visitors to our website or our accounts in the social media or when connected to our Wi-Fi;
• Our employees.
8.WHICH PERSONAL DATA DO WE COLLECT
Personal data under the following categories may be collected and processed as described in this Policy:
- Your contact details such as full name, address, telephone /fax number and email address or corresponding contact details of a third person you may indicate to act on your behalf;
- Occupational status information (occupation, position);
- Information required for signing a contract or an agreement or of people involved in this contract or agreement signing, the terms of agreement, amounts;
- Payment details (IBAN or account number, tax identification number, desired payment method, payment terms, depositor’s address and signature or other depositor’s contact details, credit card details);
- Customer’s history (satisfaction rate, quotes received, market data, transaction data, complaints, product problems, terms of cooperation);
- Apps or websites or social media related information such as IP or MAC address, cookies, name under which you appear in the media and photographs or any other public information or comments in such media;
- Your image when you enter our premises in case there is a CCTV system operating, or when you attend our events in case when we take photos in the event under your consent;
- Your personal data that are referred to your CV if you send it to us.
In the case of our employees we collect some more necessary personal data; they are internally informed through documents and manuals.
9.PURPOSE OF THE PROCESS AND LEGAL BASIS
The processing of your personal data is based on one of the “legal bases” referred to 679/2016 Regulation and specifically Article 6 (or Article 9 for specific categories of data).
- Your consent as data subject.
- The performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
- For compliance with a legal obligation to which we as ‘the controller’ are subject.
- For the purposes of the legitimate interests pursued by us as the controller or by a third party and only in where such interests override the interests or fundamental rights and freedoms of the data subject.
Special categories of personal data according Article 9 of the Regulation are only collected under a specific legal basis from our employees; they are internally informed through documents and manuals about this.
The personal data we process are connected with the above mentioned legal bases as follows:
Consent: when you contact us physically or electronically either as interested in our products and services or as a potential corporate partner, when contacting us as candidates for employment, or when informing you during our promotion activities, when you make a complaint or when you evaluate us, or when you visit our website and social media accounts, or when you are connecting to our Wi-Fi, or when you give us your personal/ professional card.
Performance of a contract: when you are our client for serving you and the fulfillment of our agreement, when you are one of our employees an affiliate or supplier for the compliance with the contractual terms, or when we communicate with you prior or under the contract as well as for the payment of our liabilities.
Legal Obligations: for the compliance with our legal obligations towards authorities such as prosecuting authorities, police, labor law and regulatory authorities, tax and auditing authorities or judicial authorities.
Legitimate interests: for improving our services, for our payment, for assessing and evaluating persons and situations or when you visit our premises where a CCTV is operating.
Our employees are internally informed through documents and procedures on the purpose and legal bases when collecting and processing their personal data.
10.STORAGE OF PERSONAL DATA TIME LIMITS
We store personal data for as long as required by the respective processing purpose and any other lawful linked purpose.
Personal data that are collected under the legal basis of ‘Performance of a contract’ or the legal basis of ‘Legal Obligations’ are maintained after the expiry of the contractual and legal obligations as long as the relevant institutional framework permits or as long as product warranties are maintained.
Personal data included in an offer that does not lead to a cooperation agreement are kept for 12 months.
CCTV records are maintained for up to 8 days, IP and Mac address are only maintained 24 hours after your Wi-Fi disconnection, while cookies retention period is referred to our cookies policy in the present webpage.
Data that may be necessary for our legitimate interests as the Controller are maintained until the reason for such storage has expired.
Personal data we process based on your consent and especially those for marketing purposes, are stored from obtaining your consent and until it is revoked.
Personal data that are no longer necessary are safely destroyed or anonymized. We restrict access to your personal data to those employees under a need to know basis.
11.SECURITY OF YOUR PERSONAL DATA
We have implemented reasonable and appropriate organizational and technical measures to protect your personal data we process, and in particular any special categories of personal data. We follow international standards 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. It is obvious that part of the security measures is not subject to public disclosure. For example, the following security measures have been implemented to protect personal data against unauthorized use or any other form of unauthorized processing:
- Our facilities are secure from unauthorized access to the possible extent implementing reasonable measures.
- Access to the personal data is restricted to a limited number of authorized employees, on the basis of secure credentials, and the necessary data transfer or transmission is carried out through secure procedures.
- Our employees are bound to confidentiality agreements, with limited access under a need to know basis. They are also provided with the appropriate training in order to handle personal data promptly and in accordance with the laws
- Special categories of personal data in physical form are locked and accessible by the minimum number of authorized employees.
- We choose trusted collaborators who are committed to their respective data protection obligations in writing. We reserve the right to audit them as provided by the Regulation.
- In our ICT systems used for the processing of personal data, all technical measures are implemented to ensure confidentiality, integrity and availability of the data.
Access to such ICT systems is monitored on a permanent basis to detect and prevent illegal use at an early stage. Although the web based transfer of data cannot be guaranteed (e.g. by cyberattacks), we work to maintain physical, electronic and procedural security measures to protect your data.
12.RECIPIENTS OF PERSONAL DATA
We in D.A. STROMAN LIMITED minimize the categories of recipients to the minimum possible provided that the legality of such disclosure is fully justified.
Part of the personal data we process may be accessed or disclosed by:
- Any supervisory or persecutory authority within its role.
- Any public or judicial authority where required by law or judicial decision.
- Company’s auditor and legal advisor only for the required amount of personal data under a duty of confidentiality.
- If products transfer carrier is been involved, only for the information required for the delivery.
- The insurance company for insurance related data.
- Banks we cooperate with and only for payment related data.
- The trainer, external consultants and training collaborators only for the necessary part of the data.
- ICT administrators, subject to confidentiality clause in non-disclosure agreements.
The personal data we collect and process is not transmitted to third countries or international organizations.
13.AREA OF PROCESSING
The personal data we collect is processed within the European Economic Zone (EEZ).
14.YOUR RIGHTS AS A DATA SUBJECT AND EXERCISING SUCH RIGHTS
You have the right to be informed, 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 – forms we are using.
We inform you that we are not using software of decision making solely based on automated processing including profiling.
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
• have to be erased for compliance with a legal obligation we are subject to
• 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 opposes 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.
Our company, in the event that you make such request in a written or electronic form regarding any of the above rights, 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 (Article 12.3).
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. Before such complaint, you may contact us if you wise so we can provide you with complete information and support.
In the event of a breach of the security (confidentiality and integrity) of the personal data processed, we will take the following measures (in accordance with Article 33 and 34 of the Regulation) 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.
16.LINKS WITH OTHER SITES
17.COMMUNICATION WITH THE NATIONAL AUTHORITY ON THE PROTECTION OF PERSONAL DATA
If you wish to contact with the Supervisory Authority, the contact details are: Jason 1 str., 1082 Nicosia, CYPRUS, telephone +357.22818456, e-mail: email@example.com.
Additional information and the Regulation in European languages can be found on the website https://eur-lex.europa.eu/eli/reg/2016/679/oj.
18.UPDATE OF THE PRESENT POLICY
This policy is effective from September 04, 2020 and will be reviewed when there is a significant change. This review will be available on the same website. Printed form of this policy is available at our offices or it may be sent to you upon request.
19.CONTACTING WITH US
For any questions or other issue regarding the processing of your personal data and the exercise of your rights mentioned above, you may contact us: 10 Bogaziou str, Dhali Industrial area, Nicosia, tel: +357.22486898, fax: +357 22486910 e-mail: firstname.lastname@example.org