We have used the following terms in this Policy
‘Data Controller’ means the person or organization which determines when, why and how to process Personal Data and implements appropriate technical and organizational measures to comply with the Law;
‘Data Processor’ means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller;
‘Data Protection Officer’ means the person who is formally appointed with the purpose of ensuring that we are aware of and comply with our data protection responsibilities and obligations according to the Law;
‘Data Subject’ means a living, identified or identifiable natural person about whom we hold Personal Data;
‘European Economic Area’ (EEA): means the EU countries and also Iceland, Liechtenstein and Norway;
‘Personal data’ means data about the Data Subject who can be identified:
a) from that data; or
b) from that data and other information to which we have or are likely to have access.
The Personal Data we may collect and use includes, without limitation, names and identification information such as email address, telephone numbers, passport numbers.
‘Processing’ means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘Special Categories of Personal Data’ means the information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data;
‘the Law’ means the General Data Protection Regulation (2016/679) (GDPR) and the Data Protection Laws of the Republic of Cyprus.
Why do we collect your Personal Data?
We collect and use Personal Data that enable us to provide our outsourced debt recovery services to our clients. This includes collecting and using of the Personal Data of the debtor and the debtor’s representatives for tracing purposes.
Transferring your Personal Data outside EEA
We generally do not transfer Personal Data to countries outside of EEA, except where transfers of Personal Data are required by the purposes set out in this Policy (i.e. debts outside the EEA or if we are engaged by a non-EEA client). If we need to transfer Personal Data outside the EEA, we will take all steps required to ensure that Personal Data continues to receive our standards of protection.
How long will we store your Personal Data?
We will store your Personal Data for the duration of the debt recovery service agreement with our client. We will delete your Personal Data upon cessation of their instructions to us (except where retention is required by the Law and/or other applicable laws of the Republic of Cyprus).
What are your rights in relation to your Personal Data?
Right to access (commonly known as a "data subject access request") - You have the right to request a copy of the Personal Data we hold about you at any time;
Right to rectification - You have the right to ask us to correct any inaccurate Personal Data we hold about you;
Right to erasure – You have the right to ask us to delete your Personal Data from our records (Please note that we will not be able to delete you Personal Data whilst we are still providing our debt recovery services to our clients. We will be able to delete your Personal Data once our debt recovery services are completed.).
Right to restrict processing - You have the right to ask us to restrict the use of your Personal Data;
Right to object - You have the right to object to the collection and use of your Personal Data;
Right to data portability - You have the right to request the transfer of your Personal Data to another party;
Right to lodge a complaint - You have the right to lodge a complaint about the use of your Personal Data directly with us by contacting our Data Protection Officer on one of the contact details below or directly with the Office of the Commissioner for Personal Data Protection in Cyprus.
How can you exercise your rights in relation to your Personal Data?
You can exercise all of your rights by contacting our Data Protection Officer on any of the contact details below:
A: 12 Kennedy Avenue, 2nd Floor | 1087, Nicosia, Cyprus | P.O. BOX: 24293, 1703, Nicosia, Cyprus
E: Data Protection Officer at email@example.com
How do we protect your Personal Data?
To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying or similar risks, we have introduced appropriate administrative, physical and technical measures such as up to date antivirus protection, encryption and the use of privacy filters to secure the storage, disclosure and transmission of Personal Data.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guarantee, we try to protect the security of the Personal Data by constantly reviewing and enhancing our information security measures.
Changes to this Policy
We may revise this Policy from time to time without any prior notice. Therefore, it is important to consult this page from time to time.
What are Cookies
You are advised that if you do not consent to the use and saving of cookies from this website on to your computer hard drive then you should take necessary steps within your web browser security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored on your computer hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. It should be noted that no personal information is stored, saved or collected.
Types of Cookies
The types of cookies used on this website can be classified into one of three categories:
Strictly Necessary Cookies: These are essential in order to enable you to use certain features of the website, such as submitting forms on the website.
Functionality Cookies: These are used to allow the website to remember choices you make (such as your language) and provide enhanced features to improve your web experience.
Analytical / Navigation Cookies: These cookies enable the site to function correctly and are used to gather information about how visitors use the site. This information is used to compile reports and help us to improve the site. Cookies gather information in anonymous form, including the number of visitors to the site, where visitors came from and the pages they viewed.
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser’s “Help” option on how to do this). Be aware that disabling cookies may affect the functionality of this and many other websites that you visit. Therefore, it is recommended that you do not disable cookies.
Security and Data Storage
We will treat all of your information in strict confidence and we will endeavor to take all reasonable steps to keep your personal information secure once it has been transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, and data stored on the website and associated database.
Please note that the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the Internet and will not hold us liable for any data breach.
Learn more about Analytics cookies and privacy information.
Use of IP Addresses. An IP address is a numeric code that identifies your computer on the Internet. We might use your IP address and browser type to help analyze usage patterns and diagnose problems on this website and to improve the service we offer to you. But without additional information your IP address does not identify you as an individual.
Hopefully the above information has clarified things for you. As it was previously mentioned, if you are not sure whether you want to allow the cookies or not, it is usually safer to leave cookies enabled in case it interacts with one of the features you use on our site. However, if you are still looking for more information, then feel free to contact us via email, at firstname.lastname@example.org