Privacy Policy

Last updated on 31 July 2018


At Mitsides Public Company Ltd we are committed to the protection of your privacy and the security of your personal data. References in this Privacy Policy to “we”, “us”, “our” and “Mitsides” are references to Mitsides Public Company Ltd
We respect your privacy and are committed to the protection of your personal data. Personal data (referred to as ‘‘Data’’ or “Personal Data”) is information that directly or indirectly identifies and relates to you or other individuals.
This Privacy Policy explains the type of Data that we collect and how we collect, transfer, process, use and disclose your Personal Data as well as the security practices that we apply in order to protect your Personal Data.  Additionally, it contains information about third parties receiving your Data as well as your rights under local applicable data protection laws and the EU General Data Protection Regulation.
Please note that this Privacy Policy applies to:

  • Our prospective and current clients
  • Job applicants and interns (both full time and part time)
  • Suppliers and other associates and partners
  • Visitors to our website
  1. Who is responsible for your Personal Data

Mitsides Public Company Ltd, is a public company, incorporated under the laws of the Republic of Cyprus, with registered office at 34 -38 Nikiforos Fokas Avenue 1016 Nicosia, Cyprus. For more information please visit the General Information section of our website.

  1. What we collect and how we obtain it

We collect and process your Personal Data in the course of our business, when you contact or request information from us, through the CCTV systems located in our premises, and when we provide our services to you. For more information regarding our services please visit the General Information section of our website.
We may collect and process the following categories personal data:
•    Contact details, including name and surname, address, telephone number and email
•    Identification information, including date of birth, passport number, ID number, and other information relevant to your identification
•    Financial information, including bank account numbers, credit/debit card numbers, and other financial information required for receiving payments and fraud prevention
•    Business related information, information provided to us in the course of our contractual or client relationship with you and/or your organisation
•    Technical information, including information collected during your visits to our website, the Internet Protocol (IP) address, browser version and type, device type, time zone setting, browser plug-in versions and types, operating system and platform
•    Recruitment related information, including curricula vitae, educational or professional background, job title, employment history and other information relevant to potential recruitment
•    Any other categories of personal data you may provide to us in the course of our relationship 

  1. Personal Data of other individuals

In case you provide us with Personal Data relating to other individuals, you must ensure that the said individuals understand how their Personal Data will be used and processed by us. It is your responsibility to inform the said individuals about the content of this Privacy Policy and ensure that they have understood and accepted how we use their Personal Data.

  1. How and why do we use your Personal Data
  • Performance of a service: We may use your Personal Data to complete and administer our services.
  • Providing customer support / communicating with you: We may use your Personal Data to communicate with you for administrative or operational reasons, for example to provide customer support, to respond or handle any queries or requests, sending you a questionnaire or asking you to provide a review regarding your experience with us or send you any information we believe may be useful to you.
  • Marketing activities: We may send marketing related information in case you have indicated that you would like to receive such information, for example to notify you of our offers, new products and services. If you want to stop receiving marketing communications you can do so by clicking unsubscribe at the link included in each newsletter. 
  • Market research: We may sometimes ask you to take part in marker research, for example to seek your views on our products and services
  • For recruitment purposes: To assess your suitability for any position for which you may apply (including but not limited to internships).
  • Improving our products and services: We may use your Personal Data to improve your user experience while using our website, to improve the content of our communications, and to improve our products and services.
  • For fraud prevention and detection or any illegal or unwanted activities: for example, credit card fraud.
  • IT Security: To protect our website, online platforms, networks and software systems.
  • Physical Security: To ensure the safety of our employees and visitors at our premises and to protect our property (including but not limited to hardware and equipment).
  • Legal claims purposes: In certain cases, we may need to use your Personal Data to handle and resolve legal disputes, to enforce the terms of any contract, agreement or arrangement we have of you (including but not limited to the terms of use of our website), or to comply with lawful requests from law enforcement authorities.
  1. Legal Justifications for processing your Personal Data

In order to lawfully process the Data described above we rely on one or more of the following justifications:
Compliance with our legal and regulatory obligations: In some occasions we use Personal Data to comply with the legal and regulatory obligations we are subject to.
Initiation, establishment, exercise or defence of in court and out of court legal procedures.
Performance of a contract: The use of your Personal Data is necessary for the performance of a contract, namely to provide our services. If we do not process your Personal Data, then we will not be able to provide our services.
Legitimate business purposes: We may use your information for our legitimate interests, such as to send you emails and newsletters, to improve and promote our products and services, to improve the content of our website and to prevent fraud.
Your Consent: In cases where you have provided your consent to the collection and processing of Personal Data we will use the legal basis of consent. You may withdraw your consent at any time by contacting us at: dpo@mitsidesgroup.com

  1. How we protect your Personal Data

We take appropriate legal, organizational, and technical measures to protect your Personal Data consistent with applicable data protection laws and the EU General Data Protection Regulation.  We use a variety of security technologies and procedures to help protect your Personal Data from unauthorised access and disclosure, loss, use, or alteration. When we use a third-party service provider, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of Personal Data.  

  1. Sharing your Personal Data with third parties

We may share your Personal Data with any of the following third parties:

  • Our service providers, affiliates, contractors, business partners, agents such as IT support, couriers, consultants and any other third-party vendors assisting us in the course of the services we provide to you;
  • Financial institutions when this is required;
  • Professional advisors and auditors such as external legal advisors and accountants;
  • Courts, tribunals, arbitrators, or other judicial committees
  1. How long do we keep your Personal Data

We will only keep your Personal Data for as long as it is necessary to fulfil the purpose(s) of collection and use. We will keep your Personal Data for the purposes of complying with any legal, regulatory, accounting, reporting requirements, to provide our services and for the establishment or defence of out of court and in court legal claims.
We determine the appropriate retention period for personal data, by taking into account the volume, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use, loss or disclosure of your personal data, the purposes of processing personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

  1. What are your rights

In certain instances you may have the right to:

  • request a copy of your Personal Data held by us;
  • request the correction and/or deletion of your Personal Data, or restrict or object to the processing of your Personal Data;
  • withdraw your consent to the processing of your Personal Data at any time, where processing is based on having your consent;
  • request to obtain and reuse your Personal Data in a format that is structured and commonly used. You may also request by us to transmit such data to other organisations;
  • complain to the Office of the Commissioner for Data Protection in cases where you believe that your data protection rights are being violated.

If you would like to exercise any of the above-mentioned rights, please inform as at dpo@mitsidesgroup.com

  1. Cookies

Our website uses “cookies.” A cookie is a small text file that is placed on your hard disk by a server. Cookies allow our website to respond to you as an individual.  They enable the website owner to distinguish you from other users of the website.  The website can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Cookies cannot be executed as code or used to deliver viruses and they cannot enable us to access your hard drive. We cannot read any information on your hard drive even if we store cookies there.  
We use cookies to improve the experience for visitors to our website.  You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or receive a warning before a cookie is stored if you prefer. Please refer to your Internet browser’s instructions or help screen to learn more about these functions and to specify your cookie preferences.
If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites or any other websites that you visit. 

The data generated through cookies on the website can be used for various purposes including the following:

Strictly necessary
These cookies are essential in order to enable you to move around the website and use its features.

Analytical/ Performance
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often and if they receive error messages. This helps us improve how a website works in future versions for example by ensuring that users are finding what they are looking for easily.

Functionality
These cookies allow the website to recognize you and remember choices you make when you visit the website such as user name, language or region you are in and provide a more enhanced personal experience.   

Targeting or advertising
These cookies are used to deliver content more relevant to you and your interests by recording 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 our interests.

Please be aware that parts of our website may not function correctly if you disable cookies.

  1. Transfer of your Personal Data to a Third Country

We may transfer your Personal Data to countries not providing an adequate level of Personal Data protection. Where appropriate, we will take steps to ensure that Personal Data transferred is subject to appropriate safeguards, such as entering into Data transfer agreements. In cases where we use Data transfer agreements or similar safeguards, we may be able to supply you with a copy or a specimen of such, if you contact us at dpo@mitsidesgroup.com

  1. Links to other websites

Our website may from time to time provide links to or embed third party websites. This Privacy Policy does not apply to those websites.  If you choose to enter such a linked site, you agree that we are not responsible for the availability of such websites and do not review or endorse and shall not be liable, directly or indirectly, for:

  • how these websites treat your Personal Data
  • the content of such websites
  • the use that others make of these websites.

Please ensure you check the legal and privacy statements posted on each website you access before entering any Personal Data.

  1. Changes to this Privacy Policy

We may change, modify or update this Privacy Policy.  If the changes we make are material, we also may post a notice regarding these changes.  We encourage you to check this Privacy Policy to stay informed about how we are helping to protect the Personal Data we collect.  

  1. Contact us

If you have any questions, comments and requests regarding this Privacy Policy please contact our Data Protection Officer at: dpo@mitsidesgroup.com