GENERAL Werty Ltd
is the controller and responsible for your personal data. In the following document, Werty Ltd
will be referred to as “We”, “Our”, “Us”.
This website is not intended for children and we do not knowingly collect data relating to children.
Email address: firstname.lastname@example.org
Postal address: 81/3 Vasileos Georgiou A, 4047 Limassol, Cyprus
Telephone number: (+357) 99 661666 THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified.
We collect, use and store personal data from you when you register on our site, place a booking order (online on our website or locally), subscribe to our newsletter or fill out a form. You may, however, visit our site anonymously.
The information we collect and/or will ask you to provide, as appropriate, is: • Identity Data
: includes ID/Passport information, driving license information, full name, username or similar identifier, nationality, date of birth and gender. • Contact Data
: includes home address, local address, email address and telephone numbers. • Financial Data
: includes bank account and/or PayPal account and/or payment card details. • Transaction Data
: includes details about payments to and from you and other details of products or services you have purchased from us. • Technical Data
: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. • Profile Data
: includes your username and password, orders or requests for services made by you, preferences and feedback. • Usage Data
: includes information about how you use our website, products and services. • Marketing and Communications Data
: includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data
We do not collect any Special Categories of Personal Data
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 do we collect any information about criminal convictions and offences. IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
||Type of data
||Lawful basis for processing including basis of legitimate interest
|To register you as a new customer.
|Performance of a contract with you
|To process and deliver your order/request including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us.
||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
||(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
||(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer a contest, promotion, survey or other site feature.
||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
||(a) Identity (b) Contact
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
|To deliver relevant website content, to send you updates pertaining to your order, occasional company news, updates, related product or service information, etc. and measure or understand the effectiveness of the content we deliver.
||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
||(a) Technical (b) Usage
||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you and to personalize your experience.
||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
||Necessary for our legitimate interests (to develop our products/services and grow our business)
We may use the email address you provide for order processing to send you information, promotional material and updates about our company. Note that at any time you may unsubscribe from receiving such emails from us. We include detailed instructions as to how you can unsubscribe at the bottom of each email. COOKIES
Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
Cookies enable us to customise our website and offerings to your needs and provide you with a better online experience. In addition, cookies are used to measure usage of various pages on our website to help us make our information more pertinent to your needs and easy for you to access.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies. GOOGLE ANALYTICS
(https://policies.google.com/privacy) disabling cookies on your browser. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. HOW WE PROTECT YOUR INFORMATION
We implement a variety of security measures to maintain the safety of your personal information when you place an order, request a service or quote, submit or access your personal information.
We offer the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. HOW LONG WE KEEP YOUR INFORMATION
Your information will be kept only for as long as required to fulfil the purposes for which it was collected. Your basic personal data (name, address, contact details) will be kept as long as required under Cyprus tax law after which time it will be destroyed. Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. YOUR RIGHTS
You have the right to: •
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. •
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. •
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where 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. •
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. •
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you feel that your personal data has not been handled appropriately according to the law, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection
, which may be contacted at:
Tel: +357 22818456
Fax: +357 22304565
We would however, appreciate the chance to deal with your concerns before you approach the Commissioner so please contact us in the first instance.
We also note that you will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Furthermore, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. DISCLOSURES OF YOUR PERSONAL DATA
We do not disclose, sell, trade, or otherwise transfer to third parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also disclose your information when we believe disclosure is required to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.
Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. THIRD PARTY LINKS
Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites. YOUR CONSENT
means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.