This Privacy Policy aims to inform you as to how “SLOA LTD” (hereinafter referred to as “Company”, “we”, “us” and “our”) collects and processes information about you and in particular, your personal data. We also intent with this document to inform you about the retention of personal data, the measures to secure such data and in general to provide you any necessary information in line with the General Data Protection Regulation (GDPR). We hereby assure you that this Policy, fully respects and complies with the EU Regulation 679/2016 (GDPR) and the relevant Law 125 / I / 2018 of the Republic of Cyprus (referred hereinafter as applicable personal data framework).

 

Useful Definitions

Personal Data is 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, address and other contact details, information regarding working experience, position, etc., 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 is 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 is 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 is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

Processing is 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 is 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.

 

The Controller

In cases where we, as a company, determine the purposes and means of the processing, the Controller is the legal person: SLOA LTD, address 9 Androkleous str., 1061 Nicosia, Cyprus, telephone +357 22051338, e-mail: [email protected].

 

Principles we adhere to

At SLOA LTD, we are committed to and adhering to the following principles of processing personal data in accordance with Article 5 of the applicable personal data framework. The personal data is:

• 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 it is processed (principle of ‘data minimisation’);
• accurate and, where necessary, kept up to date; in SLOA LTD we take every reasonable step to ensure that inaccurate personal data, having regard to the purposes for which it is processed, are erased or rectified without undue delay as soon as we are properly informed (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 and applicable Legal Framework (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 Personal Data directly from you in the following cases:

• When you contact us in person or by phone or through our webpage or by mail or email, or through our professional partners, or through our Social Media accounts, in order to be informed regarding our services or ask relevant information;
• If you receive our services, if you cooperate with us, or if you are involved in events related to the offer of our services;
• If you fill in any of our documents or subscribe to our newsletter;
• When you are connected to our website;
• 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 entities, disclose to us if we act as Processors on their behalf or when your personal data is disclosed to us by third parties under contracts or agreements.

 

Minors’ Personal Data

We do not collect and/or 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 without physical presence.

 

Personal Data we may process about you

Data from the following categories of personal information about you, may be collected and processed per case (i.e., this means not all of them but depending on the purpose of the processing) in order to serve the purpose of the processing and in accordance with the relevant legal basis as described in this Policy:

• Contact or identification details with you or a natural person you may indicate instead of you (name, surname, address, telephone or fax number, email), language and field of interest;
• Occupational information (occupation, position, organisation’s name);
• Information related to terms of agreements such us necessary information of the aforementioned, purpose of cooperation, identification card or passport number, terms and amounts, signatures;
• Elements that you include in the case of incoming mail or email;
• Details or curriculum vitae of presenters of informative or educational activities, name and contact details of participants, photos of the event under consent;
• In cases of European projects, and in the case of development and submission of co-financed projects on your behalf, names of the participants and those involved, their contact details, CVs of project team members with the usual details included in CVs, terms, amounts, times of work (anticipated or actual), role in the project, details of participants during dissemination activities or any other details required by the competent Authority;
• Payment and transaction details (IBAN, account number, tax number, desired payment method, terms of payment);
• Incident investigation data, such as incident details, data of persons involved or related information;
• Client history (transaction details, claims, problems, terms, satisfaction when you answer questionnaires) and information related to assessing persons and situations;
• Apps / websites / social media related data (cookies, full name or nickname, information you publicly disclose and comments on social media, or email attachments);
• Information referred in your Curriculum Vitae and information related to studies, competencies or previous working experience if you disclose this information to us as candidates of employment.

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 & Legal Bases

The processing of personal data performed by us as the Controller, is based on one of the “legal bases” referred 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, your consent (Article 6.1.a), the performance of a contract to which you are party or information required prior to entering into a contract (6.1.b), the compliance with our legal and statutory obligations (6.1.c), and the safeguarding our legitimate interests (6.1.f). It is rarely happening to use the legal base 6.1.d. In the case of special categories of personal data, processing by us is based on your explicit consent (9.2.a) or the processing relates to personal data which are manifestly made public by you (9.2.e).

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 interested in our services or requesting information, when you are interested in working or cooperate with us, when you fill in our documents or mail or email information to us, when you agree to inform you about our services, when you make a complaint or statement or when assessing us, when you participate in our events, when you expressly and freely agree in relation to receiving audio-visual material, when you visit our social media accounts, when you are connected to our wireless network, when you give us your business card.

Performance of a contract: when you have agreed to receive our services, when you are our employee or cooperating partner, 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 Personal Data

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 the performance of a contract and the fulfilment of our legal obligations (Article 6.1.b or 6.1.c), shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework or when the reason of retention ceases.

Personal Data included in offers that does not lead to a cooperation is kept for 12 months.

The content of proposals including your personal data shall be retained as long as necessary by the legal framework and the relevant guidelines of EU auditing authorities, both in cases where the project is approved or not approved.

Personal data you disclose to us as candidates are retained for 12 months.

Data that may be necessary for our legitimate interests as the Controller shall be kept until the reason for storing such data ceases.

Specifically, the data we process based on your consent shall be retained 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 or project partners who need to use it, for the specific purposes.

 

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. 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 in accordance with the purposes and the 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 the 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 and only to the necessary personal data.
• 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 available technical measures are received to prevent loss, unauthorised access or other illegal processing. In addition, access to these ICT systems is monitored in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet 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 receive measures to ensure that the recipients of personal data are kept to a minimum. In the internal environment personal data are processed by authorised employees. The personal data we collect is disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully collect and process as the Controller, may be accessed (or disclosed) on a case-by-case basis by:

• Any relating supervisory authority within their role;
• Any public or judicial authority where required by law or judicial decision.
• The accountant and the auditor of the company, and only regarding necessary data (financial, employment, contracts and similar data), under confidentiality.
• The advocate, for whatever data is required in legal cases, under confidentiality.
• The Insurance cooperating company and only for the relevant part of the information.
• Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
• The training or systems’ consultants, and our partners in projects under the proper agreements.

We do not allow third party service providers to use your personal data for their own purposes. We only allow your personal data to be processed for specified purposes and in accordance with our own instructions included in agreements. These third parties have contractually committed to our company that they will use the personal data only for the above specific reasons per third party, will not transmit the personal information to other third parties, and that they will not share it with third parties unless it is required by Law or Court decision.

 

Territorial Scope

The personal data we collect is processed within the European Economic Area (EEA). We do not transfer your personal data in third countries nor to international organisations.

 

 Your rights as the Data Subject and how you can exercise these rights

You have

• the right to be informed,
• the right to consent when this is the legal basis for the processing,
• the right of access to your personal data,
• the right of rectification,
• the right of erasure under specific circumstances,
• the right to restriction of processing,
• the right to data portability,
• the right not to be subject of automated decision making and profiling,
• the right to object.

Your right to consent is granted by design and by default in every case where it is required. SLOA LTD has designed and maintains consent forms when required. 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 in documents – forms we are using.

The use of personal data by an electronic system in order to make a decision without human intervention constitutes automated decision making. SLOA LTD, does not use means of automated decision-making, nor does it carry out profiling.

Right of access: you have the right to obtain from us confirmation as to whether or not your personal data is 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 is 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 has been unlawfully processed;
• your personal data has to be erased for compliance with a legal obligation we are subject to;
• your personal data has 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 to 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 it is 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 personal data, which you have provided us, in a structured, commonly used and machine-readable format and you have the right to request us to transmit those data to another controller or you, where:

6. the processing is based on consent as per Article 6.1.a, or Article 9.2.a, or when the processing is based on a contract pursuant to Article 6.1.b; and
7. the processing is carried out by automated means.

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 are valid in cases when we are the Controller. If we have the role of Processor, your request has to be directed to the Controller.

In the event that you make such request regarding any of the aforementioned rights in a proven way and after the necessary identification, 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 to 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.

Communication languages regarding the exercise of your rights are Greek and English.

 

Personal Data Breach

In the event of a breach of the security and integrity of the personal data processed, we will take the following measures (in accordance with Article 33 and 34 of the Regulation in the case we are the Controller) and we will:

• Investigate to assess if it is really a breach;
• Assess the situation, in order to implement the appropriate procedures required to limit the impact of 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

Our website may contain links to other websites that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third-party site. We recommend that you review the Privacy Policy for each site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

 

Contact details with the National Data Protection Authority

Cyprus Personal Data Protection Authority, kypranoros 15, Nicosia 1061 , Cyprus, telephone +357.22818456, e-mail: [email protected].

Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=celex%3A32016R0679.

 

Contact us

If at any time you want to contact us or make a request regarding your rights or any other matter relating to the protection of personal data you may contact us:  SLOA LTD, address 9 Androkleous str., 1061 Nicosia, Cyprus, telephone +357 22051338, email: [email protected].

 

Policy Update

This policy is effective from May 25th, 2018 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. Last update: February 12th 2024.