PERSONAL DATA PROTECTION POLICY

The protection of personal data is very important to our Company. We ensure full compliance with Law 125(I)/2018, as applicable, and any law in force or which will enter into force in the future regarding the protection of personal data, as well as the EU Regulation No 679/2016 “on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repealing Directive 95/46/EC”, and we process Personal Data in accordance with the applicable fundamental principles.

This personal data protection policy (the“Protection Policy”) – together with the Terms of Use – explains how we use your personal data (i) when you register or visit our website, http://www.polisintech.com or (ii) when you contact or request information from us.

HEAD OFFICE AND SCOPE OF WORK

 The Company is located at Poseidonos 1, LEDRA BUSINESS CENTRE, Egkomi, 2064 Nicosia – Cyprus, and deals with costume software development.

LAWFUL PROCESSING OF PERSONAL DATA

 Our Company, complying with the provisions of the relevant EU and national law, handles Personal Data, which are disclosed to us, with the utmost care and consideration, thus ensuring their security and confidentiality. In order to ensure the secrecy and security of Personal Data, the Company has taken all necessary organisational and technical measures by establishing internal security policies,

using available electronic means and by informing and providing appropriate training to its employees.

The Company processes Personal Data in a lawful manner as it exclusively collects and processes data for specified, explicit and legitimate purposes and only to the extent necessary for the realisation of these purposes. The Company ensures that the data held are accurate and kept up to date, seeking for this purpose the assistance of the data subjects, that is the natural persons the personal data belong to, and retains these data for as long as is necessary for the realisation of specific purposes.

PERSONAL DATA PROCESSED

 The Company collects and processes Personal Data, that is information pertaining to a natural person who is identified or could be identified through this information, independently of whether this identification might occur directly or indirectly. The processing of these data is any work conducted related to these data whether it by automated means or not.

The Personal Data include, for example, details such as

• Full name
• Email address
• Telephone number

The above details are only requested when a visitor communicates with the Company through our general or specialised forms of communication which may be found on our website.

Additionally, during a visit at our website further data are collected for technical purposes such as:

• IP address (Internet Protocol Address) of the computer used to access the website
• Website through which you visit us (recommendation)
• Which of our websites you are visiting
• duration of visit to the website
• date and time of visit
• type of browser and browser settings
• operating system
• device
• Geographic location of visit
• Internet Provider

This technical information may in some isolated cases constitute personal data. As a general rule, we us technical details only to the extent that is necessary for technical purposes for the operation and protection of our website and application, against attacks and malicious use as well pseudonymous or anonymous form for statistical purposes.

Newsletter

 As far as more particular purposes for the processing of Personal Data are concerned, such as informing clients regarding products and services, promotional activities, offers, and events, the Company collects and processes email addresses via a specific form which may found on the homepage of our website and which the visitor may complete optionally if they wish to be informed about all the above.

PERSONAL DATA USAGE

 The Company collects and uses your Personal Data mainly when you visit the company website. The processing of Personal Data takes place, depending on each case, according to the applicable legislation and this policy or according to the consent provided by you. In certain cases, the data is used only in a pseudonymous or anonymous form.

Τhe Company stores and uses your Personal Data when you communicate with us via telephone, email or through the communication form or when you wish to send us information in a different way and therefore you transmit your data to us for this purpose. Additionally, we store and use personal data and technical information to the extent that is necessary for the prevention and protection against malicious use or other illegal behaviour on our website e.g. the protection of data in case of attacks against our information systems. Finally, we store and use your data if we are legally obligated to do so as, for example, in the case of an official directive or a decision of the court or the Authorities as well as for the safeguarding of our rights and demands and for the purpose of defending our company before a court.

THIRD PARTIES TO WHOM PERSONAL DATA WILL BE TRANSMITTED

 The Company is likely to transmit these data to companies, within the European Union, it is collaborating with, which will process these data on behalf of the Company as processors and solely for the purposes set forth above. During data transmission the Company shall take all necessary measures in order to ensure the highest possible level of security

Τhe Company is committed to ensuring that these companies provide the necessary guarantees for the protection of Personal Data and that they shall take the technical and organisational measures necessary to ensure that the processing is lawful and to safeguard the protection of Personal Data and the rights of the relevant natural persons. The Company declares that it has signed agreements with these companies, in advance, which include conditions related to taking and monitoring safety measures by the Company.

PERSONAL DATA SECURITY

 Personal Data security is of high priority for the Company. Therefore, we protect your personal data, which is stored by us, through technical and organisational measures for the effective prevention of loss or misuse by third parties. In particular, the employees processing personal data are bound by secrecy and confidentiality. For the protection of your personal data, the data you send through the website are transmitted in encrypted mode. In order to ensure the long-term protection of your data, technical security measures are regularly monitored and, if deemed necessary, they are adjusted according to the corresponding prevailing technology standards.

COOKIE POLICY

 The use of cookies is regulated by the relevant Cookie Policy while the same level of security is employed to protect the personal data collected in this way as the one used for all the other personal data.

CONSENT AND RIGHTS OF PERSONAL DATA SUBJECT

 By choosing to agree and consent to the processing of the Personal Data concerning you, you consent to the processing of the data for the abovementioned particular purposes, either by the Company or by a partner company. You may at any time revoke your consent and exercise one of your legal rights, namely accessing and obtaining a copy of your data, rectifying inaccurate information, deleting your data or restricting their processing, portability of data into structured, commonly used and machine-readable format and forwarding it to another controller, objecting to a decision made solely on the basis of automated processing, including profile compilation, which produces legal results which concern you or substantially affect you in a similar way.

The Company handles your requests with due diligence to ensure the security of your data and the protection of your rights. Therefore, in case of doubt as to the person requesting the disclosure of the data, we may request additional information necessary to verify your identity.

In case the Company, is unable to satisfy your request promptly due to the fact that there may be a large number of such requests, it will inform you as soon as possible, and in any event within one month of the date on which your request was made, about its progress and the reason for any delay in granting it. If your claims are manifestly unfounded or excessive, especially because of their repeated nature, the Company may either charge a reasonable fee, taking into account administrative costs, to provide information, to communicate or execute the action requested or refuse to respond to the request.

In the event of a data breach and where such breach is likely to result in a high risk to your rights and freedoms and provided that it does not fall within one of the exceptions expressly provided by law, the Company undertakes the responsibility to communicate the personal data breach to you without undue delay.

You may contact the Company at any time regarding all your enquiries or claims pertaining to the protection of your personal data that are kept by the Company at the following email address: info@polisintech.com

In the event that you believe your data security has been breached in any way you have the right to lodge a complaint with the Commissioner for Personal Data Protection using the following contact details:

Website : www.dataprotection.gov.cy, Postal address: 1 Iasonos Street, 1082 Nicosia, Tel: 22818456,  Fax:  22304565, E-mail: commissioner@dataprotection.gov.cy

MODIFICATIONS TO THIS PRIVACY POLICY INFORMATION

 Any relevant future regulation will be the subject of this communication. In any event, the Company reserves the right to change the terms and conditions of the Personal Data in accordance with the applicable legal framework.

Consequently, these Privacy Policy terms may be revised and updated at any time without notice. Users of the website are kindly requested to periodically review these terms for any changes, as the continued use of the Website implies that they accept all possible modifications thereto.

The current version of the Personal Data Protection Policy entered into force in April 2020.