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Privacy Policy

Last updated: 24th June 2021

We respect your privacy and we are committed to protecting your personal data. This Privacy Policy and notice is addressed to actual and prospective customers, including visitors to our website. It serves the purpose of informing you of what personal data we collect and for which purposes, how we process it and on what legal bases we ground such processing, as well as give you information about your privacy rights and how you can exercise them.

The personal data we collect

Due to the nature of our services and pursuant to adhering to the data minimization principle, we limit collection of personal data to the minimum.

We collect personal data at the time that an account is created with us for the use of our service(s), as well as during the rendering of our service(s); specifically:

If we combine personal data with non-personal information about you, the combined information will be treated as personal data for as long as it remains combined. We do not collect or retain personal data belonging to special categories.

Purposes & Legal basis for processing

Processing personal data is ancillary to our core activities as a digital strategy design and implementation business; we do not collect or process either more or less data than what is reasonably required for achieving the purposes outlined below, for which the corresponding legal bases for processing is also set out:

  1. We collect your full name and e-mail address to create an account for you and consequently to enter into an agreement with you, as well as to renew or manage your subscription(s). The legal bases for such processing are the following:

    • Contract Performance: Primarily to enable us to perform our contract for the provision of our services to you.

    • Consent: This Privacy Policy is brought to your attention when accepting our Terms & Conditions in order to enter into a contract with us and in such instances as you may be prompted from time to time whilst using our services. By using our services, you agree to the collection and processing of your personal data on the basis of this Privacy Policy and consequently consent is granted to such processing. Consent includes the processing of personal data on an online but secure platform/database. It may be withdrawn at any time by e-mail at the e-mail address provided below, at the end of this Policy.

    • Legitimate Interest: We have a legitimate interest in knowing your full name and e-mail address to identify you and contact you as our client, respectively. Lastly, we have a legal obligation to collect such personal data for the purpose of accounting and tax purposes, as well as for compliance with legal obligations pertaining to the foregoing or other applicable legal obligations.

  2. We collect and process the personal data provided in the preceding section of this policy for the purpose of providing our services to you, including personalized experience and delivery of the type of content, services, and features in which you are most interested. We base such processing on Consent, Contract Performance, Legitimate Interest, and compliance with a Legal Obligation as provided in (a) above.

  3. We process your personal data and other information provided above in order to respond to any questions, suggestions, comments or concerns, as well as provid the technical support you need. The legal bases for such processing is Contract Performance, Consent, and the existence of a Legitimate Interest in providing tailor-made, prompt, and full service to you in our capacity as service providers, taking into consideration that due to the non-sensitive nature of the data and information collected and processed, no personal rights or freedoms are interfered with, whereas such processing is necessary to achieve the said legitimate interests.

  4. We invite you to participate in surveys and analyze both your responses to such surveys and your usage of our services, to determine the effectiveness of the services we offer, improve our platform, and develop new services. We base such processing on Consent, whether requesting it prior to such prompts, during our interaction through the provision of our services or at the time of entering into an agreement by accepting the terms of this Policy or giving consent to processing on the basis of this ground. Furthermore, we have a Legitimate Interest in such processing for the reasons mentioned in (c) above.

  5. We may also process your full name and e-mail to communicate with you and notify you of product updates, new features, or other users’ activity, based on your permission level or upon your Consent.

  6. We cause the encryption and storage of your personal data in secure cloud servers provided by third parties within or outside the EU where data is encrypted and we base such processing on Consent, Contract Performance, Legitimate Interest and compliance with a Legal Obligation as provided in the preceding paragraphs.

  7. If necessary, your personal data may also be processed by our accountants and auditors for accounting and tax purposes, by our lawyers for legal advisory and legal representation purposes, our bankers for banking and regulatory compliance, as well as our IT consultants or partners for maintenance and support purposes. The legal bases for such processing is Consent, compliance with a Legal Obligation (preparing of accounting records, AML compliance and adherence to tax laws and tax authorities‚ requests), Legitimate Interest in the effective and lawful administration and management of both, our business and contractual relationship with you, as well as taking legal, tax, and commercial professional advice on any aspect of the provision of our services, if and when necessary. We may also disclose your personal information when ordered by any Court or any other Authority having control or jurisdiction over us.
  8. We may disclose any information in case we believe, in good faith, that such disclosure is necessary in order to take precautions against any liability, investigate and safeguard against any claims or allegations, protect the security or integrity of the site and our servers, and protect or defend the rights and the property of Stronde CY LTD and any other company within the Stronde Group, since we believe we have a Legitimate Interest to protect our business, reputation and property.

We do not collect or retain payment details; payments made to us are executed through third parties and payment service providers.

Retention of personal data

We retain personal data during the provision of our services and the validity of our agreement, and thereafter for as long as necessary to comply with our legal and tax obligations, defend possible future legal claims and in accordance with relevant industry standards, always taking into consideration the applicable limitation period and the legislative provisions for the period of retrospective tax inspection for which we may be required to provide clarifications, proof and documents to the tax authorities. The type of information which is collected and the purpose for which it is collected is also taken into consideration in this process. Upon the lapse of the abovementioned periods, we remove and delete such data from our systems.

We review our retention of personal data annually.

Storing and protecting your data

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal data. Your information is stored on secure cloud servers and it is not publicly available. Access to such information is restricted only to those employees that need it to enable the performance of our agreement, ensure compliance with legal obligations, and perform such processing, for which your consent is obtained as provided in this Policy. All electronic transactions entered via our services will be protected by Secure Socket Layer (SSL) encryption technology.

Recipients and transfers of data

We will receive data from you directly, or from our associates within or outside the Stronde Group, including Stronde Limited, reg. No. 09839681, incorporated in the UK, to whom you may provide such data. When received, such data may be processed by our directors and employees, who have signed our Confidentiality Agreement; access to your data within the Stronde Group is only allowed to those who need it. Others may have access to your personal data where disclosure is deemed necessary and provided that such processing falls within the available legal basis for processing set out above. Data may also be transferred abroad to Stronde Limited, UK if this is necessary or related to the performance of our contract with you.

Some data recipients may be located outside the EU. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Your rights

Under the EU General Data Protection Regulation − GDPR, you have the right to:

You can exercise all and any of the aforesaid rights by sending us an e-mail using the contact details at the end of this Privacy Policy.

In the event that you filed a complaint with us and you feel that you want to take it further, you can contact the supervisory authority regarding personal data in Cyprus, which is the Office of the Commissioner for Personal Data Protection at 1, Iasonos Street, 1082 Nicosia, P.O. Box 23378, 1682 Nicosia, tel.: +357 22 818456, e-mail: commissioner@dataprotection.gov.cy.

Incidence Response Plan

Albeit taking all actions necessary to ensure that all personal data are securely and safely collected, stored, and processed, we are prepared to manage the unfortunate, yet distant, scenario of a possible data breach, in accordance with applicable laws, pursuant to an Incidence Response Plan which is available on request.

Cookies

Cookies are small pieces of text that a web server places on your computer or mobile device when you visit a webpage. A cookie file is stored in your web browser and allows the service or a third party to recognize you, make your next visit easier, and the service more useful to you.

For more information on this, please visit our Cookie Policy page.

Communication

We may contact you by email with information about our services. If you do not want to receive marketing emails, you can unsubscribe from emails by either clicking the link at the bottom of the emails we send you or informing us that you no longer want to receive marketing communications by sending us an email at product@stronde.com.

Please note that you may not opt-out from receiving transactional emails.

Changes to our Privacy Policy

We may update this Privacy Policy on our website to reflect our service changes and improvements (as we are continuously adding new features or make improvements based on customers’ suggestions), satisfy legal requirements or for other reasons as we deem necessary.

When we do so, we will upload our updated Privacy Policy on our website. Hence, please visit the Privacy Policy section of our website regularly. If you disagree with our Privacy Policy, you may close your account at any time. By continuing to access or use our services after any revisions become effective, you agree to be bound by the Privacy Policy, as updated.

Contact information

For any questions, comments, or concerns about this Privacy Policy, or if you wish to exercise any of your aforementioned rights, you can contact us by email at privacy@stronde.com or by post at 3, Angelou Terzaki Street, 6037, Larnaca, Cyprus, Stronde CY LTD, HE 403788.

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