TRATARO LTD (HE 361583)
Trataro Ltd is a private company limited by shares incorporated under the laws of the Republic of Cyprus, duly registered in the relevant Companies Register kept at the Department of Registrar of Companies and Official Receiver of the Republic of Cyprus with registration number HE 361583, whose registered office is at 11, Riga Feraiou str., Agios Nektarios, 3095, Limassol (hereinafter “the Company” or “we” or “us”, unless otherwise provided). Trataro Ltd takes your privacy very seriously and we ask that you read the present Privacy Statement carefully before proceeding with the submission of your personal data on the website.
The provision of your data is voluntary, however, please note that if you do not provide us with the required personal data, we may not be able to provide the information, products or services you need or process your request. You are strongly urged to read the present Privacy Statement and make sure that you agree with the contents thereof. By using the website you subscribe to the present Privacy Statement in force at all times.
Our website is not intended for children and we do not knowingly collect data relating to children.
This Privacy Statement applies to information we collect about:
- visitors to our website; and
- persons who register for our service.
Purpose of Collection of Personal Data and Intended Use
In accordance with the applicable regulatory framework we, our sub-contractors, licensees, affiliates and any third parties to whom we may communicate your information subject to the terms of the present Privacy Statement, may use your personal data solely and exclusively for the purpose for which these have been provided by you and for no other purpose, 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.
The processing of personal data that you are asked to submit on our website shall only be carried out after we have obtained your consent or because such processing is necessary for the performance of a contract to which you, in your capacity as the data subject, are a party (or are about to become a party), or in order to take measures at your request prior to entering into a contract, or in the course of pursuing a legitimate business purpose or interest on the part of the company (as set out hereinbelow), provided always that such legitimate business interest does not override your fundamental rights and interests, or where we need to comply with a legal or regulatory obligation.
Legitimate Interest 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.
The company seeks only to obtain such information as may be necessary for facilitating and procuring an optimal level of service for its Clients and users of the website.
The information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
When you register for our service we collect the following personal information from you:
- Identity Dataincludes first name, maiden name, last name, company name, username or similar identifier, marital status, title and date of birth.
- Contact Dataincludes country, street address, town/city, state, postcode, telephone number, billing address, delivery address, email address and telephone numbers.
- Financial Dataincludes bank account and payment card details, including credit card number, CVC number, Credit Card expiry date and discount coupon code.
- Transaction Dataincludes details about payments to and from you and other details of products and services you have purchased from us including order notes.
- Technical Dataincludes 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Dataincludes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
If you object to the collection and use of such personal information by us in this way, you should refrain from visiting our website. You can always stop us from collecting such information, by leaving the website.
We also collect, use and share aggregated data with our analytical systems such as statistical data or demographic data for any purpose. Such data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us to develop our website and our services. We may also provide such aggregate information to third parties. These statistics will not include information that can be used to identify you. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Statement.
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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
We may also use GPS technology and/or other relevant technologies to determine an approximation or estimation of your current location. We do not collect information from your device or from any third party in the course of calculating your estimated location, but some of our location-enabled services may require your personal data (such as your IP address) for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. By consenting to the use of this feature you authorize us and our affiliates, sub-contractors and licensees for transmission, collection, retention, maintenance, processing and use of your location data and queries to provide and improve location-based and road traffic-based products and services. You can withdraw your consent at any time by turning off the location services settings on your device.
How we will use the information about you
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.
|Purpose/Activity||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 including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(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 enable you to partake in a prize draw, competition or complete a survey
(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) 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 and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(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
|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
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We gather this information to allow us to process your registration, process any orders you may make and provide the goods or services requested, as well as to enhance your experience in the course of using the website. The relevant information is then used by us, our agents and sub-contractors to provide you with statements of your account and to communicate with you on any matter relating to the conduct of your account and the provision of the goods or services in general. If you agree, we may also contact you about other products and services we think may be of interest to you.
From time to time we may provide your information to our customer service agencies for research and analysis purposes so that we can monitor and improve the goods or services that we provide. We or our agents and sub-contractors may contact you by email at the email address that you have provided to ask you for your feedback and comments on our goods or services. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Provided that you expressly authorize us to do so, we may also provide you with information about special features of our website or any other service or products we think may be of interest to you. If, after you have authorized us to provide you with such information, you decide that you would rather not receive this information, you may revoke your consent by sending a blank email message to firstname.lastname@example.org. We may also ask for your permission to provide you with related information from third parties we think may be of interest to you. If you agree to us providing you with third party marketing information, you can always opt out at a later date by sending an email to email@example.com. We may also wish to provide your information to carefully selected third parties whose products or services we believe may be of interest to you, but we can only do so if we have obtained your previous express permission. If you change your mind at any time after you have authorized us to provide your information to third parties you can always revoke your consent by sending an email to firstname.lastname@example.org.
Cookies are small text files placed on your computer to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function if you remove cookies from your browser.
Disclosure of Your Personal Information to Third Parties
We may share your personal data with the parties set out below for the purposes set out in the table hereinabove above.
- External Third Parties as set out in the Glossary.
- Specific third parties such as https://mailchimp.com/features/landing-pages
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also share your personal information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may only use your personal data in the same way as set out in our Privacy Statement.
How we protect your information
We have put in place the following security procedures and technical and organisational measures to safeguard your personal information:
- We provide an SSL (Secure Sockets Layer) certificate is a digital certificate that authenticates the identity of the website and encrypts information sent to the server. It activates the padlock icon and the https protocol, ensuring secure connections from your website to the web browser.
- We provide a stateless firewall that implements security measure to protect our website.
- All passwords used are of maximum strength and are encrypted.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will use all reasonable efforts to safeguard your personal information and for this purpose we undertake to review our security procedures and technical and organizational measures regularly in order to account for the latest technological developments. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
Pursuant to the requirements of the GDPR in the event that we become aware of any suspected data breach in our system we are under an obligation to notify you of the nature of the data breach in question without undue delay. We are also obliged to report this to the Office of the Commissioner for Personal Data Protection (OCPDP) in its capacity as the competent supervisory authority concerning personal data protection, within 72 hours of any such suspected breach coming to our attention.
For How Long Do We Keep your Data Stored in our System?
Any requests, inquiries, comments, feedback or complaints communicated to us via our user support feature, including your name and email address, shall be kept until such time as the relevant request, inquiry or complaint has been conclusively dealt with or resolved and for the request history purpose, and in any event no longer than it is absolutely necessary.
Personal information that you submit in the course of using the Website shall be kept by us only as long as you use the website, or as long as it is absolutely necessary in order to attain the purpose for which such personal data was submitted by you in the first place, or as otherwise required by any applicable Laws or and/or Regulations in force from time to time.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We do not transfer your personal data outside the European Economic Area (EEA). The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Your Legal Rights
You have the right to request a copy of the information that we hold about you (including whether or not personal data concerning you is being processed, where and for what purpose). If you would like a copy of some or all of your personal information, please send an email to email@example.com and an electronic copy (unless otherwise requested by you) will be provided to you free of charge, within a month of receipt of such request (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). 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.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to the Company changes please let us know the correct details by sending an email to firstname.lastname@example.org.
You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
You may withdraw your consent allowing us to process and use your personal information at any time. If you elect to withdraw your consent you are entitled to have the personal information we hold about deleted or erased without undue delay, following a relevant request to this effect. You may also be entitled to require us to stop sharing this information and prevent any third parties from continuing to use this information. 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.
You may also exercise your right to have such information erased or deleted from our system in so far as the information in question is no longer relevant for the purpose for which it was originally provided by you for processing.
You are also entitled to request an electronic copy of the personal data that you have provided and request that these be transmitted directly, where this is possible, to another entity without hindrance. 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.
Furthermore, you have a right to object, at any time, to the processing of the personal information that you have submitted provided such an objection can be justified on legitimate grounds.
What we may need from you
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.
Third Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and/ or apps and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website or app you visit.
Where required by applicable data protection laws, we will always seek to obtain your express permission before we ask you to submit your personal information on our website or process your data in a particular way.
Please note that the data protection law in Cyprus will change with effect from 25 May 2018. Although this Privacy Statement sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
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.
How to contact us
We welcome your views about our website and our Privacy Statement. If you would like to contact us with any queries or comments please send an email to email@example.com
Our website may contain links to other websites. This Privacy Statement only applies to this website so when you link to other websites you should read their own privacy policies.
If you have reason to believe that there has been an anauthorised use of your personal data or that your personal data may have been used in a manner inconsistent with the purpose for which you have agreed to provide or supply such personal data in the first place, or that your personal data may have been compromised by reason of improper use, you are encouraged to contact us via email at firstname.lastname@example.org in order to communicate your complaint.
Alternatively, you are entitled to submit a complaint to the Office of the Commissioner for Personal Data Protection (hereinafter the OCPDP) in its capacity as the competent supervisory authority in respect of the applicable regulatory framework pertaining to personal data protection.. The contact details of the OCPDP are provided hereinbelow:-
Office of the Commissioner for Personal Data Protection
1, Iasonos str.,
P.O.Box 23378, 1682 Nicosia
Telephone no.: +00357 22 818456
Fax no.: +00357 22 304565
E-mail Address: email@example.com
For more information concerning your rights emanating from the Data Protection Law and the applicable regulatory framework including the relevant EU Regulations, including the General Data Protection Regulation (GDPR) you are encouraged to visit the OCPDP website at the following address: http://www.dataprotection.gov.cy
Glossary of Third-Parties with whom we may share your Personal Information
EXTERNAL THIRD PARTIES
Service providers acting as processors based in the Republic of Cyprus who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the Republic of Cyprus who provide consultancy, banking, legal, insurance and accounting services.
Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the Republic of Cyprus who require reporting of processing activities in certain circumstances.