3 Who is the Controller?
The Controller of personal data in this Policy is the legal entity Lanitis Energy Ltd, Address: 2 Syntagmatos Square, Amathus Building 4th floor, 3036 Limassol, Cyprus -
P.O. Box 70189, 4161 Limassol, Cyprus Phone +357 25 822314, Fax +357 25 822315, E-mail: email@example.com
4 Principles we Adhere to
Lanitis Energy Ltd and the companies that are included in this policy are committed to and adhering to the following principles of processing personal data in accordance with Article 5 of the Regulation. The personal data are:
• 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 they are processed (principle of ‘data minimisation’);
• accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (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 Laws (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’).
5 Collection of Personal Data
Your personal data is collected under the following cases:
We process personal data for the purposes which are mentioned to follow.
6 Personal Data of Minors
We do not collect personal information about minors, without verifiable parental consent, in cases where we can control it. In any case, if we confirm that we have collected any personal information from a minor, without verifiable parental consent (as provided in Article 8 of the Regulation), we will delete the information from our files as soon as possible. If you believe we may have collected information from a minor, please contact us.
7 Categories of Data Subjects
The categories of data subjects include:
8 Kind of Personal Data we may collect about you
The kind of personal data can be collected and processed, as described in this Policy:
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.
9 What Are The Purposes & The Legal Basis of Data Processing
The processing of personal data is based on one of the "legal grounds", as referred to in Article 6 of the Regulation (or Article 9 for specific data categories). The legal grounds the collection and processing of personal data are mainly based on are in most of the cases: a) the consent, b) the compliance in performing our contractual obligations, c) compliance with our legal and statutory obligations, and d) the safeguarding our legitimate interests. For special categories of personal data, i) the explicit consent, ii) the performance of obligations and iii) the exercise of specific rights of the controller or data subject in the field of labour law and social security / social protection law and for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment. The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: When you contact us, interested in our products and services, in cases where you assign us to perform work on your behalf with Services or Authorities, when you are interested in employment, to inform you about our products and services in the context of promotional activities, when you visit our infrastructure and in case of a CCTV system informing you on the recording, when you visit our accounts on social media for our promotion purposes or through your wireless connection to our networks .
Compliance in performing our contractual obligations: When you are our customer for our service to you and fulfilment of our agreement, when you are our employee, partner or supplier for the signing and compliance with the contractual terms, or in cases where we contact you within the framework of the agreement.
Compliance with our legal and statutory obligations: for our compliance with our legal obligations towards any Authority such as police, concerning labour law, regulatory, tax, accounting, statutory auditors, judicial authorities and services or the payment of our obligations.
Safeguarding our legitimate interests: for the improvement of our services, for our payment or payment of our obligations, for evaluations of persons and situations.
Informing our staff about the legal basis for processing is implemented internally.
10 Date Retention Period
We store personal data for as long as required by the respective processing purpose and any other permitted linked purpose. The data collected on the basis of contractual and legal obligations are kept after the expiration of the contractual and legal obligations as provided by the respective institutional framework or for as long as the guarantees are in force.
Data on offers that do not lead to an agreement are kept for three years.
The CCTV recording data is stored for 15 days, while cookies are stored for 2 years although as you can see in the relevant policy you can select your preference through the browser.
Data that may be required for our legitimate interests as a controller is kept until the reason for compliance ceases.
Especially for the data that we process based on your consent (e.g. for marketing purposes), these are kept under this consent until the consent is revoked.
Information that is no longer needed is securely destroyed or is made anonymous. We restrict access to your data to persons who need to use it for that particular purpose.
11 How Do We Ensure the Security of Personal Data
We have received reasonable organizational and technical measures to protect the personal data we collect, and in particular any specific categories of personal data. We follow international standards and practices to ensure the security of our networks. We ensure that your personal data is processed securely and legally, in compliance with policies and the development and implementation of procedures. For example, the following security measures are taken to protect personal data against unauthorized use, or any other form of unauthorized processing:
• Our facilities are safe, taking reasonable measures to the best extent possible.
• Access to personal data is limited to a certain number of authorized persons, for the specific purposes and the necessary data transfer is done through secure procedures.
• Our staff is bound by confidentiality rules, having classified and limited access only to the necessary data.
• In special data categories, there is only authorized electronic access. Furthermore, printed materials are kept in locked cabinets where only authorized persons have access.
• We select reliable partners, 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 control them in accordance with Article 28, paragraph 3.
• In the computer systems used for the processing of personal data, all technical measures are applied to the best possible extent, in order to prevent unauthorized access or other processing.
In addition, access to these IT systems is continuously monitored in order to identify and prevent illegal use at an early stage. Although data transfer via the Internet or a website cannot be safeguarded by cyberattacks, we work to maintain natural, electronic and procedural safety measures to protect your data.
Some of the measures taken are not announced for obvious reasons.
12 To Whom the Data May be Disclosed
We take every precaution to ensure that the recipients of personal data are kept to a minimum. The personal data we collect are disclosed to third parties, provided that the legality of such disclosure is fully justified.
Specific personal data from what we collect legally may be accessible (or disclosed) depending on each case:
• Any professional supervisory authority, in the context of its supervisory role.
• Any public or judicial authority, if required by law or by court order.
• Subcontractors, only for necessary information sections (address, contact details), under confidentiality.
• Our auditor, for all data required (financial data, personnel, agreements and other audit information), under confidentiality.
• The legal advisor, for all data required in legal cases, under confidentiality.
• The insurance companies, for insurance-related issues (which are required to meet the data security requirements).
• The collaborating banks (company, personnel or associates and suppliers), only for data related to payment issues.
• The training consultants, the instructor and the HRD for training issues and only for the necessary information and data departments.
• The assigned company for storage of non-used physical files, with confidentiality clause.
• The authorized information resource managers, under confidentiality.
It is noted that the personal data we collect is not transferred to third countries or international organizations.
13 Territorial Scope
The personal data we collect is processed within the European Economic Area (EEA).
14 Your rights as a Data Subject and how you can exercise them
You have the right to be informed, the right of access to your personal data, the rights of rectification and erasure (in cases it is permitted), the right to restriction of processing, the right to data portability, the right to object. If processing is based on your consent you may withdraw it at any time. We inform you that we are not using software of decision making solely based on automated processing including profiling.
The right to be informed is exercised through this privacy and personal data protection notification. In some cases it is also mentioned on documents – forms we are using.
Right of consent: you have the right to give your consent where there is no other legal basis for data processing.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data are 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:
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 Article 17 § 3).
Right to restriction of processing; you have the right to restriction of processing when:
Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and under an explicit request such data to be transferred to both you and another natural or legal person who will process it.
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.
In the event that you make such request in a written or electronic form regarding any of the above rights, Lanitis Energy 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 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. Before such complaint, you may contact us if you wish so we can provide you with complete information and support.
15 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 case we are the Controller) and we will:
16 Links to other Websites
17 Cookies Policy
18 Contact details with the Personal Data Protection Authority
Cyprus Personal Data Protection Authority, Iasonos 1, 1082 Nicosia, phone +357.22818456, e-mail: firstname.lastname@example.org.
Additional information and terminology for the Regulation can be found on the website:
19 Contact details with the Company for Personal Data issues
For any issue regarding the processing of your personal data and the exercise of your above mentioned rights, you can contact the company at the address: P.O. Box 70189, 4161 Lemesos, Cyprus, telephone: +357 25 822314, (Office hours Monday-Friday 8:00 – 16:30), fax: +357 25 822315, or e-mail: email@example.com Contact person: Ms. Georgoulla Savva
20 Policy Update
This policy is valid from 25 May 2018 and is updated when there is a significant change. This revision will be available on our website, noting the effective date. A printed form of this policy is available from our offices or can be sent to you upon your request.