1. Scope
The purpose of this Data Protection Notice is to provide data subjects with information on the terms and conditions of the processing of their personal data as required under General Data Protection Regulations (Regulation (EU) 2016/679).

This policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore, the way this website processes, stores and protects user data and information will also be detailed within this policy.

2. The website
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with national laws of the Republic of Cyprus and requirements for user privacy.

3. Responsibilities
All Employees of DELFI CORPORATE SERVICES LTD who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

4. Privacy notice

Who are we?

DELFI CORPORATE SERVICES LTD, registered number HE 241283, regulated by the Cyprus Securities and Exchange Commission (CySEC) and authorized for the provision of fiduciary services under the license number 03/196.

Address: 2, Romanos Street, Floor 4 Office 401, Nicosia 1070 Agios Antonis, Cyprus

Our and data protection representative can be contacted directly here:

• info@delficorp.com
• Tel: (357)22376867

The personal data we would like to collect from and process on you: –

When using our website, software applications or services, you may be required to provide personal information (name, address, email, account details, etc.). We will use this information to administer our website, applications, client databases and marketing material.

1. Data obtained as a result of accessing this website and creation of log files

Personal data / Specific operation.
Information is collected every time this website is accessed or used. These data and information is stored in log files on the server and can include:

IP address is temporarily stored in the system
and it is retained while that website is being accessed.

The data will be deleted when it is no longer needed for the purpose that it was collected for.-

At the end of every session – for data collected to provide access to the website.

After seven days the latest – for log files. Some data may be preserved for a longer period of time, in which case user IP addresses are deleted or removed, rendering it impossible to link the data to any individual.

Purpose.
Log files are stored to ensure website functionality, optimize the content of our website, and ensure the security of our IT system.

Necessary to provide website access to the User’s computer.

Legal basis (in accordance with Art. 6 of GDPR).
The temporary storage of data and log files is lawful pursuant to Art. 6 (1) General Data Protection Regulation.

2. Data obtained as a result of Registration

Personal data / Specific operation.
Users can register on Delfi Corporate Services Ltd website by providing personal data. All information requested in the online data entry form will be transmitted as part of the registration process.

User will be asked to grant your consent for the processing of this data as part of the registration process.

The data will be deleted after it is no longer needed for the purpose that it was collected.

Purpose.
User registration is necessary to provide specific content and services on our website, including the creation and administration of user accounts, participation in surveys, the administration of applications for admission and placement tests, the organization of examinations, registering for courses, events, examinations, and the administrative tasks associated with them.

Legal basis (in accordance with Art. 6 of GDPR).
This data is processed subsequent to user’s consent pursuant to Art. 6 (1) GDPR.

3. Contact form and email contact

Personal data / Specific operation.
There are contact forms on Delfi Corporate Services Ltd website that can be used to communicate electronically. When registering, the data entered by you into the online data entry form will be transmitted. Your consent is required for the processing of this data, and you will be referred to our Privacy Statement and asked to grant your consent when you send the form.

Alternatively, contact may be initiated using an email address provided by you. In this case, the personal data provided in the email will be stored. This information will not be passed on to third parties.

The data will be deleted when it is no longer needed for the purpose that it was collected.

Purpose.
This data is necessary for the purposes of processing the communication.

Legal basis (in accordance with Art. 6 of GDPR).
This data is processed subsequent to user’s consent pursuant to Art. 6 (1) GDPR.

4. Data obtained as a result of using cookies

Personal data / Specific operation.
Cookies are small data files, created and stored by the Internet browser that track, save and store information about the user’s interactions and usage of the website. Accessing a website may result in a cookie being saved.

The Users, have full control over cookie implementation. You can deactivate or restrict cookies by changing your browser settings. Cookies already stored can be deleted at any time. This can also be done automatically. However, disabling cookies for our website may result in some functions not working correctly.

We may use cookies to remember personal settings you have chosen at our website. In no other context do we use cookies to collect information that identifies you personally. Most of the cookies we set are automatically deleted from your computer when you leave our website or shortly afterwards.
We use anonymous session cookies (short-term cookies that disappear when you close your browser) to help you navigate the website and make the most of the features. If you log into the website, application or a course as a registered user, your session cookie will also contain your user ID so that we can check which services you are allowed to access.

Purpose.
Cookie contains a specific string of characters that allows the browser to be clearly recognized every time the website is accessed. Cookies are used to make our website more user-friendly, to simplify the website use, to provide the users with a tailored experience within this website.

Legal basis (in accordance with Art. 6 of GDPR).
The processing of personal data based on the use of cookies subsequent to user’s consent is lawful pursuant to Art. 6 (1) GDPR.

5. Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Where we are asking you for sensitive personal data we will always tell you why and how the
information will be used.

We will ensure that all personal information supplied is held securely in accordance with the General Data Protection Regulation (EU) 2016/679. Further, by providing telephone, fax and email details, you consent to Delfi Corporate Services Ltd contacting you using that method. You have the right at any time to request a copy of the personal information we hold on you. Should you wish to receive a copy of this, or would like to be removed from our database, please contact us at the address provided in this Notice.

You may withdraw consent at any time by sending us an email to the address provided in this Notice.

6. Retention period
DELFI CORPORATE SERVICES LTD will not retain your personal information longer than necessary. We will hold onto the information you provide either while your account is in existence, or as needed to be able to provide the Services to you, or (in the case of any contact you may have with our Customer Care team) for as long as is necessary to provide support-related reporting and trend analysis only.

If legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also retain some of your information for a limited period of time as required, even after you have closed your account or it is no longer needed to provide the Services to you.

7. Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 8 below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

8. Complaints
In the event that you wish to make a complaint about how your personal data is being processed by DELFI CORPORATE SERVICES LTD or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and DELFI CORPORATE SERVICES LTD’s data protection representative.

The details for each of these contacts are:

Telephone: +357 22 376 867
E-mail: info@delficorp.com
Address: Delfi Corporate Services Ltd, 2, Romanos Street, Floor 4 Office 401, Nicosia 1070 Agios Antonis, Cyprus

Right to lodge a complaint
If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data, you have the right to submit a complaint to the Office of the Commissioner for Personal Data Protection: 1 Iasonos Street, 1082 Nicosia, P.O. Box 23378, CY-1682 Nicosia

Telephone: +357 22 818 456
Fax: +357 22 304 565
E-mail: commissioner@dataprotection.gov.cy
Website: http://www.dataprotection.gov.cy