This Application collects some Personal Data from its Users.
EVRESIS SERVICES LIMITED attaches the greatest importance to the protection of your Personal Data and your Privacy when it collects and processes information about you. This Privacy Notice will inform you as to how “EVRESIS SERVICES Ltd” (hereinafter referred to as the “Company”, “we”, “us” and “our”) collects and processes information about you and in particular, your personal data. We hereby assure you that this Privacy and Personal Data Protection Policy (“Policy”) fully respects and complies with the EU Regulation 679/2016 (“Regulation”) and the relevant Law 125 / I / 2018 of the Republic of Cyprus.
Personal Data is any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, indicatively by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the
Regarding the personal data in cases we, as a company, determine the purposes and means of the processing, the Controller is the legal person: EVRESIS SERVICES LIMITED, address: Vithleem 20, 1st floor, 2033 Strovolos, Nicosia, Cyprus, tel: +357 22747000, email: firstname.lastname@example.org.
Principles we adhere to
At EVRESIS SERVICES LIMITED, we are committed to and adhering to the following principles of processing the personal data in accordance with Article 5 of the Regulation. The personal data is:
- 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 it is processed (principle of ‘data minimisation’);
- accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, 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’).
Collection of Personal Data
We, as the Controller, collect Personal Data from you in the following cases:
- When you contact us directly, or by phone, or indirectly (e.g., through our webpage and/or email, or through our collaborators, or through our Social Media accounts, etc.), in order to be informed regarding our services or ask relevant information;
- If you receive services on our behalf and not on behalf of our clients, if you cooperate with us, or if you are involved in events related to the offer of our services;
- If you fill in any of our documents, or submit a complaint, or visit our webpage, or when you are connected to our social media accounts;
- When your personal data is disclosed to us by third parties – partners or clients under contracts or agreements;
- When you visit our premises where a video surveillance system is legally operating for security purposes;
- When you are an employment candidate;
- When you are one of our employees.
In addition, it is noted that we process personal data, which third parties, usually legal entities, disclose to us, if we have the role of Processor on their behalf. In such case, those legal entities hold the responsibility to properly inform you.
Minors’ Personal Data
We do not collect and/or process minors’ personal data without verifiable parental consent in cases when we are able to control it. For example, it is not possible to control information that is communicated to us without physical presence. In any event, if we find that we have collected any personal information from a minor without verifiable parental consent (in accordance with Article 8 of the Regulation), we will immediately delete the information from our records.
Categories of Data Subjects
The categories of data subjects whose personal data we process as the Controller include:
- Natural persons or executives of legal persons, interested in our services;
- Natural Persons receiving our services or are related to the delivery of our services, or natural persons and employees of our suppliers and other legal persons cooperating with us;
- Visitors of our premises, our webpage and our social media accounts;
- Natural persons involved in projects we participate to;
- Candidates for employment;
- Our staff.
Data from the following categories of personal information about you, may be processed per case, in order to serve the purpose of the data collection and in accordance with the relevant legal basis, as described in this Policy:
- Contact details with you or a natural person you may indicate instead of you (name, surname, address, telephone or fax number, email);
- Occupational information (occupation, position);
- The content of the phone call that is recorded, when you contact us or we contact you via our call center;
- Your curriculum vitae (CV) and relevant information like role in the project, duties and responsibilities, and time allocated in the project when you cooperate with us under the framework of various projects;
- Information related to terms of agreements (yours or persons involved) such us necessary identification and contact details, terms of the service, dates, signatures and amounts;
- Payment and transaction details (IBAN or account number, tax number, desired payment method, terms of payment, depositor’s details);
- Incident investigation data, such as incident details, data of persons involved and related information;
- Client history (satisfaction, transaction details, claims, problems, terms) and information related to assessing persons and situations;
- Apps / websites / social media related data (cookies, full name or nickname, information you publicly disclose and comments on social media including photos per case, as well as information included in email attachments);
- Your photograph in case and under your specific consent is uploaded on our website or social media accounts or yourself recorded within our legally operating video surveillance system when you are visiting our premises;
- Data included within your Curriculum Vitae when you submit as candidates for employment, such as data related to studies, competencies or previous working experience, and other information included therein, as long as you disclose this information to us.
It is noted that we collect and process some more kind of personal data about our employees; they are informed through documents, manuals, policies and procedures and information internally provided.
Purposes and the Legal Bases of Data Processing
The processing of personal data from us as the Controller, is based on one of the “legal bases” as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data).
The legal bases on which the collection and processing of your personal data is based (in most of the cases) are:
- your consent (Article 6.1.a) or explicit consent (Article 9.2.a);
- processing that is necessary for the performance of a contract to which you as the data subject is party, or in order to take steps at your request as the data subject prior to entering into a contract (Article 6.1.b);
- the compliance with our legal and statutory obligations (Article 6.1.c);
- the safeguarding of our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of yours as the data subject (Article 6.1.f).
Article 9 of the GDPR regarding the legal grounds of processing special categories of personal data is related only to our employees; they are internally informed.
The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: when you communicate with us in any way directly or indirectly as interested in our services, when you are interested in working or cooperate with us, when you agree with regards to the recording of the phone call content, when you fill in our documents, when you make a complaint, when you have agreed to inform you in the framework of corporate promotion activities, when you visit our social media accounts, when you give us your business card.
Explicit Consent: when you agree to upload your photograph in our website or social media accounts.
Performance of a contract: when you have agreed to receive our services, when you are our employee or professional collaborator, during the payment of our liabilities or when we are contacting you in the framework of a contract.
Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.
Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, or for the assessment of persons and situations. In this specific legal basis is also based the video surveillance system operation in our premises, that we maintain for security reasons, namely, the protection of people and the property.
Our employees are informed about the processing purposes and the legal bases under specific documents internally.
Retention of Data
Following the principle of ‘storage limitation’, we store as the Controller personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose. It is noted, that storage period in the cases we have the role of Processor, is determined by the respective Controller.
Data collected on the basis of contractual and legal obligations shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework.
Personal Data included in offers that does not lead to a cooperation agreement is kept for 3 months.
The content of the phone call in case we have the role of Controller regarding the specific recording is retained up to 3 months and depending the volume of the data contained therein.
Cookies are stored depending on their nature as you may be informed in our cookies policy.
Personal data you disclose to us as candidates are stored for 12 months or until you revoke your consent regarding processing these data.
The CCTV recording is stored no more than 15 days.
Data that may be needed for our legitimate interests as a Controller shall be kept until the reason for storing such data ceases.
Specifically, the data we process based on your consent, is kept from obtaining the consent until it is revoked or there is no longer need to store it.
Information that is no longer necessary is securely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for the specific purpose.
How we ensure the security of Personal Data
We have received reasonable organisational and technical measures to protect the personal data we process, and in particular any specific categories of personal data. We follow international standards and practices to ensure the security of our networks. Specifically, we are Certified under the International Standards ISO 27001 Information Security Management and ISO 9001 Quality Management by TUV Austria. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:
- Access to personal data is restricted to a limited number of authorised employees under a need-to-know basis, and the necessary data transfer is done by secure procedures.
- Our employees are bound by confidentiality rules and agreements, with limited classified access to the necessary data only.
- We select trusted collaborators 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 audit them in accordance with Article 28 (3) (h).
- In our ICT systems used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access, unauthorised destruction or modification, or other illegal processing.
In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.
Some of the security measures we take are not announced for obvious reasons.
To whom the Data may be disclosed
We receive measures to ensure that the recipients of personal data are kept to a minimum. The personal data we collect is disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully process as a Controller, may be accessed (or disclosed) on a case-by-case basis by:
Any relating supervisory authority within its role;
Any public or judicial authority where required by law or judicial decision.
The auditor of the company, for necessary data required to fulfil the audit (financial, employment, contracts and other controls), under confidentiality.
Information and Communication Systems’ Administrator under specific confidentiality and data processing clauses included in specific agreements.
The legal advocate, for whatever data is required in legal cases, under confidentiality.
The Insurance cooperating company and only for the relevant part of the information.
Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
The training or Systems’ consultants and the Certification body, for systems control and auditing purposes and only for the necessary pieces of information and data.
The personal data we collect is processed within the European Economic Area (EEA).
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.
The right to be informed is exercised through this privacy and personal data protection policy. In some cases, it is also mentioned in documents – forms we are using to contact with you.
The right of consent is provided by design as we have reviewed all our processing activities and ask your consent when the case.
The following rights may be exercised to us in the case we are the Controller.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data is 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:
- your personal data is no longer necessary in relation to the purposes for which we collected it;
- withdraw your consent on which the processing is based and where there is no other legal basis for the processing;
- your personal data has been unlawfully processed;
- your personal data has to be erased for compliance with a legal obligation we are subject to;
- your personal data has been collected in relation to the offer of information society services.
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 to Article 17 § 3).
Right to restriction of processing; you have the right to restriction of processing when:
- you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- we no longer need your personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;
- you objected to processing pending the verification whether our legitimate grounds override those of yours.
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.
This right may be exercised provided that:
- the personal data have been provided by you as the data subject; and at the same time
- where the processing is based on your consent or for the performance of a contract; and at the same time
- when processing is carried out by automated means.
Therefore, according to the above mentioned, any data that have been anonymised, they do not relate to this right. However, data that has been pseudonymised and can identify the data subject is within the scope of the right.
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.
We inform you that we are not using software of decision making solely based on automated processing including profiling.
In the event that you make such request in a proven way (in physical or electronic form) regarding any of the above rights, we 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 to 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 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:
- Assess it in order to implement the appropriate procedures needed to limit the breach;
- Examine the extent of the breach and the sensitivity of the data included;
- Evaluate the risk and its impact on your rights and freedoms;
- Endeavour to reduce as much as possible the damage that is or may be caused;
- Notify within a time limit of 72 hours of becoming aware of the breach, the National Personal Data Protection Authority, if required;
- Assess the impact on your privacy and take appropriate measures to prevent the repeating of the incident.
In the event we are the processor, we will inform the Controller as soon as possible.
Cyprus Personal Data Protection Authority, 1 Iasonos Street, 1082 Nicosia, telephone +357.22818456, e-mail: email@example.com.
Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=celex%3A32016R0679.
If at any time you want to contact us or make a request regarding your rights or any other matter relating to the protection of personal data, you may contact our Personal Data Officer address: Vithleem 20, 1st floor, 2033 Strovolos, Nicosia, Cyprus, tel: +357 22747000, email: firstname.lastname@example.org.
This policy was updated and is effective from June 1st, 2022, and will be reviewed when there is a significant change. This review will be available on our website, with a note of the effective date. You may find a hard copy of this policy at our front desk or may be dispatched at your request.