DATA PROTECTION AND CONFIDENTIALITY STATEMENT OF I.G. PERFECT ECLASS LIMITED
The purpose of this document;
Our company is committed to protecting the confidentiality and security of your personal data in accordance with the General Data Protection Regulation of the EU (‘GDPR’) and the Law on the Protection of Natural Persons with regard to the Processing of Personal Data and the Free Movement of such Data of 2018 (Law 125(I)/2018).
This data protection and confidentiality statement describe how we collect, manage, use, and process your personal information during your use and navigation of the website www.perfecteclass.com.cy, including the processing of any information you may provide through our website www.perfecteclass.com.cy, such as subscribing to our newsletter or expressing your interest in a free trial of our services.
Our company is the ‘data controller.’ This means that we are responsible for deciding how your personal data is retained and used. We are obligated by data protection legislation to provide you with the information contained in this data protection and confidentiality statement.
This statement applies to every user of our website, as well as any user who provides personal data through our website. This statement is not part of any service agreement or any other contract. We may modify, update, and/or replace this statement at any time.
It is important to read this statement together with any other data protection statements we may provide in specific cases when collecting or processing personal information about you, so that you know how and why we use this information.
Data Protection Principles
Our company undertakes to comply with the principles related to the processing of personal data set forth by the GDPR. These principles dictate that the personal information we retain about you must:
- Be processed lawfully, fairly, and transparently..
- Be collected only for specific, explicit, and legitimate purposes that we have clarified to you and not processed in any way that is incompatible with these purposes.
- Be relevant to the purposes we have informed you of and limited only to those purposes.
- Be accurate and up-to-date.
- Be retained for as long as necessary for the purposes we have informed you of.
- Be kept secure.
Contact Information
If you have any questions regarding this Data Protection and Confidentiality Statement, please contact our company through the following means:
- Address: 3, Agiou Georgiou Street, Office 4, P.O. Box: 7600, Athienou, Larnaca, Cyprus
- Open Telephone Line: +357 26020823
- Email: info@perfecteclass.com.cy
Personal Information We Collect and Why We Collect It
The website www.perfecteclass.com.cy collects and uses personal information for the following reasons:
Visitor Tracking
This website utilizes Google Analytics (‘GA’) to monitor user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages, and to track their journey within the site.
While GA records data such as geographic location, device, internet browser, and operating system, none of this information personally identifies you. GA also records your computer’s IP address, which could be used for your personal identification, but Google does not grant us access to it. We consider Google to be a third-party processor.
GA uses cookies, details of which can be found in Google’s developer guides. Our website uses GA’s analytics.js application.
Disabling cookies on your internet browser will prevent GA from tracking any part of your visit to pages on this website.
Our Blog
If you choose to add a comment to any posts we have published on our blog, the name and email address you enter with your comment will be stored on this website’s database, along with your computer’s IP address and the time and date you submitted the comment. This information is used only to identify you as a contributor to the comments section of the respective blog post and is not passed on to any of the third-party processors described in detail below. Only your name will be displayed on the public-facing website.
Your comment and its associated personal data will remain on this site until 1) you request deletion of the comment or 2) we remove the blog post. If you wish to have the comment and its associated personal data deleted, please contact us using the contact information above, using the email address you used to comment.
If you are under 16 years of age, you MUST obtain parental consent before posting a comment on our blog.
NOTE: Avoid entering personal information in the comment field on this website.
Contact Forms and Email Links
If you choose to contact us using the contact form on our ‘Contact’ page or an email link like info@perfecteclass.com.cy, none of the data you supply will be stored by this website, nor will it be passed on or processed by any third-party processors. Instead, the data will be collated into an email and sent to us via the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL), meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
Electronic Newsletter
You have the option to subscribe to our company’s electronic newsletter through which you will be informed about various topics related to our company’s activities and more. Before subscribing to our newsletter, you will be asked to fill out an electronic form where you will enter your full name, phone number, and email address. Your consent to process this data for the specified purpose will also be required. If, for any reason, you wish to stop receiving our newsletter, you can contact us at info@perfecteclass.com.cy to communicate your preference.
Free Trial and Expression of Interest for Services
If you choose to fill out the expression of interest form for the free trial of the Perfect eClass educational platform or express interest in the technological digital solutions services we provide, located on the website www.perfecteclass.com.cy, the name, phone number, and email address you enter into this form will be stored in the database of this website along with your computer’s IP address and the date and time you submitted the details.
Legal Basis of GDPR for the Use of Your Personal Information
We will use your personal data only in accordance with the legal bases of the General Data Protection Regulation (GDPR) listed below. Generally, we will use your personal data in the following cases:
- Where we take pre-contractual measures at your request before entering into a contract between us, and where we need to perform the contract we have entered into with you.
- When we need to comply with a legal obligation.
We may also use your personal data in the following rare cases:
- Where it is necessary for our (or third parties’) legitimate interests and your interests and fundamental rights and freedoms do not override those interests.
- When you have explicitly asked us to do something or have given clear consent for us to process your personal data (e.g., responding to a question you may have submitted, subscribing to our newsletter, or expressing interest in our services).
We may use your personal data for the following specific purposes:
- Establishing or agreeing with you (or a company related to you) the terms on which we cooperate. [1]
- Providing contractual benefits to you. [1]
- Managing the contract we have entered into with you. [1]
- Managing and planning the business, including maintaining accounting records and auditing them. [1], [2], [3]
- Conducting performance reviews, performance management, and setting performance requirements. [1], [3]
- Training, education, and development requirements. [1], [2]
- Compliance with health and safety obligations. [1], [2]
- Fraud prevention. [1], [2], [3]
- Monitoring equal opportunities. [1], [2], [3]
- Sending you informational material related to our services. [4]
- Submitting a question or any other request to us (e.g., for a free trial) through the website. [4]
Some of the above cases may overlap, and there may be various bases justifying the use of your personal data.
Not Providing Personal Data
In case you do not provide specific information when requested, we may not be able to fulfill the contract we have entered into with you (such as providing you with a benefit), or we may be prevented from complying with our legal obligations.
Change of Purpose
We will use your personal data only for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. We may process your personal data without your knowledge or consent when required or permitted by law.
Right to Withdraw Consent
In limited cases where you may have provided your consent for the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent at any time for that particular processing. To withdraw your consent, please send a written request to us at info@perfecteclass.com.cy.Once we receive notice that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we have another legal basis for doing so.
Automated Decision-Making
Automated decision-making occurs when an electronic system uses personal information to make a decision without human intervention. We may use automated decision-making processes in any of the following cases:
- When it is necessary to enter into or fulfill a contract with you.
- When allowed by law, which also provides suitable measures to safeguard your rights, freedoms, and legitimate interests.
- In limited cases, with your explicit written consent and when appropriate measures are in place to protect your rights.
You will not be subject to decisions with significant impact based solely on automated decision-making unless we have a lawful basis for doing so and have informed you in advance.
Sharing of Data
We may need to disclose your data to third parties, including service providers. We require our third-party partners, where possible, to respect the security of your data and treat it in accordance with the law.
Why We May Share Your Personal Data with Third Parties?
We may share your personal data with third parties when required by law or when we have another legitimate interest in doing so.
Third-Party Service Providers Processing My Personal Data
“Third parties” include third-party service providers (including partners, contractors, and authorized representatives) and public or local authorities. The following activities are performed by third-party service providers: tax and social security contributions, IT services, accounting, auditing, tax, and legal services.
How Secure Is My Data with Third-Party Service Providers
All our third-party service providers are required to take appropriate security measures and organizational measures to protect your personal data in accordance with our policies. We do not allow third-party service providers to use your personal data for their own purposes.
We only allow them to process your personal data for specific purposes and in accordance with our instructions.
What Happens with Other Third Parties
We may disclose your personal data to other third parties, for example, in the context of a possible sale or restructuring of the business. We may also need to disclose your personal data to a regulatory authority or to comply with the law.
International Data Transfer
Some of our third-party service providers are located outside the European Economic Area (EEA), so the processing of your personal data will involve data transfer outside the EEA. Each time your personal data is transferred outside the EEA, we ensure that a similar level of protection is provided, ensuring that when we use specific service providers, we may use specific contracts approved by the European Commission, providing your personal data with the same protection offered within the EEA. Please contact us if you wish to receive more information about the specific mechanism we use when transferring your personal data outside the EEA.
Data Security
We have implemented measures to protect the security of your data, such as creating backups and protecting the integrity of electronic communication and data storage systems. Details about these measures can be provided upon request.
Third parties can process your personal data only according to our instructions and where it has been agreed to treat them confidentially and maintain the source of information.
Data Retention – How long will you use my data?
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected them. To determine the appropriate retention period for personal data, we consider the quantity, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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, as well as any applicable legal requirements.
As a practice, after 10 days from the end of the free trial, or from the expiration of any contract, or from the termination or cessation for any reason of the Perfect eClass educational platform service, we will securely delete any data or information, personal or not, entered into the user account as well as the account itself. We will retain data or information, personal or not, only with the user’s consent.
In some cases, we may pseudonymize your personal data so that they can no longer be associated with you, allowing us to use this information without further notice. Once the purposes for which we collected your data no longer exist, we will securely destroy your personal data in accordance with applicable laws and regulations.
Access, Correction, Deletion, and Restriction Rights
Your rights regarding personal data
Under certain conditions, you have the right to:
- Request access to your personal data. This allows you to receive a copy of the personal information we hold about you and check that we are processing it lawfully.
- Request correction of the personal information we hold about you. This allows you to correct any incomplete or inaccurate information we have about you. Please inform us if your personal information changes during our relationship.
- Request deletion of your personal information. This allows you to ask us to delete or remove your personal information where there is no reason for us to continue processing it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to the processing of your personal information where we rely on a legitimate interest (or that of a third party) and there is something about your particular situation that makes you want to object to processing for this reason. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This allows you to ask us to suspend the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.
- Request data transfer. You can ask us to transfer your personal information to another party.
If you want to exercise any of the above rights, please write to us at info@perfecteclass.com.cy.
Data Protection Officer and Complaints
Given the scale, nature, scope, and purposes of our company, we have not appointed a Data Protection Officer (DPO) to oversee compliance with this data protection and confidentiality statement. However, if you have any questions about this data protection and confidentiality statement or how we handle your personal data, please contact us at info@perfecteclass.com.cy.You also have the right to lodge a complaint at any time with the Office of the Commissioner for Personal Data Protection, the supervisory authority for personal data protection matters in the Republic of Cyprus.
Data Breaches
We will report any illegal data breach of this website within 72 hours of the breach if it is apparent that personal data stored in a recognizable format has been stolen.
COOKIES
The website www.perfecteclass.com.cy uses “cookies,” a technology that stores data on your computer using the functional capabilities of your internet browser, in order to collect statistical information about the visitors of its website and to display relevant advertisements through the Google and Facebook networks. If you do not wish to use cookies for promotional purposes, you can configure your browser to prevent their storage. For more information regarding the use of cookies on our website, you can find in our Cookies Policy, here.
Changes to this data protection statement
This privacy policy may change from time to time in accordance with legislation or developments in the industry. We will not explicitly inform our customers or website users about these changes. We recommend checking this page occasionally for any policy changes.
Recognition and Acceptance
By continuing to use the website www.perfecteclass.com.cy, you acknowledge that you have read, understood, and accepted the content of this statement.
