Introduction

This Website Notice applies to “SNEMA LTD”, the owning company of “snema.com.cy”, (hereinafter referred to as “SNEMA” or the “Company”), as the Data Controller of the Personal Data collected from the aforementioned websites.

SNEMA is committed to protecting the personal information collected when you use our website. This Website Notice pertains to SNEMA website and sets out SNEMA commitment in protecting Personal Data and how that commitment is implemented regarding the collection, use, transfer and retention of Personal Data. This Policy is valid only for cases that we define the purposes and means of the processing, therefore acting as data controller.

Personal Data Collection and Use

SNEMA has designed a standard website contact form to initiate communication with any interested individual. This form is used for any inquiries or requests and it directs them to the appropriate department or staff member. Additionally, we provide SNEMA phone numbers for a more direct contact if required. Our landline phone calls may be recorded for training and monitoring purposes and our recordings are usually held for a period of six months. In order to handle and address your inquiries and requests we might collect and store your full name, email, contact details and any other information you might choose to share with us. That information is strictly used to adequately respond to your inquiries or requests and will not be disclosed to third parties other than those mentioned in this policy or where disclosure is required or permitted by law.

SNEMA has designed a newsletter service in order to provide you with offers relevant to your interest. For your subscription we only request your email address which will be strictly used for promotion that might interest you. In any case that a user of the service may wish to withdraw consent, we offer the ability through the emails that we send or by contacting our DPO. In such cases we also permanently delete the email address from our database.

Please note you can withdraw your consent to all or any one of the above purposes of processing at any time by contacting our DPO. Also note that all processing of your personal data will cease once you have withdrawn consent, but this will not affect any personal data that has already been processed prior to this point.

For processing to be lawful under the General Data Protection Regulation, we identify a lawful basis before we can process your personal data. In this case, the legal basis for the data processing effected by us is the granting of your explicit consent to the processing, by submitting the consent form only in case you agree with this policy.

Transfer of Personal Data

SNEMA may disclose Persona Data collected to our suppliers or subcontractors insofar as reasonably necessary for dealing with your inquiries or requests. Such transfers will be protected by appropriate safeguards (e.g. appropriate contractual clauses, data processing contracts, intra-group disclosures of personal data, etc.). In addition, we may disclose Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject. In any case that we might need to transfer personal data at third parties, SNEMA is committed to ask for your consent if we will not recognise any other legal basis.

Children

Our website is not intended for children and we do not intentionally solicit or collect personal data from individuals under the age of 18. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information.

In limited instances, we may have a campaign or program targeted towards children. In these instances, details on the information practices will be presented within the terms and conditions of the program or campaign.

Personal Data Retention and Deletion

SNEMA is committed not to retain personal data for a longer period than it is necessary regarding the reasons that the personal data was obtained, and we will make sure we will delete it securely.

Rights of Data Subjects

In this section SNEMA addresses the rights deriving from Regulation (EU) 2016/679 and how these rights can be accessed from the Data Subjects.

Individual’s Right of Access or Rectification

SNEMA assumes that Personal Data collected directly from the individual will be accurate and complete. Individuals can access and update their own Personal Data. For exercising your rights, please contact to our DPO at info@snema.com.cy

Individual’s Right to Erasure

The data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

SNEMA is obligated to erase personal data where one of the following applies:

• personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• the data subject withdraws consent and no other legal basis for processing exists.
• the data subject objects to the processing carried out on the grounds of the Data Controller’s legitimate interests and there are no other overriding legitimate grounds for the processing.
• the personal data has been unlawfully processed.

If the request to erase Personal Data has been received, identity has been confirmed, the request meets one of the above requirements and there is no legal contrary reason for processing, SNEMA must delete the relevant data in its entirety.

If SNEMA cannot delete personal data, will ensure that:

• is not able, or will not attempt, to use the personal data to inform any decision in respect of any individual or in a manner that affects the individual in any way.
• does not give any other organisation access to the personal data.
• protects the personal data with appropriate technical and organisational security; and commits to permanent deletion of the information if, or when, this becomes possible.

Individual’s Right to Object

Individuals have the right to object at any time to the processing of their personal data by sending an email to info@snema.com.cy

Individual’s Right to Data Portability

These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

If SNEMA cannot respond fully to the request within 30 days, the DPO shall nevertheless provide the following information to the Data Subject, or their authorized legal representative within the specified time:

• An acknowledgement of receipt of the request.
• Any information located to date.
• Details of any requested information or modifications which will not be provided to the Data Subject, the reason(s) for the refusal, and any procedures available for appealing the decision.
• An estimated date by which any remaining responses will be provided.
• An estimate of any costs to be paid by the Data Subject (e.g. where the request is excessive in nature).
• The name and contact information of the contact person.

Our Details

If you have any concerns, questions or complaints about this policy, then please contact us at: info@snema.com.cy

In case you have believe that the processing of your personal data is violating the law, you may file your concerns or complaints at the relevant supervising authority. You may find a list with all supervising authorities of the EU here:

[http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080].