1. Introduction
DECIMAL 62 SOLUTIONS LTD (hereinafter the “Company”) is incorporated in Cyprus under registration number HE 375186 through the Department of Registrar of Companies and Official Receiver (http://www.mcit.gov.cy/drcor). The Company is the “Controller” of the personal data you provide to us. We collect both anonymous data (for understanding website usage and behaviours) and limited personal data such as name, contact information and email etc.
2. General
This Privacy Policy only applies to the information that the Company collects and controls. The Company needs to know your basic personal data in order to provide you with notice writing and analysis services in line with this overall contract.
The Company shall not disclose to a third party, any of its Clients’ confidential information unless required to do so by a regulatory authority of a competent jurisdiction; such disclosure shall occur on a ‘need-to-know’ basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company shall expressly inform the third party regarding the confidential nature of the information.
Any personal information is treated as confidential and may be shared only within the Company, by its employees and affiliates for business purposes, as permitted by the applicable law. The information may be disclosed to third parties, such as the Company Partners and Affiliates for business purposes only, such as, but not limited to, servicing Client and informing Clients about new products and services. Our Company Partners, Affiliates, and Business Introducers maintain the privacy of your information to the same extent the Company does in accordance with the policy. Information may also be provided to non-affiliated companies, providing professional, technology, legal, and accounting services. Non-affiliated companies that assist the Company in providing services to you are required to maintain the confidentiality of such information and to use your personal information only in the course of providing such services for the purposes that the Company dictates and within the ambit of the applicable law.
The Company will not sell or give away your name, mailing address, phone number, email address or any other information to anyone. The Company will use various security measures to protect your information from unauthorized users.
The policy sets out the procedures and methods used by the Company to collect, use and manage personal information from its visitors, potential and active clients through the Company’s website (hereinafter referred to as the “Site” or the “Website”).
3. Collection of Information
When you choose to submit information to, the Company may collect information from you such as your name, postal address, email address, telephone number, your firm’s name or comments. Generally, the information that the Company collects on the Site is used only for the Company’s own internal purposes, for example, to improve the content of the Site, to improve the Company’s marketing and promotional efforts, to statistically analyse Site usage patterns on an aggregate basis, to improve the Company’s content and Site offerings, and may be used by the Company to contact you to provide you with information that the Company believes may be useful to you. The Company believes that these uses allow it to improve the Site and better tailor it to meet users’ needs. All the personal data processed is controlled by our staff in Cyprus, however for the purposes of IT hosting and maintenance this information is located on servers within the European Union.
4. General Requirements for Data Processing
Data processing means collection, recording, arrangement, storage, alteration, disclosing, consultation, extraction, use, transmission, cross-use transferring or granting access to third parties, interconnecting, closure, deletion or destruction of data, or several of the aforementioned operations, regardless of the manner in which they are performed or the means used.
The Company shall compile a list and documentation of means used in data processing and shall keep records of data processing. The list of means used in data processing shall include the name, type and number of the equipment and the name of the manufacturer of the equipment; the name and number of the licence of the software used and the name of the software manufacturer; the location of the documentation of the software used
The Company shall retain and control your data for a minimum of six years, after which time it shall be erased. Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. Persons engaged in the processing of data shall process data only for authorised purposes under the established conditions, and they shall maintain the confidentiality of data which has become known to them in the course of performance of their duties and which are not intended for public use. Such confidentiality requirement continues after termination of the employment or service relationship with the Company. Unauthorised processing of data (including recording, alteration, deletion, reading, copying, (transmission), unauthorised transportation of records and any other unauthorised use of data (not prescribed by official duties) shall be prohibited.
The Company shall implement adequate and sufficient measures to ensure that every data processing operation leaves a trace, which would afterwards enable identification of the person who performed the operation, the nature and time of the operation and any other relevant facts, including when, by whom and which data were recorded, altered or deleted, or when, by whom and which data in the data processing system were accessed, as well as information on any transmissions of data. A possibility for restoring the content of data before modifications shall be available when any modifications are made in data or documents. Adequate security measures, including encryption of data if necessary, shall be implemented upon transmission of data by means of data communication equipment or in the transport of records. If the accuracy of data is in dispute, the data in questions shall be closed until confirmation of accuracy of the data or determination of correct data. Third persons who provided or received the data shall be promptly notified of any corrections made in data if it is technically feasible and does not lead to disproportionate expenses. Automatic decisions of the data processing system, without participation of the data subject, shall be permitted only on the conditions and pursuant to procedures specified by law.
5. Disclosure of Information
At no time will the Company sell or broker any of the information that the Company receives from you through your use of the Site to any third parties. As a general rule, the Company will not disclose any personal information to any third parties, except in the following circumstances: (i) when the Company believes in good faith that it is required under applicable law, (ii) to protect other users of the Site, or (iii) to respond to an emergency and as set forth below. The recipients of such information may include companies or individuals that are established in countries outside of the European Economic Area and which may not have comprehensive data protection laws.
Information may be given to third-party contractors or other persons or entities that the Company engages in the course of outsourcing certain functions, as applicable. Information will be shared with such third-party contractors, persons or entities only to the extent reasonably necessary for them to perform services on the Company’s behalf and not for any other purpose, and pursuant to reasonable confidentiality obligations. The Company may disclose information if legally required to do so, if requested to do so by a governmental entity or regulatory authority or if the Company believes in good faith that such action is necessary to comply with legal requirements or process, prevent a crime or protect national security. If you engage, or the Company reasonably suspects that you are engaging, in any illegal activity, the Company may disclose your personal information without a subpoena, warrant or other court order to the extent the Company determines in its sole discretion is necessary to cooperate with appropriate authorities. The Company reserves the right to transfer any information that the Company has collected about you through your use of the Site to a third party that acquires a portion of the Company’s business or in the event that the Company sells or otherwise transfers some or all of its assets related to the Site.
The Company maintains rigorous physical, electronic and procedural safeguards to protect personal information against unauthorised access or disclosure, accidental loss, use, alteration or destruction. The Company is aware of, and complies with, relevant laws and regulations regarding personal data.
6. Other Websites
The Site may contain links to third-party websites over which the Company has no control. The Company is not responsible for the privacy policies or practices of such other websites and the Company encourages you to review the privacy policies, if any, on such websites.
7. Cookies
When using the Company’s Website, we may use cookies to collect information. A cookie is a small data file that is stored on the Clients’ computer, for the purpose of making it easier for them to navigate the Website by for example; remembering their IDs, passwords and viewing preferences, thus allowing them to visit member-only areas of the Website without logging in again. The Clients can set their web browser to inform them when cookies are enabled, or to disable cookies. If the Clients do not wish to receive cookies, most web browsers will permit them to decline/disable cookies and in most cases will still allow them complete access to our Site.
8. Tracking Systems
Tracking systems used on the Company’s Website(s) may collect data detailing the pages you have accessed, how you discovered this site, the frequency of visits etc; this information is obtained in order to improve the content of the Company’s website and may also be used to contact the Clients, through any appropriate means and providing the Clients with any information the Company believes to be useful to them.
9. Security
The privacy and confidentiality of the Clients personal information is of fundamental importance to the Company. The Company takes all appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data and personal information.
The Company restrict access to personal information to employees who need to know the specific information in order to operate, develop or improve our services. These individuals are bound by confidentiality and will be subject to penalties if they fail to meet these obligations.
10. Legal Disclaimer
The Company reserves the right to disclose the Clients’ personally identifiable information as required by rules and regulations and when the Company believes that disclosure is necessary to protect their rights and/or to comply with a judicial proceeding, court order, or legal process served. The Company will not be liable for misuse or loss of personal information resulting from cookies on the Company’s Website(s) that the Company does not have access to or control over. The Company will not be liable for unlawful or unauthorised use of your personal information due to misuse or misplacement of your passwords, negligent or malicious.
11. Amendment/Review
The Company will not be obliged to notify its Clients individually of changes, other than substantial material changes to the policy. Thus, the Clients should refer to the Company’s website for the latest and most up to date version of the Policy, which will be applicable from the date of publication on the web.
12. What Are your Rights?
If at any point, you believe the information the Company processes in relation to you is incorrect, you may request to see this information and even have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you may complain to the Information Commissioner’s Office (ICO).
The Company’s Data Protection Officer may be contacted at [email protected].