PRIVACY POLICY

SAPO GIVEAWAYS PUBLIC LTD understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

 

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:  

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;
“Our Site”	means this website, sapo.com.cy;
“Cyprus and EU Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
“We/Us/Our”	means SAPO GIVEAWAYS PUBLIC LTD , a limited company registered in Cyprus whose registered address is 9-11 Isaak & Solomou str, 2236, Latsia, Nicosia, Cyprus

 

Information About Us

1.    Our Site, sapo.com.cy, is owned and operated by SAPO GIVEAWAYS PUBLIC LTD , a limited company registered in Cyprus whose registered address is 9-11 Isaak & Solomou str, 2236, Latsia, Nicosia, Cyprus.

2.    Sapo.com.cy is an online marketplace for corporate and personal gifts.

 

Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

 

What Data Do We Collect?

Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it and consent to Us using it, for example, when placing an order. Depending upon your use of Our Site, We may collect some or all of the following data:

1.    Name

2.    Email Address

3.    Address

4.    Phone

 

How Do We Use Your Data?

1.    All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). 

2.    We use your data to provide the best possible services to you. This includes:

–        Providing and managing your Account

–        Providing and managing your access to Our Site

–        Personalising and tailoring your experience on Our Site

–        Supplying Our services to you

–        Personalising and tailoring Our services for you

–        Responding to communications from you

–        Supplying you with email alerts about your orders, recommendations, account updates and newsletters. You can unsubscribe at any time from all of the above except alerts about your order which are necessary for the timely operation of the service

–        Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

 

3.    In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services we can provide you without your consent for Us to be able to use such data.

4.    With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message with news and offers of Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.    Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.  We will only process your personal data if at least one of the following bases apply:

                   i.        You have given consent to the processing of your personal data for one or more specific purposes;

                  ii.        Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

                 iii.        Processing is necessary for compliance with a legal obligation to which we are  subject;

                iv.        Processing is necessary to protect the vital interests of you or of another natural person;

                 v.        Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

                vi.        Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

How and Where Do We Store Your Data?

1.    We only keep your data for as long as We need to in order to use it as described above and/or for as long as We have your permission to keep it.  In any event, We will conduct a review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention policy can be found below in section 16.

2.    Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.

3.    Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

4.    Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

 

Do We Share Your Data?

1.    We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

2.    In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

 

How Can You Access and/or Control Your Data?

1.    When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).

2.    You can request to view,export,rectify, restrict the usage, object or delete all the data sapo.com.cy holds according to articles 15-21 of the GDPR. Send your request at info@sapo.com.cy

 

What Cookies Do We Use and What For?

1.    Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

2.    All Cookies used by and on Our Site are used in accordance with current Cyprus and EU Cookie Law.

 

What Third party services do We Use and What for?

1.    Our Site uses analytics services provided by Third Parties. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

2.    You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

3.    You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

4.    It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

Summary of Your Rights under GDPR

Under the GDPR, you have:

1.    the right to request access to, deletion of or correction of, your personal data held by Us;

2.    the right to complain to a supervisory authority;

3.    be informed of what data processing is taking place;

4.    the right to restrict processing;

5.    the right to data portability;

6.    object to processing of your personal data;

7.    rights with respect to automated decision-making and profiling.

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section Contacting us below.

 

Automated Decision-Making and Profiling

1.    In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

2.    The right described in above does not apply in the following circumstances:

a.    The decision is necessary for the entry into, or performance of, a contract between You and Us;

b.    The decision is authorised by law; or

c.     You have given you explicit consent.

3.    Where We use your personal data for profiling purposes, the following shall apply:

a.    Clear information explaining the profiling will be provided, including its significance and the likely consequences;

b.    Appropriate mathematical or statistical procedures will be used;

c.     Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and

d.    All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

 

Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@sapo.com.cy. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

 

Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

 

Retention Policy

Data retention is defined as the retention of data for a specific period of time and for back up purposes. We shall not keep any personal data longer than necessary, but acknowledge that this will be dependent on the different types of documents and data that we have responsibility for. From time to time, it may be necessary to retain or access historic personal data under certain circumstances such as if we have contractually agreed to do so or if we have become involved in unforeseen events like litigation or business disaster recoveries.

 

Destruction and Disposal

Upon expiry of our retention periods, we shall delete confidential or sensitive records categorised as requiring high protection and very high protection, and we shall either delete or anonymise less important documents.