Privacy Policy

Introduction

This website www.diadikon.com is operated by Diadikon Ltd with registration number HE 381750 with registered office at Pyrrou Dima 3, Mosfiloti, 7647 Larnaca, Cyprus (Diadikon, We). This privacy policy aims to give individuals who are using this website (who unless otherwise specified coincide with Data Subjects) (You, User) information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter. When you use any of our services other privacy policies may potentially apply. 

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using their data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Important information about Diadikon

We, Diadikon Ltd, with registration number HE 381750 and registered office at Pyrrou Dima 3, Mosfiloti, 7647 Larnaca, Cyprus is the controller and responsible for User Data. In some cases, we may process your Personal Data based on an agreement with a third party. In those cases, that third party is a data controller, and we are a data processor. In those cases, the terms of that agreement may govern how we process your Personal Data.

If you have any questions about this Policy or how we process your Personal Data or our privacy practices, please contact us at:

Email: info@diadikon.com

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, the Cyprus regulator for data protection issues. We would appreciate you coming to Diadikon with your complaint in the first instance to give us a chance to resolve it.

Types of Data collected

Among the types of Personal Data that this website collects, by itself or through third parties, there are: Cookies; Usage and Technical Data; first name; last name; phone number; email address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by you, or, in case of Usage and Technical Data, collected automatically when using this website.

You are responsible for any third-party Personal Data obtained, published or shared through this website and confirm that you have the third party’s consent to provide the Data to Diadikon.

Types of Data Collected – categories

We only collect the most relevant, proportionate for each purpose and strictly necessary personal information from you in the course of our business when you use our Website. 

The personal information that we collect, and process includes:

• Identity Data that includes first name, last name, username or similar identifier, date of birth and gender
• Contact Data that includes billing address, delivery address, email address, telephone numbers
• Technical Data that includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices User uses to access this website
• Usage Data that includes information about how User uses our website.
• Marketing and Communications Data that includes preferences in receiving marketing from us and our third parties and communication preferences

Mode and place of processing the Data

Methods of processing

We take appropriate security measures to prevent unauthorized access, use, disclosure, modification, or destruction of the Data consistent with the applicable data protection laws and the EU General Data Protection Regulation.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf,), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information, keep it secure and protect it

Who we may share your Data with

In addition to us, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. Hence, we may share personal information the following categories of third parties as necessary:

• Service providers who provide IT, system administration services and customer screening services.
• Third parties to whom we outsource certain support services such as, without limitation, document processing and translation services, photocopying and document review, confidential waste disposal, IT systems and/or software and/or storage providers, IT Support service providers, document and information storage providers.
• Professional advisers including lawyers, bankers, auditors, insurers and other professionals who provide consultancy, banking, legal, insurance, corporate, administration and accounting services.
• Government or governmental agencies, regulatory authorities, courts and law enforcement agencies, registries. We may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted.
• Appropriate parties in the event of emergencies.
• Advertising networks:to support and display ads on our website, apps and other social media tools.
• Third party service providers to assist us with client insight analytics, such as Google Analytics.
• Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

Please note the following:

• This list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services as effectively as we can.
• We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The updated list of these parties may be requested from us at any time.

Place

The Data is processed at our operating offices and in any other places where the parties involved in the processing are located.

Third-Country transfers

Depending on your location, data transfers may involve transferring or processing your Data to a country other than your own. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. For any transfer of data outside the EEA, which are not recognized as providing adequate data protection through an adequacy decision, we will implement and procure appropriate measures and safeguards to ensure that your personal information remains protected and secure in accordance with applicable data protection laws and the EU General Data Protection Regulation.

Mode of obtaining Data

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your basic information including your name and surname, contact information including your email address, social media account, where appropriate, and likes, posts, tweets and other interaction with our social media presence, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a promotion or survey;
  • send complaints or requests; or
  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Usage Data and Technical Data, and generally technical information and online data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
  • analytics providers such as Google analytics.
  • advertising networks.

Retention time

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for longer if we are required to do so based on our regulatory, compliance, or professional indemnity obligations or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised 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, and the applicable legal, regulatory, tax, accounting or other requirements. We may remove your personal information based on our retention policies in compliance with our security standards without further notice or liability. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after removal of your Personal Data.

The purposes of processing

Legal Basis and Purposes for Processing

We may process Personal Data relating to you if one of the following applies:

• You have given your consent for one or more specific purposes;
• provision of Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party and your interests and fundamental rights do not override those interests.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

We set out below, in a table format, a description of all the ways we plan to use your Data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your Data. You may contact us for details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below.

The firm shall not carry out any automated decision-making activities using your personal information.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Change of Purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

The rights of Users

You may exercise certain rights regarding your Data processed by us.

In particular, you have the right to do the following:

• Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
• Object to processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. You have the right to verify the accuracy of your Data and ask for it to be updated or corrected.
• Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your Data. In this case, we will not process your Data for any purpose other than storing it.
• Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Data from us. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Data is required for compliance with law or in connection with claims.
• Receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on your consent, on a contract which you are a part of or on pre-contractual obligations thereof.
• Lodge a complaint. You have the right to bring a claim before your competent data protection authority.
• Automated decisions: You may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

How to exercise these rights

Any requests to exercise your rights can be directed to us through our contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.

Marketing Policy 

We will only process your Personal Data for marketing purposes once we have your consent. You have the right to object where we process your Personal Data for direct marketing purposes. This means you can opt-out from receiving direct marketing from us at any time.

You can opt-out of receiving direct marketing from us at any time.  You can do this by clicking on the “unsubscribe” link included at the end of any marketing email we may send to you, or by contacting us at info@diadikon.com.

You have the right to ask us not to continue to process your personal data for marketing purposes.

Links to third party websites

Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others. The personal data that you provide through these websites is not in any case subject to this Privacy Policy and the treatment of your personal data by such websites is not our responsibility. 

You should consult the other websites’ Privacy Policy notices which will set out how your information is collected and processed when visiting those websites, as we have no control over information that is submitted to, or collected by, these third parties.

Children

We do not knowingly collect information from children or other persons who are under 16 years old. If you are under 16 years old, you may not submit any personal data to us. 

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by uploading the revised policy on this page and possibly within this website. The changes take effect from the date posted on this page and/or our website.

Should the changes affect processing activities performed on the basis of your consent, we shall collect new consent from you, where required.

It is important that the personal data we hold about you is accurate and current. You must keep us informed if your personal data changes during your relationship with us.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

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, including the security measures concerning the operation and use of this website. The Data Controller, unless otherwise specified, is us, Diadikon who operates the Website.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User’s device. See the cookie policy.