Privacy Policy

1. PURPOSE OF THIS POLICY

This policy describes how We Are Digidal Creative Media (“We”), member of MDA Digidal Creative Ltd, collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the Cyprus (‘Data Protection Legislation’).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. ABOUT US

We are a company that provides marketing services for businesses. We are registered in Cyprus as a Limited Company under number HE424853. Our registered office is 5.Genadiou Scholariou,Mesa Geitonia, 4003 Limassol Cyprus

For the purpose of the Data Protection Legislation and this policy, We are the ‘data controller’. This means that We are responsible for deciding how We hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy policy.

We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy policy or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example, when:

• you request a proposal from us in respect of the services We provide;
• you or your employer or our client engages us to provide our services and also during the provision of those services
• you contact us by email, telephone, post or social media (for example, when you have a query about our services); or
• from third parties and/or publicly available resources (for example, from your employer or from Companies House or from HM Customs and Excise).
• from advisers who are acting or previously acted for you, your employer or our client.

4.The information We hold about you may include the following:

We obtain personal data about you, for example, when:

• your personal details (such as your name and/or address, date of birth and contact information) which are necessary for us to provide services agreed with you, your employer or our client;
• details of contact We have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you including information about any enquiries and complaints you make to us;
• information from research, surveys, and marketing activities;
• information We receive from other sources, such as publicly available information, information provided by your employer or our client or Government Agencies.

5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with you or your employer or our client and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our client. This may include processing your personal data where you are an employee, subcontractor, supplier, customer or shareholder of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances, where your consent is required for the processing of your personal data, then you have the right to withdraw your consent to processing for such specific purposes.

Please note that We may process your personal data for more than one lawful basis depending on the specific purpose for which We are using your data.

Situations in which We will use your personal data

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you or your employer or our clients and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier, customer or shareholder of our client;
• provide you with information related to our services and our events and activities that you request from us or which We feel may interest you, provided you have consented to be contacted for such purposes;
• seek your thoughts and opinions on the services We provide;
• and notify you about any changes to our services.

In some circumstances, We may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case We may use it without further notice to you.

If you refuse to provide us with certain information when requested, We may not be able to perform the contract We have entered into with you. Alternatively, We may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this policy, where We are legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, We take into consideration:

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which We originally collected the personal data;
• the lawful grounds on which We based our processing;
• the types of personal data We have collected;
• the amount and categories of your personal data;
• and whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where We need to use your personal data for another reason, other than for the purpose for which We collected it, We will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, We will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. DATA SHARING

Why might you share my personal data with third parties?

We will share your personal data with third parties where We are required by law, where it is necessary to administer the relationship between us, or where We have another legitimate interest in doing so.

Which third-party service providers process my personal data?

Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, marketing services and banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

7. TRANSFERRING PERSONAL DATA WITHIN EUROPEAN ECONOMIC AREA (EEA)

We may transfer the personal data We collect about you to a country within EU in order to perform our contract with you.

Where there is not an adequacy decision by the European Commission in relation to that country they will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.

We have put in place the following measure to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation, as follows:

• We check that Sub-contractors or Sub-processors of your data, who may hold that data within EU.

Should you require further information about this, please contact us using the contact details outlined below.

8. DATA SECURITY

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where We are legally required to do so.

9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal data We hold about you is accurate and current. Should your personal information change, please notify us of any changes of which We need to be made aware by contacting us, using your usual point on contact with us.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

1. Request access to your personal data. This enables you to receive details of the personal data We hold about you and to check that We are processing it lawfully.
2. Request correction of the personal data that We hold about you.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
4. Object to processing of your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where We are processing your personal information for direct marketing purposes.
5. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our data protection point of contact at [email protected]
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, We may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it

10. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact at [email protected]

Once We have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless We have another legitimate basis for doing so in law.

11. CHANGES TO THIS POLICY

Any changes We may make to our privacy policy in the future will be updated on our website at: www.digdalcreative.media/privacy-policy/

This privacy policy was last updated on December 2023.

12. CONTACT US

If you have any questions regarding this policy or if you would like to speak to us about the manner in which We process your personal data, please either email our Data Protection Point of Contact at [email protected] or telephone on +357 99334537

Cookie Policy

This policy is designed to provide you with information about our use of cookies.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart, or make use of e-billing services.
• Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.
• Functionality cookies: These are used to recognize you when you return to our website, enabling us to personalize our content for you and remember your preferences.
• Targeting cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests.

You can find more information about some of the individual cookies we use and the purposes for which we use them below:

Google Analytics

Cookie: _gid, _ga

Purpose: These cookies collect information about how visitors use our site to help us improve the site. The information is collected in an anonymous form.

More information: Opt out of being tracked by Google Analytics

Digidal Creative Media site cookie acceptance

Cookie: mfn-gdpr

Purpose: This cookie is used to record if a user has accepted the use of cookies on our website.

More information: To withdraw your consent after accepting this cookie, delete the cookie.

LiveChat cookies

Cookie: AASID, __lc_cid, __lc_cst, __oauth_redirect_detector

Purpose: These cookies allow us to see if you are a returning visitor and to maintain your chat history with us as you navigate through the website. You do not have to engage with our live chat box at any point.

More information: LiveChat Security

Please note that third parties may also use cookies, over which we have no control. Check relevant third-party websites for more information about their cookies and how to manage them.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after you close your browser or clear your cache.