This Privacy Notice will inform you as to how “PURESSENCE LTD” (hereinafter referred to as the “Company”, “we”, "us", “our” and similar) collects and processes information about you and in particular your personal data and is respecting your privacy. We hereby assure you that this Policy fully respects and complies with the EU Regulation 679/2016 and the relevant Law 125 / I / 2018 of the Republic of Cyprus.
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, indicatively by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Controller means 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.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Regarding the personal data processing in cases we as a company are the Controller, i.e. we determine the purposes and means of the processing, the Controller is the legal person PURESSENCE LTD, address 1 Everest str., Aradippou Industrial zone, 7100 Larnaca, Cyprus, tel: +357 24533878, email: info@puressence.com.cy.
At PURESSENCE LTD, we are committed to and adhering to the following principles of processing personal data in accordance with Article 5 of the Regulation. The personal data are:
Finally, we are able to demonstrate compliance with the aforementioned principles (principle of ‘accountability’).
We as the Controller collect your Personal Data in the following cases:
In addition, it is noted that we process personal data, which third parties, usually legal persons, disclose to us if we have the role of Processor on their behalf. In such case these Legal Persons hold the responsibility to properly inform you.
We do not collect and process minors’ personal data without verifiable parental consent in cases when we are able to control it. For example, it is not possible to control information that is communicated to us online. In any event, if we find that we have collected any personal information from a minor without verifiable parental consent (in accordance with Article 8 of the Regulation), we will immediately delete the information from our records. If you believe we may have collected information from a minor, please contact our company.
The categories of data subjects include:
Kind of Personal Data we may collect about you
Data from the following categories of personal information about you may be collected and processed per case in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:
It is noted that we collect some more kind of personal data about our employees; they are informed throughout documents, manuals, policies and procedures and information internally provided.
Purposes of Processing & the Legal Bases of Data Processing
The processing of personal data is based on one of the "legal bases" as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data).
The legal bases on which the collection and processing of personal data is based (in most of the cases) are, your consent (6.1.a), the compliance in performing our contractual obligations (6.1.b), the compliance with our legal and statutory obligations (6.1.c), and the safeguarding our legitimate interests (6.1.f). For special categories of personal data, the explicit consent (9.2.a), the performance of obligations and the exercise of specific rights of the controller or data subject in the field of labour law and social security / social protection law (9.2.b) and for the assessment of the working capacity of the employee (9.2.h). The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: when you communicate with us in any way directly or indirectly as interested in our services, when you are interested in working to or cooperate with us, when you fill in some of our documents besides those necessary by the institutional framework, when informing you about our services in the context of our promotions, when you make a complaint, when you visit our social media accounts, when you give us your business card.
Commitment to perform our contractual obligations: when you have agreed to receive our services and products, when you are our employee or collaborator, during the payment of our liabilities or when we are contacting you in the framework of a contract.
Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.
Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, for the assessment of persons and situations, and when your icon is recorded in our legal CCTV system.
Our employees are informed about the processing purposes and the legal bases with specific documents internally provided.
We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose.
Data collected on the basis of contractual and legal obligations shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework.
Personal Data included in offers that does not lead to a cooperation agreement is kept for 6 months.
Personal data related to our CCTV System are retained no more than 15 days.
Cookies are stored depending on their categories as you may be informed in our cookies policy linked to the present policy (please see below).
Personal data you disclose to us as candidates are stored for 12 months.
Our Wi-Fi does not store information after disconnection.
Data that may be needed for our legitimate interests as a Controller shall be kept until the reason for storing such data ceases.
Specifically, for the data we process based on your consent, these are kept from obtaining the consent until it is revoked or there is no longer need to store it.
Information that is no longer necessary is safely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for the specific purpose.
How we ensure the security of Personal Data
We have received reasonable organizational and technical measures to protect the personal data we collect, and in particular any specific categories of personal data. We follow international standards and practices to ensure the security of our networks. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in line with the provisions of ISO 27001 Standard (Information Security Management) and in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:
In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.
Some of the security measures we take are not announced for obvious reasons.
To whom the Data may be disclosed
We take measures to ensure that the recipients of personal data are kept to a minimum and only when it is necessary. The personal data we process as Controller are disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully process as the Controller, may be accessed by (or disclosed to) on a case-by-case basis by:
The personal data we collect is processed within the European Economic Area (EEA). We do not transfer as the Controller personal data to third countries or International Organisations.
Your rights as a Data Subject and how you can exercise them
You have the right to be informed, the right of consent if it is the legal basis for the processing, the right of access to your personal data, the rights of rectification and erasure (in cases it is permitted), the right to restriction of processing, the right to data portability, the right to object. If processing is based on your consent you may withdraw it at any time.
The right to be informed is exercised through this privacy and personal data protection notification. In some cases it is also mentioned on documents and forms we are using. You may ask a hard copy of our policy by communicating with us.
The right of consent is been provided to you by design when necessary (when there is no other legal basis related to the collection of information).
We inform you that we are not using software of decision making solely based on automated processing, including profiling.
More specifically, you have the following rights as applicable per case, provided that you will exercise them in writing and after the verification that you are the data subject.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data are being processed as well as other relevant information, and, where that is the case, access to your personal data.
Right of rectification: you have the right of rectification of your inaccurate personal data as well as to have incomplete personal data completed by providing a supplementary statement.
Note: Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process.
Right to erasure (‘right to be forgotten’); we have to positively answer such right when:
We reserve the right to refuse this right if the processing is necessary for compliance with any legal obligation we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according Article 17 § 3, GDPR).
Right to restriction of processing; you have the right to restriction of processing when:
Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and under an explicit request such data to be transferred to both you and another natural or legal person who will process it.
Right to object: you have the right to object to the processing of your data at any time when the reason for the processing relates to direct marketing.
In the event that you make such request in a written or electronic form regarding any of the above rights, we will assess your request and respond within one month of its receipt, either for its satisfaction or to provide you with objective reasons preventing it from being satisfied, or, given the complexity of the request and the number of requests at the given time, request from you an extension of response for a further two months period (according Article 12.3 of the Regulation).
The exercise of your rights is free of charge. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to answer or charge you an administrative fee.
If you are dissatisfied with the use of your data by us, or our response after exercising your rights, you have the right to lodge a complaint with a supervisory authority.
In the event of a breach of the security of the personal data processed, we will take the following measures in accordance with Article 33 and 34 of the Regulation in case we are the Controller and we will:
In the event we are the processor, we will inform the Controller as soon as possible.
Our Website may contain links to other websites that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third-party site. We recommend that you review the Privacy Policy for each site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Please visit our Cookies Policy by clicking here.
Contact details with the National Data Protection Authority
Cyprus Personal Data Protection Authority, 1 Iasonos Street, 1082 Nicosia, telephone +357.22818456, e-mail: commissioner@dataprotection.gov.cy.
Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=celex%3A32016R0679.
If at any time you want to contact with us or to make a request regarding your rights or any other matter relating to the protection of personal data you may contact with our Personal Data Coordinator: address 1 Everest str., Aradippou Industrial zone, 7100 Larnaca, Cyprus, tel: +357 24533878, email: info@puressence.com.cy.
This policy was updated and is effective from October 12, 2021, and will be reviewed when there is a significant change. This review will be available on our website, with a note of the effective date. You may find a hard copy of this policy at our premises or may be dispatched at your request.