Personal Data Privacy Policy

We take the privacy of your personal data very seriously. Preserving the priceless value of this data and your ability to control it is of the utmost importance to us. Because of this, we want to be transparent about what data we collect, how we collect it, and how we process it to ensure that you are sufficiently informed on its usage so you can make the right choices in all our services and provisions.

We work to gain your trust on a daily basis, around five key areas of collection and usage of personal data:

Control: We provide you with absolute control of processing your personal data in a direct way and with clear choices.

Transparency: Our procedures for the collection and processing of data are completely transparent in order for you to make informed choices.

Legal protection: We comply with all applicable laws and regulations and we treat the legal protection of your personal data as a fundamental human right.

Safety: We protect the data that you trust us with, in the best possible way.

Personalized experience: Personal data collection helps us serve you in a personalize way, by providing you with information, products, provisions and services tailored to your needs and wishes in order to make your experience as good as possible.

In this effort, your contribution is particularly valuable: If you notice something that does not work as expected with regard to the protection of your personal data, please contact us by using the contact information at the end of this policy.

Purpose of the Personal Data Privacy Policy

This Policy explains what kind of personal data we collect from you through our interaction with you, and how we save and process this data.

Personal data we collect

We collect your personal data in order to provide you with personalized services and communication and to provide you with the best possible interaction with us. Some of these data are provided directly from you, such as, for example, when you roam on our website, when you subscribe to our contact list, when you enter in a contract with us or when you contact us for information.

We also collect some data by recording how you interact with our products and services, by using cookies (more on that may be found below). 
We also collect data from third parties, which we protect under this Policy, as well as possible additional restrictions imposed by the provider of these data. These providers may differ over time, but may include the following:

Social networks provided you have granted access to your data located on these networks.

Service providers who help us specify your location based on the IP address.

Widely available data sources, such as free state databases or other free-to-use data.

When we ask you to provide us with your personal data, you have the following two options:

1. To accept
2. To refuse

Under this feature, if you choose not to provide the information necessary for the provision of a service, you will not be able to use it.

The data we collect depends on the general context of your interaction with us, the options you make, including the settings for the protection of your personal data, as well as the services and features that you use. The data we collect may include the following:

Name and contact details:

• Name
• Last name
• Date of birth
• Mobile phone number
• Email and other similar contact information

Tax Information:

• Company name
• Registered office
• VAT number
• Credit/Debit Card Details

Identification Details:

• Passwords and/or similar information used for the safety of your account
• Passport/National ID/Driver’s Licence
• Demographic data:
• Date of birth
• Country/city/region

Preferences/Interests:

• Language
• Favourite products
• Purchasing habits, as well as your interests and favourites that can be deduced or derived from other data we collect

Device and usage data:

In case you browse in our website, we collect data related with your device and the way you interact with us and our products. For example, we collect data regarding the features you use, information of the products you buy, and your browsing on our website. This data includes your commands and interactions through text and other systems we have. This data also includes the settings you choose and the software configuration you use most.

Contacts and Relationships:

Information you provide us regarding your relationships with other registered users of our services.

Location data:

To improve our services with location features, we collect location data of varying degrees of precision. The accurate location data can be data from the Global Navigation Satellite System (GNSS) (e.g. GPS), as well as data from nearby cellphone antennas and Wi-Fi hotspots that we collect when you activate products or features based on location. Inaccurate location data includes the locations resulting from your IP address, data indicating less precisely where you are, such as city or postal code, etc.

Video:

If you visit the offices, or other facilities of the companies associated with LUXELVILLAS or attend any of their events, your image may be recorded by our security cameras.

We also collect the information you provide us and the content of the messages you send to us, such as your comments and reviews about our products or services, or questions and information you provide to our customer service department. Telephone conversations or chat sessions with our representatives may be recorded.

How we use your personal data

LUXEL VILLAS and its associated companies use your data to conduct their business activities, fulfil their contractual obligations and to provide products and services which require the use of personal data, in order to improve and personalize your experience and your interaction with them. Additionally, we may use your data to communicate with you, inform about your account, product information, and more. We do not use the content of emails, conversations, video calls, or your documents, photos or other personal files for targeted advertising.

Communications:

We use your data to communicate with you and to personalize and/or personify this communication. For example, we may contact you by phone or email or by other means of communication to let you know about available security updates, invite you to participate in a survey or event, or to inform you that you need to take certain action in order to keep your account updated. In addition, you can subscribe to our contact list, in order to receive our newsletters and choose whether you want to and how to receive messages and promotional material.

Why we share your personal data:

We share your personal data with your consent or as required to complete any transaction or contractual obligation or to provide any product or service you have requested. For example, we share your data with banks and other institutions which process payment transactions or provide other financial services, when you provide us with, for the payment of a transaction and/or a contractual obligation and/or a service and/or a product, for fraud prevention and to mitigate any credit risk.

In addition, we share your personal information with the Website Owner – associated companies. We also share personal data with our suppliers or external associates, who work on our behalf for the purposes described in this policy, such as companies we have employed for the provision of customer support services or for system protection and to ensure the quality of our services.

In these cases, the companies comply with our company’s Personal Data Privacy Policy and the security requirements we have set, and they do not use the personal data they receive from us for any other purpose. In the context of a corporate transaction, as for example, a merger, we may disclose your personal data.

Finally, we may gain access, transfer, disclose and save your personal data when we believe in good faith that this is necessary for:

1. Compliance with applicable law or to respond to any valid legal procedure,

2. Your and our other customer protection, such as for the avoidance of junk mail, attempt to defraud our website users, or to prevent life loss or the possibility of serious injury, and

3. The protection of the rights or the property of the Website Owner’s members, including the enforcement of the terms governing the use of services. However, if there are reasonable grounds for believing that a registered user is using our services to distribute stolen intellectual or material property of the Website Owner’s members, we will not inspect the private content of that user on our own but we will refer the matter to the appropriate authorities.

Websites and services of third parties:

Periodically, we may use third party services in order to efficiently run some of the processes required to operate the site. The providers of such services have access to certain personal data which are provided by the users of this website.

Any data used by third parties are used only to the extent necessary to perform the services we request. Any use for other purposes is strictly forbidden. In addition, any data processed by third parties will be processed in accordance with the terms of this Personal Data Privacy Policy.

Links to other websites:

Periodically, the Website Owner’s website may provide links to other websites. We have no control over such websites and we do not bear any responsibility for their content and data collection practices. This privacy policy does not extend to the use of such websites by you. We recommend that you read the privacy policy of the other websites before using them.

Alterations of the ownership and control of the company:

From time to time, the Website Owner and its associated companies may expand or reduce their activities and this may result to the sale and/or transfer of their control in whole or in part. The data provided to the Website Owner will be transferred, together with the part relating to any part of the transferred companies, and in accordance with the terms of this Personal Data Privacy Policy, the new owner or the new controlling party will be permitted to use the data for the purposes for which we were originally given.

We may disclose data to a prospective purchaser of the company or any department thereof.

In the above cases, we will take measures to ensure the protection of your privacy.

Your Rights

You may find below a list of your legal rights insofar as your personal data are concerned. Please note that some of these rights may not be applicable to your situation.

• You have the right to gain access to the personal data that we hold about you.
• You have the right of rectification, that is, to request the correction, without undue delay, of any personal data that we hold about you and are either inaccurate or incomplete.
• You have the right to obtain the erasure of your personal data, without undue delay, provided, amongst others, the personal data in question are no longer necessary in relation to the purposes for which they were collected.
• You have the right to restrict our processing activities or to object to the processing of your personal data.
• You have the right to data portability, that is, to request from us that we send your personal data in a structured, commonly used and machine-readable format, and to transmit those data to another controller.
• If we rely on your consent as our legal basis for the processing of your personal data, you have the right to withdraw that consent at any time.

If you wish to exercise any of your above-mentioned rights or have any questions or comments with regard to this Privacy Policy, you may contact us by using the contact information at the end of this policy.

We will respond to requests to access or delete your personal data within 30 days.

Your communication preferences:

You can choose whether you want to receive promotional material from the Website Owner and its associated companies via SMS, Messaging services, Phone or other available means of communication. If you wish, you can be excluded from our contact list at any time by following the instructions contained in the messages you receive, or by getting on touch with us using the contact information at the end of this policy.

Additionally, you may configure your options regarding the receiving of messages through your personal account. These options do not apply to the mandatory service announcements that constitute part of certain of the Website Owner’s services or for the performance of surveys or other informational announcements that have their own subscription cancellation method.

Monitoring according to the browser application

The Website Owner’s website, uses cookies (small text files that are placed to your devices) and similar technologies for web location, e-services and data collection purposes. This website can install and access certain cookies on your computer. Cookies identify your devices in a unique way, but they may also provide other information. The Website Owner has carefully selected these cookies, which do not have access to your computer’s documents and files and has taken steps to ensure that your personal data is as protected as possible.

Use of cookies and similar technologies

Cookies and similar technologies are used for various purposes, such as:

• Saving of your preferences and settings: Your device may save settings that allow our programs to work properly or maintain your preferences over time. We save preferences, such as your contact language, address, etc., so you do not have to import them every time you return to the website. If you choose to be excluded from interest-based promotions, we will save your preference to be excluded in a cookie on your device.
• Safety: We use cookies to detect frauds and possible abuse of our website and our services.
• Saving of the information you provide to a website: When you provide information on the website, we store the data in a cookie to improve your browsing.
• Social media: Our website may include cookies through social media, including those that allow the users who connect to the service of the social media, to share the content through this service.
• Comments: We use cookies that allow you to comment on a website.
• Interest-based promotions: cookies are used to collect data about your website activity and identify your interests, in order to provide you with offers and privileges that interest you. You can be excluded from receiving interest-based promotions at any time.
• Analysis: In order to evaluate our products and services, we use cookies and other identifiers to collect usage and performance data, such as, for example, to count the number of unique visitors to our website and to develop statistical data. This includes cookies from the Website Owner and other associated companies, as well as third-party analysis service providers.
• Performance: we use cookies to balance the load, in order to ensure the correct and continuous operation of the websites.

Cookies

Upon visiting our website, a message will appear asking for your consent in order to keep the cookies used active. By giving your consent to the placement of cookies, you allow the Website Owner and its associated companies to provide you with better experiences and services. If you wish, you may reject the installation of cookies from that moment on. However, certain features of the website may not fully work or work as intended.

This website may install the following generic cookie types:

Furthermore, this website may install the following specific cookies (but not limited to):

Controlling cookies:

Most browsing applications accept cookies automatically but at the same time provide control options that allow you to block or delete them. Through your device’s settings, you have the ability to receive a warning about the use of cookies on specific services, or even not to accept cookies.

Some features of the services provided through the website, depend on cookies. If you choose to block the cookies, you may lose the ability to sign in or use some of these services as well as your preferences which rely on cookies.

Monitoring Protection: By using Internet Browser Options that exclude the content of third-parties, including cookies from any website, you limit the information that the specific third-party websites can collect from you.

You can enable or disable cookies on your web browser application. Most Internet browser applications accept cookies by default, but this can be adjusted. For more details, please consult the Help section of your web browser application.

You can choose to delete cookies at any time. However, you may lose any information that allows you to have quicker and more effective access to the website, including, but not limited to, personalization settings.

It is recommended that you make sure that your internet browser application is updated and consult its help section and instructions provided by your internet browser application developer if you are not sure how to customize your privacy settings.

Where we save and process personal data

Your collected personal data is saved and processed in Cyprus or in any other country or region in which the Website Owner and its associated companies, affiliated companies, subsidiaries or service providers are operating.

We take measures to ensure that the data we collect under this Personal Data Privacy Policy is processed in accordance with the provisions of this Policy and the requirements of the European General Data Protection Regulation (GDPR).

Preservation of personal data by us:

Your personal data is preserved for two years, for the provision of products and services and the processing of transactions you have requested or for as long as required by law for other essential purposes such as the compliance with our legal or tax obligations, resolving disputes and enforcing our contracts. Within the context of these various operations, preservation time may vary considerably.

Changes to this Personal Data Privacy Policy

• This Personal Data Privacy Policy may vary from time to time, reflecting the needs of our customers and our promise of maximum protection and transparency regarding their personal data.
• We will update this Personal Data Privacy Policy whenever necessary by modifying the “last updated” date indicated at the beginning of the Personal Data Privacy Policy.

Unless otherwise stated, the companies associated with the Website Owner are responsible for saving and processing of the personal data collected through the services under this policy.

Contact Information

If you have any concerns, complains or questions regarding our practices around the protection of personal data, please get in touch with us via our contact information found in the footer below. We will respond to questions or concerns within 30 days.

In addition to the above, you also have the right to lodge a complaint to the Office of the Commissioner for Personal Data Protection in Cyprus, at the following postal and email address:

1 Iasonos str., 1082 Nicosia 
P.O.Box 23378, 1682 Nicosia 
Tel: +357 22818456 
Fax: +357 22304565 
Email: [email protected]