1 Introduction

It is very important for us in DIMCO Ltd (hereinafter referred to as the “Company”, “we”, “us” and “our”) the protection of your personal data and privacy when collecting and processing information about you. We hereby assure you that this Privacy and Personal Data Protection Policy (“Policy”) fully respects and complies with EU Regulation 679/2016 (“Regulation”) and the relevant Law 125 / I / 2018 of the Republic of Cyprus.

2 Definitions

• 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, in particular by reference to an identifier such (indicatively) as a name, an identification number, age, address, occupation, marital status, contact details, education, work, 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.

3 The Controller

Regarding the personal data in cases we determine the purposes and means of the processing, the Controller is the legal person DIMCO LTD, address 47 J. Kennedy Av, 1076 Nicosia, Cyprus, tel: +357 77776069, fax: +357 22497192 e-mail: [email protected].

4 Principles we adhere to

At DIMCO 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:

• processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of ‘lawfulness, fairness and transparency’);
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (principle of ‘purpose limitation’);
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of ‘data minimisation’);
• accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (principle of ‘accuracy’);
• kept in a form which permits identification of data subjects for no longer than it is necessary or as required by relevant Laws (principle of ‘storage limitation’);
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (principle of ‘integrity and confidentiality’).

Finally, we are able to demonstrate compliance with the aforementioned principles (principle of ‘accountability’).

5 Collection of Personal Data

We as the Controller collect Personal Data from you in the following cases:

• When you contact us directly or indirectly (e.g. through our webpage, e-shop and/or e-mail, or through our affiliates and collaborators, or through our Social Media pages, etc.), in order to be informed regarding our products and services or ask relevant information;
• If you purchase products and services from us or are involved in events related to the sale of products and services;
• When completing any of our documents in paper or electronic form or when we complete such documents under your suggestions;
• When you cooperate with us or if your data is transmitted to us by third parties – partners under contracts or agreements;
• When you enter our facilities if there is a CCTV system in operation or when you connect to our wireless network via Wi-Fi;
• When you contact us directly, through our website or through ads we have posted on other websites or in the press for a job sending us or posting your CV;
• When you work with us.

In addition, it is noted that we process personal data, which third parties, usually legal entities, disclose to us if we act as Processors on their behalf.

We process personal data for the purposes set out below.

6 Minors’ Personal Data

We do not collect personal information about minors without verifiable parental consent in cases where we can 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), we will delete the information from our records immediately. If you believe we may have collected information from a minor, please contact our company

7 Categories of Data Subjects

The categories of data subjects include:

• Interested persons regarding our products and services and visitors of our infrastructure;
• Clients;
• Third parties involved in events related to the delivery of our services or sale of our products or natural persons that are affiliates or suppliers or employees or collaborators in a legal person cooperating with us;
• Candidates for employment;
• Visitors of our webpage or our social media accounts or those connected in our Wi-Fi;
• Our staff.

8 Kind of Personal Data we may collect about you

Data from the following categories of personal information about you may be collected and processed as described in this Policy:

• Contact information of you or any person you may indicate (name, address, telephone or fax number, e-mail);
• Occupational status information (occupation or job);
• Information related to terms of agreements (yours or persons involved) such us identification data, terms and amounts;
• Payment Information (IBAN or account number, tax identification number, desired payment method, payment terms, deposit details, credit card details);
• Electronic identification data such as the computer’s IP or MAC address;
• Information related to potential accidents and persons involved regarding our legitimate interests;

Information regarding insurance if you are depended person of a staff member;

• Customer history and ratings like satisfaction rate, transaction and purchase details, claims, problems in items, terms as well as information related to assessing persons and situations;
• Social media apps / websites / media data (cookies, username or name, photo, public information and comments when contacting us on social media, or through email attachments);
• Your picture when entering our infrastructure or attending our events, or your photo uploaded on our social media or website under your consent;
• The details mentioned in your CV or any attachments you send to us as candidates.

It is noted that we collect some more kind of personal data about our employees; they are informed through documents, manuals, policies and procedures and information internally provided.

9 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, the consent, the compliance in performing our contractual obligations, the compliance with our legal and statutory obligations, and the safeguarding our legitimate interests. For special categories of personal data, the explicit consent, the performance of obligations and the exercise of specific rights of the controller or data subject in the field of labor law and social security / social protection law and for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment. 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 products and services, when you are interested in working to us or cooperating with us, when you fill in our documents, when informing you about our products and services in the context of our promotions, when you make a complaint or statement or when assessing us, when you have an insurance benefit as a depended person of our employees, when participating in our events, when you visit our social media accounts, when you are connected to our wireless network, when you give us your business card.

Commitment to perform our contractual obligations: when you are our client receiving our products or services directly from us or through our network of affiliates and collaborators, when you are our employee or collaborator in order to serve you and fulfil the terms of the agreement, 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 police, labor law, regulatory, tax, accounting, auditors, judicial authorities and agencies.

Safeguarding our legitimate interests: to improve our services, when you enter our facilities where a CCTV system is operating for security reasons, or when investigating and managing any potential incident or accident, to receive our payment, or for the assessment of persons and situations.

Our employees are informed about the processing purposes and the legal bases under specific documents internally.

10 Retention of Data Period

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 including in offers that does not lead to a cooperation agreement is kept for 12 months.

The personal data in our the CCTV system are retained for 28 days.

Cookies are stored depending on their nature as you may be informed in our cookies policy linked to the present policy (please see below) but still you may erase it according your preferences. IP and MAC address are kept for 60 days.

Personal data you disclose to us as candidates are stored for 12 months.

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 (as an example for marketing), 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.

11 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 special 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 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:

• Our facilities are safe taking reasonable measures.
• Access to personal data is restricted to a limited number of authorised employees under a need to know basis, and the necessary data transfer is done by secure procedures.
• Our employees are bound to confidentiality rules and agreements, with limited classified access to the necessary data only.
• In special categories of data, there is only authorised online access. In hard copy, they are locked in lockers where only authorised persons have access.
• We select trusted collaborators who are bound in writing, in accordance with Article 28 of the Regulation, with the same obligations regarding the protection of personal data. We reserve the right to control them in accordance with Article 28 (3) (h).
• In our ICT systems used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access or other illegal 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.

12 To whom the Data may be disclosed

DIMCO LTD takes every precaution to ensure that the recipients of personal data are kept to a minimum. The personal data we collect are disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully collect as a Controller, may be accessed (or disclosed) on a case-by-case basis by:

• Any relating supervisory authority within its role;
• Any public or judicial authority where required by law or judicial decision;
• Transportation companies delivering ordered products and only regarding the absolutely necessary information in order to ensure proper delivery and the customs officer in the event of delivery of goods by customs;
• The auditor of the company, for necessary data according requirement (financial, employment, contracts and other controls), under confidentiality;
• The legal advisor or advocate of the company, for whatever data is required in legal cases, under confidentiality;
• The Insurance cooperating company in relating cases;
• Banks cooperating with the company, the staff or affiliates and suppliers, only for payment related data;
• The training or systems consultants, the trainer and HRDA (training Authority) for training or systems control issues and only for the necessary pieces of information and data;
• Our ICT systems administrators under specific strong Non-Disclosure Agreements.

The personal data we collect is not transmitted by us to third countries or international organizations.

13 Territorial Scope

The personal data we collect is processed within the European Economic Area (EEA).

14 Your rights as a Data Subject and how you can exercise them

You have the right to be informed, 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.

Your right to be informed is exercised through this privacy and personal data protection notification. In some cases it is also mentioned on documents or forms we are using.

We inform you that we are not using software of decision making solely based on automated processing including profiling.

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 answer such right when:

• your personal data are no longer necessary in relation to the purposes for which we collected it;
• you withdraw your consent on which the processing is based and where there is no other legal basis for the processing;
• your personal data have been unlawfully processed;
• your personal data have to be erased for compliance with a legal obligation we are subject to;
• your personal data have been collected in relation to the offer of information society services;

We reserve the right to refuse this right if the processing is necessary for compliance with 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).

Right to restriction of processing: you have the right to restriction of processing when:

• you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you objected to processing pending the verification whether our legitimate grounds override those of yours.

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, DIMCO Ltd 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 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. Before such complaint, you may contact us if you wish so we can provide you with complete information and support.

15 Personal Data Breach

In the event of a breach of the security and integrity 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:

• Assess it in order to implement the appropriate procedures needed to limit the breach;
• Examine the extent of the breach and the sensitivity of the data included;
• Evaluate the risk and its impact on your rights and freedoms;
• Endeavour to reduce as much as possible the damage that is or may be caused;
• Notify within a time limit of 72 hours of becoming aware of the breach, the National Personal Data Protection Authority, if required;
• Assess the impact on your privacy and take appropriate measures to prevent the repeating of the incident.

In the event we are the processor, we will inform the Controller as soon as possible.

16 Links to other Websites

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.

17 Cookies

By following this link you will be informed on our cookies policy.

18 Contact details with the National Data Protection Authority

Cyprus Personal Data Protection Authority, 1 Iasonos Street, 1082 Nicosia, telephone +357.22818456, e-mail: [email protected].

Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=celex%3A32016R0679

19 Contact with us

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 us DIMCO LTD, address 47 John Kennedy Av, 1076 Nicosia, Cyprus, tel +357 22680286 or +357 77776069, fax +357 22497192, e-mail: [email protected].

20 Policy Update

This policy is effective from May 25, 2018 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 front desk or may be dispatched at your request.