Privacy Policy

Table of Contents

Controller of your personal data. 1
Type of Personal Data we collect. 1
How we collect your Personal Data. 2
What are your rights?. 2
Your Obligation to provide Personal Data. 2
Why we collect your personal data?. 3
Ways of Use of Your Personal Data. 3
Children. 5
Retention. 5
Cookies Policy. 5
Sharing of Personal Data. 5
Data transfer outside EEA.. 6
Third party websites. 6
Automated Decision Making. 6
Opt-out Decisions. 6
How you can contact us. 7
Amendments. 7

Cycon Chemicals Ltd respects your privacy and your personal data and is committed to protect them. This policy explains to you how we process and use the personal data we collect and lists, inter alia, your rights and our obligations for such collection, process and use of your personal data and it has been prepared in harmony with the EU General Data Protection Regulation 2016/679 (hereinafter referred to as the “GDPR Regulation”).

We are responsible for ensuring that your data is held securely, that you are given accurate information about how your data is used, and that your rights regarding your data are respected.

1. Controller of your personal data

The controller of the personal data we keep in order to provide to you our services is Cycon Chemicals Ltd with address at 1 Erechthiou, 2413 Engomi, Nicosia Cyprus and number +357 22818498.

2. Type of Personal Data we collect

In case that you are one of visitors or users or registered persons of cycon.com.cy or cycon.gr (together referred to as the ‘Website’) or clients (existed or prospective) or if you make any order or if you apply for a job position through our Website, we may collect your personal data including:

External Data:

Identifying data such as name, surname, professional ID
Behavioural data such as browsing and on-line ordering behaviour, favourite and shopping list, engagement with email and its content
Demographic data such as age group, gender

Financial Data:

Account details such as date of creation, VAT registration, company registration
Transactional details such as bank account, purchase value
Credit details such as credit worthiness, credit records

Social Data:

Professional such as job title, employment and education history
Social network such as connections and friends on social media, shares, comments, bio description
Communication such as written correspondence through email, social media or other media used to assist you once you request for assistance.

Tracking data:

Computer device such as IP address, type of devise
Contact such as email address, telephone number, physical address etc
Location such as country
Consent such as the date and time you provided consent to receiving web push notification for marketing purposes
Website user journey such as navigation via cookies event tracker, date of last visit, interaction with content

Depending on the kind of the service(s) we provide to you we may collect additional personal data.

3. How we collect your Personal Data

Personal data may be obtained by us:

directly from you by filling contact forms and/or through our communication;
from publicly available sources (e.g. the Department of Registrar of Companies and Official Receiver, commercial registers/catalogues, the internet, adverts etc)
from automated technologies such as ……… that aim to assist you when request for it or provide you useful information while browsing our website
from third parties (e.g governmental authorities, financial institutions etc)

4. What are your rights?

According to the GDPR, you, as data subject, have the following rights:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know but you can always ask for additional information and/or clarifications.
The right to access the personal data we hold about you. This means that you can ask us details of your personal data and for a copy of it if this is available.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
The right to erase your personal data (partially or in total), subject to the limitations referred to in the present Policy and/or of any law or regulation.
The right to be informed regarding rectification, erasure or restriction of data processing that affect your personal data.
The right to object to us using your personal data for a particular purpose or purposes subject to the limitations referred to in the present Policy and/or of any law or regulation.
The right to object to processing your personal data for direct marketing and/or automated processing including profiling which is related to direct marketing.
The right to data portability meaning that you can ask to obtain a copy of your personal data in a structured, commonly used and machine readable format. You also have the right to ask for your personal data to be transmitted directly to another data controller in case such transmission is technically feasible.
The right to revoke the consent at any time if we use your personal data based on your written consent. It is clarified that any processing prior to the receipt of such revocation will not be affected.
The right to be notified in case of high risk of data breach which affecting your personal data.

All above rights -except right in paragraph (j) – can be exercised by placing a request in writing as described in the Contact Us section of this Privacy Policy. You can also request clarifications or lodge a complaint against the way we process your personal data.

Upon receiving your request we will respond to your request (free of charge but in case that your request is ‘manifestly unfounded or excessive’ a fee for our administrative costs may be charged) within reasonable time not exceeding one month.

In case we have not complied with your request or you are not satisfied with our response you have the right to lodge a complaint with the Office of the Data Protection Commissioner.

All above rights are limited and subject to the provisions of Regulation (EU) 2016/679 and/or limited and subject to the provisions of the current Privacy Policy.

5. Your Obligation to provide Personal Data

You need to provide us with personal data which are absolutely necessary in order to:

Enable website subscription and provide the appropriate access rights and/or
commence and proceed with a business or employment relationship with you or with the legal entity or body or person for which you are the authorized representative, officer or owner and/or
perform of our contractual obligations and/or
comply with our legal or regulatory or statutory obligations including the money laundering laws which require that we verify your identity before we enter into a contract or a business relationship with you or the legal entity or person for which you are the authorized representative, officer or owner.

We notify you that if you do not provide us with the required data, then we will not be able to commence or continue our business relationship either to you as an individual or as the authorized representative, officer or owner of a legal entity or body or person.

6. Why we collect your personal data?

The main purposes of collecting, processing or transferring your personal data are the following:

To create an account on our Website to access further information or place a pre-order for the delivery of goods;
To perform a business contract: This may include delivery of goods and services, new employment or comply with a legal obligation;
To request marketing to be sent to you;
To enter a conference, competition, promotion or survey;
To make suggestions and recommendations to you about goods or services that may
be of interest to you;
To assist you when you request support;
To use data analytics to improve our website, services, marketing, customer relationships and experience
In case you apply for a job position, to check your professional profile or curriculum vitae (CV)

7. Ways of Use of Your Personal Data

Your personal data may be used for the following purposes:

Performance of a contract

We process personal data in order to provide our services and/or products based on contracts with you including the case where you order a product from our Website or if we receive a relevant customer service request from you or when you register on the Website, but also to be able to complete our procedures including ‘due diligence’ and ‘know your client’ procedure so as to enter into a contract with prospective clients. Please refer to our Terms & Conditions for more information. Please also read our Registration & Account Terms and Conditions which apply to you when you register for an account on our website.

We may also collect personal data of a candidate in order to decide if we are going to enter into an employment contract with him/her and/or in order to commence such employment relationship.

Compliance with legal, regulatory and law enforcement request

We process personal data in order to comply with number of laws, statutory requirements and regulations to which we are subjects including Tax laws and Anti-Money Laundering Laws as amended from time to time.

We hereby inform you that we cooperate and we shall cooperate with government and law enforcement officials and private parties to enforce and comply with the law and/or regulations to which we are subjects. This means that we will disclose – which is kind of process – any information about you and any personal data of you to such government or law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal.

In such case and only if we are legally entitled to notify you, we will take reasonable steps to give a notice to you for the disclosure of your personal data to such third parties as part of legal process.

Safeguarding or servicing legitimate interests

We advise you that we may process personal data so as to safeguard the legitimate interests of us or of any third party. In simple words, legitimate interest is when we have a business or commercial reason to use your data always respecting the principle of proportionality and necessity. For instance, we may collect your personal data in following cases:

To monitor how our Website is used so that we are able to provide a personalized browsing experience, to help us improve the Website to make it more user-friendly and help you find products that could be of interest.
To analyse the performance of product ranges, anticipate market trends and monitor Website behaviour patterns using third party services such as Google Analytics.
To understand customers’ patterns, their needs, the products and services that they are interested in, we analyze ordering histories, browsing histories, customer demographics and market research information.. This helps us to offer an enhanced customer experience and to provide relevant products, personalized services and offers, and to better manage customers’ relationships. It also helps us tailor the marketing that individuals receive in our marketing messages or are shown on our own and other websites, including social media.
When we have a service message we need to send you via email confirming your order or returns or informing you of any changes that might affect your order, our service to you or changes to online ordering terms and conditions.
When you save an item to your Shopping Bag, but don’t check out, we may send you an email service message to remind you that you haven’t checked out.
When providing your personal data for email communication purposes you also consent to us using tracking technologies in the email to make sure the email has been delivered, that you have opened it and to monitor if you have clicked on any of the links. This information helps us to measure the value of our communications and to provide you with relevant content at the right frequency, in compliance with our Retention Policy (see below).
When you use our live chat facility to message and talk to our customer care team we have a legitimate interest to ensure we handle and manage any query you have regarding the products and services we provide.
We may use your data to establish or exercise our legal rights or to defend against any legal claims.

Protection of vital interests

We can process your personal data if it is necessary to protect and service your Vital Interests and/or the Vital Interests of another natural person(s).

Acquisition of data subject consent

We have the right to process your personal data for any reasons other than the reasons referred above provided that you have given us your specific consent for such process. For instance in the below referred cases:

For direct marketing by email including registration to receive news about us;
For online registration for one of our events;
For offering goods and services that may be relevant to you. These can be configured in the settings of your device or browser.

8. Children

The products we sell or promote are aimed at individuals above the age of 18.

We do not knowingly collect or maintain information about persons under 18 years of age. If we learn that information about persons under 18 years of age has been collected on or through the Website, we will take appropriate steps to delete this information. If you are the parent or legal guardian of a child under 18 years of age who has registered for an account or service on our Website, please contact us using the contact information below to have that child’s account or service terminated and personal information deleted.

9. Retention

We will process and/or store your personal data for the duration of our relationship with you, and as long as necessary to fulfill our contractual and legal obligations.

We may keep your data for as long as we are obliged and/or entitled to keep such data in accordance to any law or regulation to which we are subjects and if there is no such law or regulation we will delete your data:

When no longer necessary for the purposes for which that information was collected and processed and/or;
Upon your request or objection to delete data, provided there are no overriding legal grounds requiring maintain that information and/or;
If our collection of information was based on your consent, upon the withdrawal of your consent.

10. Cookies Policy

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Currently we operate an ‘implied consent’ policy which means that we assume you are happy with our use of cookies. If you are not happy, then you should either not use this site, or you should delete our cookies once you have visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)

11. Sharing of Personal Data

As already mentioned herein, we may share certain personal data with third parties if a legal obligation, court or authority order, legitimate public or private interest, contract or consent exists. Some examples are:

Supervisory and other regulatory and public authorities
Our employees and our subsidiary and affiliated companies and their employees
Other firms, management or trust companies, mainly subsidiary or connected companies of us
According to our procedures for combating money laundering and financing of terrorism, the entities that provide information on regulatory compliance
Third-party service providers: We partner with and are supported by service providers. Personal Information will be made available to these parties only when necessary to fulfil the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and other fulfilment and delivery. Our third-party service providers are not permitted to share or use the personal information we make available to them for any other purpose than to provide services to us.
Third parties for legal or financial reasons: We will share personal information that is required to protect our rights, users, systems and services for example external legal consultants, financial auditors and accountants, banking and finance institutions.
Third parties for commercial reasons: We will share personal information directly related to a vendor business in those cases where our company is contractually bind such as MSD Animal Health (https://www.msdprivacy.com/gr/gr/) .
If any of your personal data is acquired by a third party as described in the paragraph above, we will take reasonable steps to ensure that your personal data is safely and legally processed.

12. Data transfer outside EEA

Your personal data may be transferred and/or processed by third parties outside EEA, in countries that European Commission decided that it does not offer an adequate level of data protection.

Where we transfer your information outside of the EEA, in such countries, we have agreements in place with those parties that will receive and process your personal data which include standard data protection clauses approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. Click HERE if you would like to find out more about these safeguards or to receive copy of these standard data protection clauses,

Also, please note that we are working with cloud providers the data processing terms and the privacy policy of which could be found to the following links:

Facebook
Google

13. Third party websites

This privacy policy does not apply to third party websites connected by links on our website. We cannot guarantee that these third parties handle your personal data in a reliable or secure manner. We recommend you read the privacy statements of these websites prior to making use of them.

14. Automated Decision Making

We use automated decision making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

We process your personal data via automated decision making methods in order to assist you while browsing our website.

15. Opt-out Decisions

You can withdraw your consent for direct marketing by sending an email to h.kaponis@cycon.com.cy

You can withdraw your consent for online registration for one of our events by sending an email to h.kaponis@cycon.com.cy and by requesting the deletion of your registration.

The consent for offering goods and services that may be relevant to you can be configured in the settings of your device or browser.

16. How you can contact us

If at any time you have questions about our practices or any of your rights described above, you may reach our Data Protection Officer (“DPO”) and our dedicated team that supports this office by contacting us at h.kaponis@cycon.com.cy

17. Amendments

We are able to change or amend this Privacy Policy from time to time. This could happen, for example, because of law changes, or if we change our business or our practices.

You shall be deemed to have accepted such amendments immediately after their publication in our website. Thus, we encourage that you read our Privacy Policy from time to time.