This Privacy Policy (“Policy”) sets out the rules of personal data processing and applies when you access and use the website https://malonecyprus.com/ (“Site”), owned and administrated by Malone Cyprus LTD, the company incorporated under the laws of the Republic of Cyprus, with its registration number ΗΕ 423804 and registered address at 79 Spyrou Kyprianou, PROTOPAPAS BUILDING, 2nd floor, 3076, Limassol, Cyprus (“Malone Cyprus”, or “We”, “Us”, “Our”).

We notify you that the Company acts as a controller (Article 4(7) of the GDPR) processing your personal data for the purposes stated in this Policy. Please read this Policy carefully be aware of how your personal data are used by the Company.

The Commay amend and change this Policy at its sole discretion and without notice. It is your sole responsibility to revise this Policy for any amendments and modifications. Your continued usage of the Site after amendments and changes have come into force shall be interpreted as your consent to the revised Policy.

Contact Information

Should you have any questions about this Policy or the Site as a whole, please, do not hesitate to contact us via the interface of the Site or by email address [email protected].

What personal data do We collect from you when you use the Site?

Your Contact data. When you contact Us via the interface of the Site and or via e-mail address available for contacts, you hereby provide Us with the following data:

• Your name;

• Your e-mail address;

• Your message including all the personal data it contains.

Analytics data. We have deployed analytics services, provided by Google and Cloudflare. These services collect various data concerning you. Google Services include Google Analytics, Google Tag Manager, and Google reCAPTCHA.

Google Analytics, is a web analytics service, that helps Us to collect the data concerning your usage of the Site, and, with help of these data, to enhance and develop the Site. Google Analytics collects the following data concerning you:

• Your User-Agent string. It helps to identify which browser is being used, what version, and on which operating system;

• Your IP address;

• The total time you spend on the Site;

• The time you spend on each page and in what order those pages were visited;

• What internal links have been clicked by you (based on the URL of the next pageview);Initial page inspection that analytics.js performs when creating a new tracker object is used to determine your geographic location, what browser and operating system are being used, your device`s screen size and whether flash or java is installed, and the referring website.

If you don’t want to have your data been tracked by Google Analytics, you can install Google Analytics Opt-out Browser Add-on, which provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en.

Google Tag Manager is a tool made by Google that allows Us to integrate and manage tags (snippets of code) into the Website. Google Tag Manager collects the following data:

• Aggregated data about tag firing. This data does not include your IP addresses or any user-specific identifiers that could be associated with a particular individual. Other than data in standard HTTP request logs, all of which are deleted within 14 days of being received, Google Tag Manager does not collect, retain, or share any information concerning you.

Google reCAPTCHA protects the Site from spam and abuse. This tool is primarily used to distinguish whether an input is made by an individual or robot, algorithm, code, or by any other form of automated processing. Google reCAPTCHA collects the following data concerning you:

• The information about your input on the Site.

If you want to find out more about how Google processes your data, please, follow Google`s Privacy Policy https://policies.google.com/privacy.

Сloudflare provides web optimization and security services that We use to improve and protect the Site, including a reverse proxy, pass-through security service. Cloudflare collects the following data concerning you:

• Your IP address;

• System configuration information;

• Other information about traffic to and from the Site.

To find out more about the processing of the data by Cloudflare, please follow Cloudflare`s Privacy Policy https://www.cloudflare.com/privacyStatement/.

How do We use the data collected from you?

We use your Contact data for the following purposes:

• To reply to your message/email and perform actions, which may arise from the context of your message.

We use Analytics data for the following purposes:

• To find out how the Site is used by its audience;

• For research and analysis. For example, We use aggregated data in order to find out which pages of the Site are more likeable, and how the Site is used by visitors of particular gender, geography or age. Having known these data, We will use them to enhance and develop the Site or make it more user-friendly;

• To diagnose any problems/technical failures on the Site or performance of the Site or on the Server, that makes the Site available;

• To have the Site protected from any cyberattacks, threats, abuse, and any other threats and damages;

• To provide you with the full functionality of the Site.

With whom do We share your data?

We share your data with the various recipients. Here you can find the list of them:

Google. (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, D04E5W5, 368047). As described above, we use various Services, provided by Google. Thus, your data may be shared with this recipient.

Cloudflare (Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107 USA). As described above, we use the Services, provided by Cloudflare. Thus, your data will be shared with this recipient.

Personal data transfers to Cloudfare are made on the EU standard contractual clauses, including supplementary measures as necessary.

Our employees. The Site is maintained and operated by a large number of persons. Thus, your data may be disclosed to the employees of Malone Cyprus.

Governmental Authorities. This disclosure will be applied only if the Company is obliged to disclose your data to the Authorities under applicable law.

Contractors and Affiliates of Malone Cyprus. We do our business globally and some of our facilities and business processes may be subcontracted to other business entities (or, simply, companies), natural persons, or organisations. These recipients will process your data in strict compliance with this Policy – this strictness is reached by proper contractual arrangements, signed between Malone Cyprus and these recipients.

How long the data, collected from you, will be retained?

For the data, collected by Google Services – the data shall be stored on Google`s servers for a period of 14 (fourteen) months, starting from the date of your last visit to the Site. Contact data shall be stored as long as required for the particular purpose of the communication.

Protection of children

We do not knowingly process the data about children. If you are a parent or individual that has parental responsibility for a child, that has provided us with his/her personal information, please, contact Us and appropriate measures will be applied by Malone Cyprus.

Your rights

You have several rights, which you may implement by sending a request to our e-mail address [email protected]. These rights are the following:

The right to access (Article of the 15 GDPR). You have the right to receive confirmation from us as to whether your personal data are being processed, as well as to receive a copy of your personal data.

Right to rectification (Article 16 of the GDPR). You have the right to request the rectification of your personal data if the data are inaccurate, as well as the complete the data if the data are incomplete.

Right to erasure (Article 17 of the GDPR). You have the right to request the erasure of your personal data. This right applies if:

Your personal data is no longer required for the purposes for which they were collected;

Personal data are processed unlawfully;

We do not need to store your personal data in order to comply with applicable law;

In other cases where deletion is required or permitted by applicable law.

Right to restriction of the processing (Article 18 of the GDPR). You have the right to request the restriction of the processing of your personal data in the following cases:

If You contest the accuracy of your personal data, we will restrict the processing of such data until we verify their accuracy;

If you object to the processing of personal data based on our legitimate interest, we will restrict the processing of such data until the legitimate interest is confirmed;

If the processing is unlawful, you can object to the deletion of personal data and request the restriction of their use instead;

If we no longer need personal data, but you need it to establish, exercise, or defense legal of legal claims.

Right to object (Article 21 of the GDPR). You have the right to object to the processing of your personal data based on our legitimate interests. We will not continue to process personal data if we are unable to demonstrate the existence of compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

Right to lodge a complaint (Article 77 of the GDPR). You can always contact us with any questions regarding the processing of your personal data. However, if you believe that your rights have been violated, you can file a complaint with the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our registration). Commissioner’s website: http://www.dataprotection.gov.cy.

If you are within the EU, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or place of work. You can find the list of data protection authorities in the EEA at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Cookie Notice

The Site uses cookies. Cookies are small files placed on your device when you visit the Site. The cookies help Us to identify your device, provide you with the full functionality of the Site, and to protect the Site from spam, abuse, and cyberattacks.

Most browsers allow to control and manage the cookies. The “Help” or “Setting” tab in your browser shall provide you with the proper functionality. Here you can find the guidelines for cookie management for the most widely spread types of browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies

Opera: https://help.opera.com/en/latest/web-preferences/

Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies

Internet Explorer: https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer

Safari for Mac: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Cookies used by the Site