| FIXED4U CY LIMITED
FIXED4U CY LIMITED is a private company incorporated in Cyprus. The Company provides professional and reliable smartphone, smartwatch, tablet, laptop and PC repairs as well a wide variety of related accessories for sale at very competitive prices. The Company and its employees often have access to personal data of its customers.
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This Privacy Notice aims to inform and assure you that FIXED4U CY LIMITED (hereby refer to as Company or we) handles your Personal Data (as defined below) with respect to your personality and your rights and in accordance with Regulation (2016/679 (EU) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the Regulation).
This Notice addresses to all natural persons who wish to contract with us or to establish a business relationship, Clients, Client’s authorized representatives, and/or members of another legal entity and/or natural persons who already have a business relationship with us.
Personal Data means any information about you that could identify you directly or indirectly, such as the personal information described in paragraph 2 below.
Processing means any operation or set of operations which is performed on Personal Data, by automated means or otherwise, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Note that this notice addresses all individuals, who are existing clients and potential clients who may maintain other business relationship with the Company and/or clients or individuals that previously had such a business relationship with the Company.
We ask you to read this Privacy Notice carefully as it contains important information on who we are, how and why we collect, store, use and share your Personal Data, your rights in relation to your Personal Data and on how to contact us and the supervisory authorities in the event that you have a complaint.
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| 1. Who we are | Controller:
FIXED4U CY LIMITED Address: 10 Giannou Kranidioti street, Nice Day House, 4th Floor, Office 401, 1065 Nicosia Telephone: +357 22 679809 FAX: + 357 22679816 E-Mail: personaldata@fixed4ucyltd.net
Data Protection Officer:
Harris Kyriakides LLC Address: 115 Faneromenis Avenue, Antouanettas Building, 6031 Larnaca. Telephone: +357 24 201600 FAX: +357 24 201601 E-Mail: personaldata@fixed4ucyltd.net |
| 2. Our sources of collecting Personal Data and the Personal Data we process. | We process Personal Data that you provide to us in the course of our services of device sales and repairs. For this purpose, we process and collect Personal Data that we receive from you and/or the Authorised person appointed from you and/or third parties authorised or instructed by you. We may also collect and process Personal Data from databases and/or sources that are publicly accessible, such as the press, the media and/or third parties in order to enable us to comply with our regulatory obligations. We process Personal Data that we collect lawfully and that we are permitted to process.
Information we collect
a) The Personal Data we collect from our Clients mainly include the following: Name, Surname, Residential City, Email Address (personal), telephone number (home, work or mobile) and photographs of the device given to the Company.
b) Based on our Clients’ consent, the Company may download and hold any and/or all data of the electronic device if it is necessary for the provision of our services.
Please note that the data we collect vary among the different services we provide. |
| 3. The purpose for processing your Personal Data and the legal ground of this processing.
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We collect and process Personal Data in full compliance with the provisions of the Regulation as well as the national legislation.
In the paragraphs below (3.1 to 3.4) there is a more detailed analysis of the purposes and the legal ground of the processing.
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| 3.1 For the performance of a contract (Article 6 (1)(b))
The processing of Personal Data is necessary in order for us to be able to provide our services to you in accordance with our service agreement and/or engagement contact and/or to fulfill your orders and/or to provide you with related services.
The purposes of the processing are adjusted according to the nature of the service provided, such as product sales, device repair with or without a passcode, delivery services etc.
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| 3.2 For the purposes of the legitimate interests pursued by us or by a third party (Article 6 (1)(f))
Except for the above case, either we or third parties, process your Personal Data when necessary, except if your fundamental rights and freedoms override the below interests. Below are some examples:
(A) in court proceedings and/or to claim our legal claims.
(B) in the context of the operation and security of the IT sector of the company.
(C) in the context of preventing and clarifying criminal offenses.
It is noted that the CCTV system established outside our premises aims at providing a safe and secure environment for our employees and Clients and the smooth operation of our Company. |
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| 3.3 Due to your consent (Article 6 (1)(a))
If you give your consent on the processing of your Personal Data for specific purposes, such as for direct marketing purposes, the legal ground for the processing of your Personal Data is your express consent.
Please note that you may at any time withdraw your consent. The validity of this revocation will concern the future. Furthermore, it should be noted that the above also applies if you gave us your consent before 25 May 2018.
Competitions: If you are participating in our competitions, we process your Personal Data in accordance with the Terms and Conditions of the competition announced in our website or social media. We may also process your Personal Data for direct marketing purposes, but only after you have expressly given your consent for that.
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| 3.4 For compliance with a legal obligation (Article 6 (1)(c))
We are subject to various legal obligations, such as the obligations arising from applicable the tax legislation in general, the laws and regulations applicable in the Republic of Cyprus, any directives, rules or guidance issued by the Cyprus Securities and Exchange Commission as well as any regulations issued by a competent organ of the European Union.
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| 4. Who we share your data with |
Within the Company
In the course of the Company’s operation, the relevant employees responsible for the performance of our contractual and legal obligations receive the necessary data.
Moreover, we might share your Personal Data within our Company shops in Cyprus, if this is necessary for the performance of our services and/or to fulfill your orders.
Outside the Company
Under Article 28 of the Regulation, we have the right to designate a processor. In such a case, it is likely that the processor will receive your Personal Data for the above purposes. For example, we might designate as processors, consultancy companies such as IT services, accountants, law firms, recruiters, auditors as well as companies that provide organizing and courier services.
Furthermore, the Company is legally obliged and/or may need to transfer your Personal Data in the course of the provisions of our services to various government and/or semi-governmental authorities and/or services and/or organisations, such as for VAT and/or other applicable tax legislation obligations.
It is possible for us to share your Personal Data to other people/companies/organisations, other than the above, in the course of the provisions of our services to you or if you have given us your express consent for such transfer.
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| 5. How long your Personal Data will be kept for | We will hold your Personal Data defined in paragraph 2(a) above during our contractual relationship. After the termination of our contractual relationship and/or the repair and collection of the electronic device, we hold your Personal Data for up to 3 years, or the period required by any applicable law, or according to the relevant directive of the Commissioner of Personal Data.
We will hold your Personal Data defined in paragraph 2(b) above during our contractual relationship. After the termination of our contractual relationship and/or the repair and collection of the electronic device, we hold your Personal Data for up to 1 month. |
| 6. Transfer of your Personal Data outside the EEA or to an international organization | We may transfer your Personal Data to third parties which are located outside the European Economic Area (EEA), including but not limited to the following (as applicable), only if the transfer is necessary to perform our contractual obligations and/or to fulfill your orders and/or when you have given your express consent:
· To Google Drive, Dropbox;
· To USA based Servers.
In any case, the processors in third countries are obliged to apply the Regulation in the same manner as the companies which are located within the European Economic Area.
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| 7. Keeping your Personal Data secure | We have appropriate security measures in place to prevent Personal Data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine business need to have access to it. Those processing your infromation will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
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| 8. Your rights | You have a number of important rights under the Regulation. Specifically:
(a) right to access your Personal Data (Article 15): meaning you might receive information and/or copy of the Personal Data we hold free of charge.
(b) right to rectification (Article 16): you might ask us to correct any mistakes in your information which we hold.
(c) right to erasure (right to be forgotten) (Article 17): you might ask us to erase the Personal Data concerning you.
However, we reserve the right to deny the erasure, if the processing is necessary for compliance with a legal obligation, for reasons of public interests or for the establishment, exercise or defense of legal claims.
(d) right to restriction of processing (Article 18): you might require us to restrict our processing of your Personal Data if you contest the accuracy of your Personal Data, the lawfulness of the processing, or you have objected to processing (according to article 21, see below) and you wait for our reply whether we have legitimate grounds which override yours.
(e) right to data portability (Article 20): you have the right to request and receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to a third party under certain circumstances.
(f) right to object (Article 21): you have the right to object at any time to processing of Personal Data concerning you which is based on performance of a task carried out in the public interest or for the purposes of the legitimate interest pursued by us or third parties (article 6 (1) (e) and (f) of the Regulation).
(g) You also have the right to object under Article 22 at any time to processing of Personal Data concering you for direct marketing or decisions being taken by automated means which procude legal effects concerning you or similarly significantly affect you.
In case you exercise this right, we shall no longer process your Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claim.
(h) right to withdraw your consent: you reserve the right to withdraw your consent at any time. However, the withdrawal of the consent does not affect the lawfulness of the processing based on consent before its withdrawal.
If you wish to exercise any of the above rights or to ask any questions or clarifications, please do not hesitate to contact us.
If you like to exercise any of those rights, please: · email or write to us or our Data Protection Officer · let us have enough information to indentify you · let us have proof of your identity and address · let us know the information to which your request relates.
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| 9. How to complain | We hope that we can resolve any query or concern you raise about our use of your information.
However, the Regulation also gives you right to logde a complaint with the supervisory authority, the Commissioner of Personal Data Protection. For more information concerning the process of filing a complain please visit the website www.dataprotection.gov.cy/ or via e-mail at commissioner@dataprotection.gov.cy . |
| 10. Are you obliged to provide us with your Personal Data? | You are required to provide your Personal Data to the extent that it is necessary to conclude, perform or terminate our agreement for services and/or contract between us and to fulfill your mandates.
In case you refuse to give us your Personal Data, we will not be able to provide and/or continue to provide our services to you.
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| 11. Automated individual decision-making and profiling | ‘Profiling’ means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, personal preferences, interests, reliability, behaviour, location or movements.
As a rule, the Company does not make automated decisions or profiling. If we make use of automated decision-making or profiling, you will be properly informed if this is necessary on the basis of the relevant legislation. |
| 12. Changes in this privacy notice |
This Privacy Notice was published on 16th of March 2020 and last updated on 2nd April 2020.
We may change this privacy notice from time to time and in such case we will inform you via email.
We also ask you to periodically visit our website for any updates of this privacy notice.
Please contact us, if you have any questions about this privacy notice or the information we hold about you at personaldata@fixed4ucyltd.net.
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