Last update: May 24, 2018
The following statement describes the overall Policies and practices of CyprusNet, including advertising on our network of websites, as well as across other internal websites, and products and services that are offered by the CyprusNet.
Links to other websites
cyprusfree.com website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website unless it is one belonging to our network. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
INFORMATION COLLECTED BY CYPRUSNET
Non-Personally Identifiable Consumer Data
CyprusNet delivers advertisements across multiple channels and media, including to web surfers who visit any of the hundreds of websites that are a part of CyprusNet's network. With respect to individuals who visit those websites, we collect what is known as 'Click Stream Data.' Click Stream Data is anonymous in respect to the fact whether the web surfer is logged in or not, and includes information such as a web surfer's IP address, the type of the page where the clcik action occured, date and time when an advertisement delivered by our website has been viewed or has been interacted with by a web surfer.
In addition to the Click Stream Data collected across our network, CyprusNet owns numerous websites and services where collecting of extra non-personally identifiable data may be a requirement in order to fulfill a business purpose.
As a part of the registration process at these websites, we may request and collect additional non-personally identifiable information about the visitor. Examples of the non-personally identifiable data that may be requested include age, gender, and interests. None of the foregoing information (collectively referred to as 'non-personally identifiable data'), by itself, or together, can by its nature be tracked to a specific individual.
Personally-Identifiable Consumer Data
At some of the websites owned and operated by CyprusNet we ask people to register and provide personally-identifiable data. CyprusNet is committed to making sure that clear notice and choice is provided to all consumers before the personally-identifiable data is collected, and that they have opted-in to our use of their data. Examples of personally-identifiable data that may be requested include name, address, and e-mail address. Web surfers who have provided personally identifiable data may elect to have their data deleted from our files, or kept from being used for purposes other than for the service requested, by following the Data Opt-Out procedures set forth below.
Other Information That Is Collected
At some websites, including this one, CyprusNet collects information on individuals and companies who want to enter into business relationships with CyprusNet ('business information').
We maintain business information for purposes of administering the program, such as maintaining account information, sending payments, etc. We may share business information with third-parties who provide administrative services (and they are required to maintain the confidentiality of the information), as well as law enforcement or government officials as we deem necessary or appropriate.
HOW COLLECTED INFORMATION IS USED
First of all we are not selling any personally identifiable or not identifiable data.
The non-personally identifiable data that CyprusNet collects is used for marketing and sales efforts to better target advertisements and other content to individuals in an effort to create a personally relevant experience for each person. The data is also used to predict responses to advertisements, and to help determine which ads perform best and which content is most appropriate for different individuals.
If a consumer elects to provide CyprusNet with personally-identifiable data, we may utilize such data for marketing purposes. In such situations we are going to additionally request, that data may be combined with information collected from other sources to assist with targeting ads to that consumer's preferences and behaviors, and for other CyprusNet sales and marketing efforts.
cyprusfree.com may collect and use User's personal information for the following purposes:
- IP address of the web surfer visiting our advertisers' websites through our website may be used and shared with our respective advertiser for statistical purposes.
- To improve customer service.
- Information you provide helps us respond to your customer service requests and support needs more efficiently.
- To personalize user experience.
Other data controllers the company works with:
- Google - Through Google's AdSense Platform
- Google - Through Google Analytics Platform
We do not share your personal data we hold with none of the external controllers. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller.
A description of what personal data the company processes and for what purposes is set out in this Privacy Notice.
The company will process some or all of the following personal data where necessary to perform its tasks:
- Names, titles, and aliases;
- Contact details such as telephone numbers, addresses, map location, and email addresses;
Where they are relevant to the services provided by a company, or where you provide them to us, we may process information such as gender, age, marital status and nationality;
Where you pay for activities or services, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
Do we need your consent to process your sensitive personal data?
In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
We strive to make sure that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
We use your personal data for some (or all, where relevant) of the following purposes:
- To deliver services including providing spend management solutions; spend control, data analysis, data reporting.
- To understand your needs to provide the services that you request and to understand what we can do for you and inform you of other relevant services;
- To confirm your identity to provide some services;
- To contact you by post, email, telephone or using social media (e.g., Intercom, Facebook, Twitter);
- To help us to build up a picture of how we are performing;
- To enable us to meet all legal and statutory obligations and powers including any delegated functions;
- To maintain our own accounts and records;
- To seek your views, opinions or comments;
- To notify you of changes to our facilities, services, events and staff;
- To send you communications which you have requested and that may be of interest to you. These may include information about new projects or initiatives;
- To allow the statistical analysis of data so we can plan the provision of services.
What is the legal basis for processing your personal data?
The company has certain powers and obligations. Your personal-dentifiable data is processed for compliance with a legal obligation which includes the discharge of the company’s statutory functions and powers. We will always take into account your interests and rights. This Privacy Notice sets out your rights and the company’s obligations to you.
- We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
- Sometimes the use of your personal data requires your consent. We will always first obtain your consent to that use.
- We may use information to understand how our Users as a group use the services and resources provided on our Site.
- To improve our Site.
- We may use feedback you provide to improve our products and services.
- To send periodic emails.
- We may use the email address to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated statistical information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data.
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations. The company is permitted to retain data in order to defend or pursue claims. In some cases the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
Your rights and your personal data
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
You have the following rights with respect to your personal data:
- The right to access personal data we hold on you
- At any point you can contact us to request the personal data we hold on you as well enquire as why we have that personal data, who has access to the personal data and where we obtained the personal data from.
- There are no fees or charges but requests which are manifestly unfounded or excessive may be subject to an administrative fee.
- The right to correct and update the personal data we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your personal data erased. If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
- The right to object to processing of your personal data or to restrict it to certain purposes only
- You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
- The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within 30 days of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
- You can withdraw your consent easily by telephone, email, by post (see Contact page) or from the relevant website's withdrawal functionality where such option is in place.
When we receive your request to delete your data we will pursue your request with undue delay. In some situations where is not clear whether the personal data can be deleted whitout breaching any existing law or if there will not be any lawfully reason for not deleting your data we will proceed to delete the data as per your request and we will confirm you that your data has been deleted or the reason why it cannot be deleted (for example because we need it to comply with a legal obligation).
Like many other websites, cyprusfree.com makes use of log files. The information inside the log files includes internet protocol ( IP ) addresses, type of browser, Internet Service Provider ( ISP ), date/time stamp, referring/exit pages, and number of clicks to analyze trends, administer the site, track user 's movement around the site, and gather demographic information.
Cookies and Web Beacons
What is a Cookie?
Google's use of advertising cookies enables it and its partners to serve ads to your users based on their visit to your sites and/or other sites on the Internet.
Our users may opt out of personalized advertising by visiting Ads Settings.
DoubleClick DART Cookie
- Google's use of the DART cookie enables it to serve ads to users based on their visit to a specific website.
- DART uses "non personally identifiable information". It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers.
cyprusfree.com has no access to or control over these cookies that are used by third-party advertisers.
If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites.
We use third-party advertising companies to serve ads when you visit our Web site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see here.
SHARING WITH THIRD-PARTIES
All personally-identifiable data provided by individuals is maintained in strict confidence by CyprusNet and will be treated with the same level of respect and care that CyprusNet treats its other proprietary information and trade secrets. There are instances, however, in which personally-identifiable and non-personally identifiable information is shared with third-parties, as described below.
The non-personally identifiable data may be shared with third-party partners of CyprusNet on an anonymous basis.
With respect to personally-identifiable information, CyprusNet may, from time to time, provide information to certain third-party administrative vendors for efficiency purposes in providing administrative services such as billing, delivery and pay-outs, or for other services related to providing a CyprusNet product or service. Any third-party vendor so used will be required to enter into a confidentiality and non-disclosure agreement with CyprusNet upon terms and conditions consistent with the policies set forth herein.
CyprusNet may also share personally-identifiable information with third-parties who enter into business relationships with us. These business partners may include financial service providers (including credit bureaus and insurance agents); non-financial companies (including retailers, online and offline advertisers, membership list vendors, direct marketers and publishers); companies that perform marketing services on our behalf, and others such as non-profit organizations. We may also disclose information to a third-party who provides substantially similar services as the original service signed up for, if we decide to stop providing such services ourselves. In such situations, we will provide our subscribers with an opportunity to opt-out of such sharing. Please be aware that CyprusNet is very careful about which companies it does business with.
In addition to the above, there is also the possibility that CyprusNet, or part(s) of the company, may one day be purchased by, or merged with, another company. If that's the case, the acquiring (or merging) company will have access to your information.
Finally, CyprusNet may share information on individuals as it deems necessary to comply and cooperate with government and law enforcement officials.
CyprusNet makes every effort to maintain the security of its network and the data we collect. We use state-of-the-art technology, including encryption, to ensure the highest security standards. Any data that is stored on CyprusNet's servers is treated as proprietary and confidential and is not available to the public. Nevertheless, there are certain services that will give access of data to the public. These include, but are not limited to job postings, personal resumes and other personal data that you voluntarily choose to publish on our websites. On such situations we strive to prompt you about security implications of your decisions and where possible ask your consent for proceeding to such actions. Whenever our users or customers voluntarily choose to use our services that are making their data public on our websites, CyprusNet is not responsible or liable for any physical, material or non-material damage to natural persons such as loss of control over their personal data or limitation of their rights, discrimination, identity theft or fraud, financial loss, unauthorized reversal of pseudonymization, integrity and availability, damage to reputation, loss of confidentiality of personal data protected by professional secrecy or any other significant economic or social disadvantage to the natural person concerned.
CyprusNet has a strict internal security policy with respect to the confidentiality of customer and other data, limiting access only to those employees who have a need to know such information for the purpose of effectively delivering CyprusNet's products and services. Please keep in mind, however, that the Internet is not a 100% secure medium. Therefore, although we use industry standards to protect information, the possibility of somebody defeating our security measures does exist.
Access to Data
CyprusNet allows consumers who have voluntarily provided personally-identifiable data, access to their data to ensure that it is correct and to make any changes. Please contact us at firstname.lastname@example.org.
CyprusNet is committed to helping protect consumer privacy on the internet and actively monitors consumer privacy issues.
CyprusNet in its capacity as an advertising network may link and use information and material from websites found in the World Wide Web without the permission of the website owner. If however website owners do not wish to be advertised or listed in the Cyprus Network they should contact us and we shall immediately remove any links, logos, banners or other information and content related to their website.
Governing Law/Forum Selection
All matters relating to your access to and use of the site shall be governed by and construed in accordance with the laws of the Republic of Cyprus and the parties submit to the exclusive jurisdiction of the Cypriot Courts.
For more information, or if you have questions or concerns regarding CyprusNet privacy practices, please send us an e-mail at email@example.com.