PRIVACY NOTICE
- INTRODUCTION
- Trikomitis Ltd and A. Trikomitis Motors Ltd take data protection seriously. The said companies are private limited liability companies with registration numbers 3614 and 92069 respectively and are based in Larnaca. The company A. Trikomitis Ltd was founded was founded in 1943 in Famagusta and deals with the import and sale of saloon cars, trucks and outboard engines in Cyprus. The company is the exclusive representative of the SUZUKI, HINO and TOHATSU brands, respectively importing cars, trucks, outboard engines and their corresponding accessories and spare parts. In addition, it provides the relevant repair and maintenance services (workshop). The company A. Trikomitis Motors Ltd, was founded in 1998 and deals with the import and sale of cars, motorcycles and helmets. A. Trikomitis Motors Ltd, is the exclusive representative SsangYong Motor, DAF, NZI and SUZUKI for the import of motorcycles (SUZUKI), cars (SsangYong), trucks (DAF), and helmets (NZI) and their accessories and spare parts.
Hereinafter and for the purposes of the present privacy notice, A. Trikomitis Ltd and A. Trikomitis Motors Ltd will be jointly referred to as the “Company”.
The use of the Internet pages of the company is not possible without the provision of some personal data; however, if a Data Subject wishes to use certain services via our website, processing of further personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we will obtain consent from the data subject.
The company complies with the provisions of Regulation (EU) 2016/679 of the European Council and the Council of 27.4.2016 for the protection of individuals against the processing of personal data and for the free movement of such data. Further, for the purposes of effective application of certain provisions of the act of the European Union, the company adopts and implements the Law on the Protection of Natural Persons Against the Processing of Personal Data and the Free Movement of Data Law 125 (I) / 2018 as amended and/or will be amended from time to time.
Personal Data processing shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific legislation applicable the Company. By means of this Privacy Notice, we would like to inform the general public why we collect and process personal data and Data Subjects rights relating to the collection and processing of Personal Data.
- DEFINITIONS:
The data protection notice of the Comapany is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR) but for ease of understanding the following definitions apply.
“Controller”: 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
“Personal data”: 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 as a name, an identification number, location data, 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.
“Data subject”: any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
“Processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“Recipient”: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
“Third Party”: a natural or legal person, public authority, agency or body other than the Data subject, Controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal data.
“Restriction of processing”: the marking of stored personal data with the aim of limiting their processing in the future.
“Processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Profiling”: 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, health, personal preferences, interests, reliability, behaviour, location or movements.
“Consent”: Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
- PURPOSE
As a means to fulfill its obligations under National Law, certain personal data are collected for the better organization of the company as well as for the events it organizes and/or co-organizes, and as well for the facilitation of the company’s relationships with friends, the members of its Board, its employees and associates.
Through this Privacy & Privacy Policy (hereinafter the Policy) the company seeks to explain its practices and policies for the collection, use, processing, transmission and exchange of data and cookies collected and published on the company’s website http://www.ioannisd6.sg-host.com///.
This Policy applies regardless of whether the company’s website is accessible through your personal computer, mobile device or any other technology or device. For any information, you could contact us or the Data Protection Officer.
- CATEGORIES AND USES OF THE DATA WE COLLECT
| No. | Purpose of processing of data | Personal Data | Possible consequences of failure to provide personal data | Legal Basis of Processing |
| 1 | Customer Data Collection | Name, Address, ID number, Car / Truck Registration Processes, Property Title. | Inability to Conclude a Sales Contract | Legal Obligation / Execution of Contract |
- DISCLOSURE OF PERSONAL DATA
- Personal data will not be assigned, disclosed or transmitted to any third party/entity in a manner other than that described in this Policy. However, the company reserves the right to disclose personal information to third parties:
- If we are obligated to disclose or share your personal information in order to comply with any legal or regulatory obligation, to enforce our terms and conditions or to protect the rights, property and security of our customers or third parties.
- To co-operate with law enforcement agencies in law enforcement, as well as in investigating and prosecuting illegal activities such as fraud. We reserve the right to disclose any information about you to law enforcement and other relevant bodies that, in our opinion, is necessary or related to any fraud investigation or other illegal activity.
Specifically, these bodies are:
- Personal Data governing bodies
- Director of the Department of Labor and the Ministry of Labor
- Inspectors
- Police
- Anti-Money Laundering Agencies (AMLs) / Anti-Terrorism Financing Agencies (CTFs)
- Law enforcement agencies
- Finally, we reserve the right to disclose specific personal information to third parties/ independent service providers, or independent contractors who help us maintain our website and provide us with other administrative services. We seek to ensure that these third party / independent service providers will not use your personal data for any purpose other than to provide the services to which they are contractually committed. We also create contracts with these third parties which oblige them to comply with the privacy standards required by law and to use the data only for the purposes for which they were transmitted.
- We will not disclose your personal data to third parties outside the European Union; in countries where there is no appropriate data protection regime. However, in the event that such a data transfer is required, we will take all possible measures to ensure that your data is treated securely as within the EU / EEA and in accordance with this Policy and applicable law. In addition, we will update our present Policy to cover cross-border data transfer and related privacy safeguards.
- FOR HOW LONG DO WE KEEP YOUR DATA
- It is our policy to keep your data only for as long as necessary for the purpose for which it was collected, in accordance with the principles of data minimization and limitation of the storage period. In addition, we align the retention of your data with possible variations arising from the exercise of your privacy rights. However, in some cases, specific personal information may be retained beyond this time due to possible legal obligations, legal interests, historical and scientific reasons, etc. Such cases are possible issues related to:
- Money laundering
- Taxation
- Civil law
- Criminal law
- Labor law
- Any other legal issues
- Historical and Scientific reasons
- THE RIGHTS TO PROTECT YOUR PERSONAL DATA
- At any time, while we maintain or process your data, you retain the following rights and you can submit a request to an employee of the company or to the Data Protection Officer (DPΟ) – (find contact details below):
- The right of Access: Each data subject shall have the right to obtain from the controller, information about his or her personal data stored at any time and a copy of this information. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. When referring to the Company, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
- Right to Rectification: Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to Erasure (Right to be forgotten): Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have an obligation to erase personal data without undue delay where one of the statutory grounds applies, as long as the processing is not necessary
- Right of Restriction of Processing: Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where a statutory reason applies and under certain circumstances.
- Right to Data Portability: Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format.
- Right to Object: Each data subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her.
- Automated individual decision-making, including profiling: Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling.
- Right to Withdraw Consent: Where consent forms the basis for processing, Data Subjects shall have the right to withdraw his or her consent to the processing of his or her personal data at any time. Data Subjects can withdraw consent by logging into the user portal, clicking the privacy link in the menu and then updating the privacy settings as required. Data Subjects can also contact the Data Protection Officer or any other employee to withdraw consent.
- Right to Complain to the Supervisory Authority: Where consent forms the basis for processing, Data Subjects shall have the right to withdraw his or her consent to the processing of his or her personal data at any time. The details of the Supervisory Authority are contained at the bottom of this Privacy Notice.
- Restriction of processing – you have the right to request that the processing of your personal data be restricted and we are obliged to satisfy this request when certain conditions apply
- Right of objection – you have the right to object to the processing of personal data concerning you, under certain conditions
7.2 We will evaluate your request and answer you about its progress (approval of request, partial approval of request, rejection of request) as soon as possible (between 3-4 business days) and definitely within one month from its submission.
In the event that the Company rejects your request regarding the aforementioned Privacy Policy, we will contact you with the reasons for the rejection. You have the right to file a complaint directly with the regulator and the Data Protection Officer (through the means described in paragraph 15 of the current policy).
7.3 We reserve the right to reject requests that are unreasonably repetitive, require disproportionate technical effort or have disproportionate technical consequences, endanger the privacy of others or are impossible to implement.
- UPDATE OF YOUR PERSONAL INFORMATION
8.1 Notwithstanding exceptional cases, you may check, update or delete certain personal information of the Website. However, certain information that is necessary to verify your eligibility, cannot be deleted.
8.2 You can obtain a copy of your personal information through contacting us. For your protection, you will need to prove your identity in order to receive such copies. You should include the necessary information to identify yourself and additional relevant information that will help us in fulfilling your request. We will comply with such requests, unless we have a legal obligation or a legal interest in not deleting the data.
- SECURITY
9.1 The protection of your data is extremely important to the institution and in this regard, we constantly strive to provide all possible means of protection for the protection of your personal data, the restriction of unauthorized access and / or possible changes. These tools include information security measures in line with current best practices for protecting your privacy. These measures include technical and procedural actions and monitoring and detection actions aimed at securing data from misuse, unauthorized access or disclosure, loss, alteration or destruction. Although absolute security cannot be guaranteed, should a Data Subject have a particular concern about a particular method of data transmission, we will take reasonable steps to provide an alternative method.
- COOKIES
10.1 A “cookie” is a small text file that is downloaded to your device when you visit a website and allows the website to obtain certain information from your browser, such as your preferences. This website uses cookies and similar technologies to manage logins, to provide personalized websites and to customize ads and other content to suit your specific needs and interests.
10.2 You may configure your browser to exclude all cookies, including cookies related to our services, or to know when a cookie has been set by us. However, it is important to note that many of our services may not work properly if cookies are disabled. For example, we may not remember your language preferences. Refer to the technical documentation of your browser or mobile device for instructions on how to delete or disable cookies.
10.3 For more information about cookies, how they are used and how they are used in the use of your personal data, please visit www.aboutcookies.org or www.allaboutcookies.org.
- CHANGES IN PERSONAL DATA PROTECTION POLICY
11.1 We strive to continually review and update this Policy in order to comply with legal and regulatory requirements, while providing optimal protection of your personal data. Any update will be notified to you through the current website.
- CONTRACTUAL OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA AND THE POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA
12.1 For clarity, the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject/customer provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded
- AUTOMATED DECISION-MAKING & PROFILING
We do not process personal data for automatic decision-making or profiling.
- GENERAL
You may not transfer any of your rights under this privacy notice to any other person. We may transfer our rights under this privacy notice where we reasonably believe your rights will not be affected.
If any court or competent authority finds that any provision of this privacy notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy notice will not be affected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This notice will be governed by and interpreted according to the law of the Republic of Cyprus. All disputes arising under the notice will be subject to the exclusive jurisdiction of the Cyprus Courts.
- CONTACT US
If you believe that we do not comply with the provisions of this Policy or any other matter relating to data protection at any time, please contact us by e-mail at poliviatricomiti@gmail.com / a.tricomitis@cytanet.com.cy .
We inform you that the Data Protection Officer is Polyvia Trikomiti.
15.1 NAME AND ADDRESS OF THE CONTROLLER:
The Controller is: A. Trikomitis Ltd/ A.Trikomitis Motors Ltd
Email: a.tricomitis@cytanet.com.cy
Website: http://www.ioannisd6.sg-host.com///
15.2 NAME AND ADDRESS OF THE DATA PROTECTION OFFICER:
The Data Protection Officer of the Controller is: Polyvia Trikomiti
Data Protection Officer,
Email: poliviatricomiti@gmail.com
A Data Subject may contact our Data Protection Officer directly with any enquiries relating to Data Protection.
- CONTACT DETAILS OF THE LEAD SUPERVISORY AUTHORITY:
The Lead Supervisory Authority overseeing the Controller is:
Office of the Commissioner for Personal Data,
Email: commissioner@dataprotection.gov.cy
Tel. No.: +357 22818456
Website: http://www.dataprotection.gov.cy
- CHANGES TO THIS PRIVACY NOTICE
This privacy notice was last updated on 23/12/2021. We may change this policy by updating this page to reflect changes in the law or our privacy practices. However, we will not use your Personal Data in any new ways without your consent.
