Privacy Policy

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of this Website.  This Privacy Policy sets out the basis by which Bernaretaro Limited, a company organized and existing under the laws of the Republic of Cyprus, with registration number HE447504  processes personal information that we collect from you or that you will provide to us.

Please read the policy below carefully before using the Website. By using or visiting any part of the Website, you are deemed to have agreed and accepted the terms and conditions of this Privacy Policy. If you do not agree to accept and be bound by this Privacy Policy or any amendment thereto, then please discontinue the use of the Website.

1.     Amendment or Changes to the Policy

We reserve the right, at any time, to amend this Privacy Policy. Any such change shall be binding and effective immediately upon posting of the changes on the Website.

2.     Personal Data Collection

We collect your personal information that can help us identify you. This information may include, but is not limited to:

a.     The information you provide us when you contact us through the “Contact Us” form; or

b.     When you apply for a job opportunity in our “Careers” section, we collect the data you provide us and further information, data or documents that you may be asked to provide during the recruitment process.

3.     Disclosure on Use of Your Information

We use, store, and process the information we collect from you, to:

a.      Contact you in relation to our products or services;

b.      Carry out certain profiling of you and your activity on the Website in order to personalise, measure, and improve our marketing and to send you more relevant marketing communications.  We will process your personal information to undertake marketing activities to offer you products or services that may be of your interest. You can always opt out of receiving marketing communications from us by following the unsubscribe instructions included in each of our marketing communications.

c.      We use, store, and process the information to carry out the recruitment process in order to take steps to possibly enter a contract and for future job opportunities.

d.      Comply with a legal obligation to which we are subject to under applicable laws and regulations.

4.    Storage of Personal Data

We store your personal data in a secure and updated system of data storage and management. This system allows the supply, on request, of details of the data held and maintains a record of how it has been used.

The data is processed in a manner that ensures the appropriate security of personal data.

5.    Sharing of Personal Information

We may share and disclose your personal data as provided below.  However, we will not transmit your information to any third party outside of the Group other than what is provided herein.

a.      We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against us, (iii) to respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability.

b.     We can use third-party service providers to help us provide services related to the Website and the payment services. Service providers may be located inside or outside of the European Economic Area (“EEA”).  These providers have limited access to your information and are contractually bound to protect and to use it on our behalf only for the purposes for which it was disclosed and consistent with this Privacy Policy.  You can always contact us to receive the full list of our service providers which process your data.

c.      We may share your information, including personal information, to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

d.     We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

6.     Your Rights

As a data subject, you have several rights in relation to your personal information that we process, these are detailed below.

We will ask you to verify your identity before proceeding with any request under this privacy policy; this is in order to protect the confidentiality of your information. If you need to contact us in relation to any request you wish to make under your data subject rights, you can do so by emailing or writing to our Data Protection Officer (contact details are within this Policy). Please note any third party you use to submit a request on your behalf will have to prove and verify they are acting on your behalf.

A. RIGHT TO BE INFORMED. As a data subject, you have the right to be informed that your personal data will be, are being, or were collected and processed.

B. RIGHT TO ACCESS. You have the right to request a copy of the personal information we hold about you. If you would like to request a copy of the personal information you should contact our Data Protection Officer. We will ask you to verify your identity before proceeding with any request under this privacy policy.

C. RIGHT TO OBJECT. You have the right to object to the processing of your personal data which is processed based on our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims. Your request will be looked at and where we can comply with the request we will, if we take the decision not to comply with the request, we will explain this to you in writing.

D. RIGHT TO ERASURE. You have the right to have your personal information erased, if:

1. The personal information is no longer necessary for the purpose which we originally collected or processed it for;

2. You gave your consent to the processing in the first place and you withdraw your consent and we have no other legal basis to rely upon to process the information;

Your request will be looked at and where we can erase the personal information requested. However, this right only applies in certain circumstances; it is not a guaranteed or absolute right. If, however, we take the decision not to comply with the request as we have a lawful basis to continue the processing, we will explain this to you in writing.

E. RIGHT TO RECTIFICATION. You can request us to rectify and correct any personal information we hold about you. If, however, we take the decision not to make the change you have requested, we will explain this to you in writing.

F. RIGHT TO RESTRICT PROCESSING. You have the right to restrict the processing of your personal information in certain circumstances. Where we suspend our processing of your personal data, we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions. Your request will be looked at and where we can comply with the request we will and for the duration of the restriction time scale you have indicated, if however, we take the decision not to comply with the request, we will explain this to you in writing.

G. RIGHT TO DATA PORTABILITY. The right to data portability allows you to obtain the personal data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format that enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by us directly to the other organisation if this is technically feasible.

H. RIGHT TO WITHDRAW CONSENT. You have the right to withdraw consent of us processing your personal data where we requested your consent to do so. You may opt-out of marketing communications by visiting your account page and un-ticking the received communications from our box or by contacting us via the relevant services.

I. RIGHT TO COMPLAINT. You are entitled to lodge a complaint with the local supervisory authority, which is the Office of the Data Protection Commissioner in the Republic of Cyprus (the “Commissioner”) in case you are not satisfied with the manner we process your personal data. You may find the Commissioner’s contact details here.

7.  Transfer of your Personal Data

To facilitate our global operations, we may transfer, store, and process your information within our family of companies or share it with service providers based outside Europe for the purposes described in this Privacy Policy.

If we transfer your Personal Data outside of the EEA, within the group or to our business partners, we will take all reasonable steps to ensure that adequate measures are in place to keep your personal data as secure as it is within the EEA and in accordance with this Privacy Policy, by relying on the use of standard contractual clauses or binding corporate rules or any other acceptable method that ensures protection of your data to the standard required within the EEA.

8. How long do we keep your personal data?

We can only keep the data we collect from you for so long as it is necessary forone of the purposes listed above. Accordingly, your personal data will be retained in accordance with the appropriate retention period for each category of data and in strict compliance with applicable law. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes. In particular, where we collect your data to:

1. evaluate your application to work with us, your personal data shall, subject to any further lawful processing (including, without limitation, your consent to us to retain such information, and/or requirement to retain personal information for compliance with a legal requirement to which we are subject to), be securely deleted or destroyed following an unsuccessful application for employment; and
   
2. satisfy a request relating to the Website that you have filed with us (i.e. where you subscribed with us to receive newsletters and updates published on the Website), your personal data shall, subject to any further lawful processing (including, without limitation, your consent to us to retain such information, and/or where we have a legitimate interest to do so), be retained until you withdraw the consent you have provided us with.

9.   Leak of Personal Data

No data transmission can be entirely secured and guaranteed. Notwithstanding any measures we take to protect your personal data, we cannot guarantee that:

a. such security measures will prevent our computers from being accessed illegally, and

b. the personal data on them being stolen, misused, or altered.

You remain solely responsible for the security of your computer and device at all times and we may not have any responsibility whatsoever for destruction or inappropriate disclosure of personal data. For your own protection, you are strongly encouraged to:

a. virus-check the device you are using to access our Website and

b. avoid posting or providing to us via the Website, any data you believe may contain a virus.

10. Links to other websites

The Website may include links to other internet sites. Such sites are beyond our control and we assume no responsibility for the content and privacy practices of any such sites. You acknowledge and agree that your linking to other sites, use of such sites, and use of any information, material, products and services offered and/or provided by such sites, is solely and exclusively at your own risk. Consequently, the information practices of third party websites are not covered by this Privacy Policy.

11. Contact Us

If you have questions about this Policy or our information handling practices, you can contact us by emailing us at info@bernaretero.com or online through our website “Contact Us” form.