PRODUCTS & OTHER WEBSITES PRIVACY POLICY

This Site is owned, operated and maintained by C.A. Papaellinas Ltd("CAP"). At CAP, we recognize that visitors to our Sites may be concernedabout the information they provide and how we treat that information. ThisPrivacy Policy addresses those concerns. We are committed tosafeguarding your privacy and handling your data in an open andtransparent manner. Looking after the personal data you share with us isof hugely important to us. We may update the Privacy Policy from time totime, so please check in occasionally.

What this Policy Covers

We are committed in doing the right thing when it comes to your personaldate and that’s why we‘ve developed this privacy and cookies policy(“Policy”), which:

• sets out the types of personal data that we collect
• explains how and why collect and use your personal data
• explains when and why we share personal data within the C.A.Papaellinas Group and with other organizations; and
• explains the rights and choices you have when it comes to yourpersonal data

What types of personal data do we collect

If you choose to contact us, we will ask you for some personal informationabout you, as well as some optional information about your use of ourProducts. The main purposes for which we use your personal information are:

• to communicate with you in a personal way, such as responding toyour feedback or service requests and register and settle complaints;
• to perform market research to understand your needs and improveour business;
• to comply with legal obligations.

In addition, when you visit our website, we may obtain certain informationby automated means, such as cookies, web server logs, web beacons, andother technologies. A “cookie” is a text file that websites send to a visitor’scomputer or other Internet-connected device to uniquely identify thevisitor’s browser or to store information or settings in the browser. A “webbeacon,” also known as an Internet tag, pixel tag or clear GIF, links webpages to web servers and cookies and may be used to transmitinformation collected through cookies back to a web server. Additionaldata may be collected though Google Analytics. More information about cookies is provided further below under “Cookies and other similartechnologies”.

We may use these automated technologies on our website to collectinformation about your equipment, browsing actions, and usage patterns.The information we obtain in this manner may include your device IPaddress, identifiers associated with your devices, types of devicesconnected to our website or mobile applications, web browsercharacteristics, device characteristics, language preferences, referring/exitpages, clickstream data, and dates and times of visits to our website ormobile applications. These technologies help us (1)remember yourinformation so you do not have to re-enter it; (2) track and understandhow you use and interact with our website or mobile applications; (3) tailorthe website around your preferences; (4) measure the usability of ourwebsite or mobile applications and the effectiveness of ourcommunications; and (5) otherwise manage and enhance our services,and help ensure they are working properly.

Your browser may tell you how to be notified when you receive certaintypes of cookies or how to restrict or disable certain types of cookies.Please note, however, that without cookies you may not be able to use allthe features of our website. For mobile devices, you can manage how yourdevice and browser share certain device data by adjusting the privacy andsecurity settings on your mobile device.

In addition, you may connect with CAP or one of its websites throughsocial networking websites, such as Facebook or Instagram. If you initiatesuch a process, such as by “Liking” a CAP product on Facebook, you will beallowing Facebook to provide us with information from your Facebookprofile. Whenever submitting information on a social network website youshould familiarize yourself with their privacy policy and practices. CAP isnot responsible for the privacy practices of these third-party websites.

How we collect your personal information?

You can share your personal information with us in several ways, forinstance by:

• communicating with us by e-mail, phone, social media or in writing;
• participating in a social media activity related to our Products byviewing the activity or by clicking "like" or "share";
• cookies placed by CAP or third parties on your computer or mobiledevice when you visit our websites and accept the cookies.

When and why we share personal data within theC.A. Papaellinas Group and with other organizations

We would like to let you know that we work with carefully selected ServiceProviders that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing and combining data, processing payments and delivery orders. We would liketo assure you that we only share personal data that enable our ServiceProviders to provide their services.

Some of the Service Providers we work with operate online media channels, and they place relevant online advertising for our products andservices on those online media channels on our behalf. For example, you may see an advert for our products and services as you use particularsocial media sites.

We may share personal data with other organizations if the law or a publicauthority says we must share personal data, if we need to share personaldata in order to establish exercise or defend our legal rights.

Other than the disclosures referred to in this policy, we will “not” discloseany personal information without your consent unless we are legallyentitled or obliged to do so (for example, if required to do so by CourtOrder or for the purposes of prevention of fraud or other crime).

How we protect your personal data

At CAP we are committed in respecting, protecting and maintaining yourprivacy and thus, we have a lot of measures in place.

For example, we use computer safeguards such as firewalls and dataencryption. We also enforce physical access controls to our buildings andfiles to keep this data safe. We only authorize access to employees whoneed it to carry out their job responsibilities.

As part of our policies, we enforce physical, electronic and proceduralsafeguards in connection with the collection, storage and disclosure ofpersonal data. We may occasionally ask for proof of identity before weshare your personal data with you.

The personal data that we collect from you may be transferred to, andstored at, a destination outside the European Economic Area ("EEA"). Itmay also be processed by companies operating outside the EEA who workfor us or for one of our service providers. We would like to reassure youthat we will put in place appropriate protection measures to make surethat your personal data remains adequately protected and is treated inline with this Policy.

You should be aware that the internet is an insecure environment. Whilstwe take appropriate technical and organizational measures to safeguardyour personal data, please note that we cannot guarantee the security ofany personal data that you transfer over the internet to us. However, wewill continue to update these measures, as appropriate, when newtechnology becomes available.

Cookies and other similar technologies

A Cookie is a small data file that is stored by your Web browser on yourcomputer. We use Cookies to keep track of your current browsing session, to make your online experience and interaction with our websites asinformative, relevant and supportive as possible.

Some cookies are necessary so you should not disable these if you want tobe able to use all the features of our Websites. You can disable othercookies but this may affect your online experience. Also, you can choosenot to accept Cookies but certain functions of our websites may not workcorrectly or at all if you set your browser not to accept cookies.

When it comes to Cookies you have a lot of choices, you can use yourbrowser settings to accept or reject new Cookies and to delete existingCookies. You can also set your browser to notify you each time newCookies are placed on your computer or other device.

Cookies allow us to improve the way our Websites work so that we canpersonalize your experience and allow you to use many of their usefulfeatures.

For example, we use Cookies so we can remember your preferences whenyou return to our Websites. Also, cookies help us deliver online advertisingthat we believe is most relevant to you on our Websites and otherorganizations’ websites. Cookies used for this purpose are often placed onour Websites by other organization, and always with our permission.In addition, Cookies can help us to understand how our Websites are beingused, for example, by telling us if you get an error message as youbrowse. The Cookies collect data are mostly aggregated and anonymous.

When you visit our Websites, these Cookies automatically log your IPaddress (the unique address which identifies your computer on theinternet) which is automatically recognized by our web server. We use IPaddresses to help us administer the Site and to collect broad demographicinformation for aggregate use.

With this way, we can measure the effectiveness of our marketingcommunication, including online advertising campaigns, for example, bytelling us if you have opened a marketing email that we have sent you andthe number of times you are shown an advert. Cookies can, also, tell us ifyou have seen a specific advert and how long it has been since you haveseen it.

Children’s data

It is very important for us to protect children's privacy. We may collectpersonal data in relation to children only if we have first obtained theirparents’ or legal guardian’s consent or unless otherwise permitted underlaw. For the purposes of this privacy statement, “children” are individualswho are under the age of eighteen (18).

How long we keep your personal information for

Personal information collected will be retained no longer than necessary inorder to fulfil the purposes as outlined in this Privacy Policy, unless alonger retention period is required and justifiable or permitted by law. We may keep your data for up to ten (10) years in accordance with thedirective of the Data Protection Commissioner(http://www.dataprotection.gov.cy).

Your rights

Under the General Data Protection Regulation (EU) 2018/679 which isapplicable from 25 May 2018 you have various rights with regards to thepersonal data we hold about you.

These are:

Receive access to your personal data. This enables you to e.g. receive acopy of the personal data we hold about you and to check that we arelawfully processing it.

Request correction (rectification) of the personal data we hold about you.This enables you to have any incomplete or inaccurate data we hold aboutyou corrected.

Request erasure of your personal information. This enables you to ask usto erase your personal data (this is known as the ‘right to be forgotten’)where there is no good reason for us continuing to process it.

Object to processing of your personal data where we are relying on alegitimate interest and there is something about your particular situationwhich makes you want to object to processing on this ground. If you lodgean objection, we will no longer process your personal data unless we candemonstrate compelling legitimate grounds for the processing whichoverride your interests, rights and freedoms.

You also have the right to object where we are processing your personaldata, for marketing purposes.

If you object to processing for marketing purposes, then we shall stop theprocessing of your personal data for such purposes.

Request the restriction of processing of your personal data.

This enables you to ask us to restrict the processing of your personal data,i.e. use it only for certain things, if:

• it is not accurate,
• it has been used unlawfully but you do not wish for us to delete it,
• it is not relevant any more, but you want us to keep it for use inpossible legal claims,
• You have already asked us to stop using your personal data but youare waiting us to confirm if we have legitimate grounds to use yourdata.

Request to receive a copy of the personal data concerning you in a formatthat is structured and commonly used and transmit such data to otherorganizations. You also have the right to have your personal datatransmitted directly by ourselves to other organizations you will name(known as the right to data portability).

Withdraw your consent regarding the processing of your personal data atany time. Note that any withdrawal of consent shall not affect thelawfulness of processing based on consent before it was withdrawn orrevoked by you. You have the right to withdraw your consent given to us,opt-out, unsubscribe or change preferences via a link in the footer of allnon-transactional email messages. These options are made availablewhen you sign-up for our email lists and in email messages delivered fromus.

Right to lodge a complaint

If you have exercised any or all of your data protection rights and still feelthat your concerns about how we use your personal data have not beenadequately addressed by us.

Contacting us

To exercise any of your rights, or if you have any other questions about ouruse of your personal data, please contact by using the ”Contact Us” pageon this website.

You can also contact our Data Protection Officer [email protected].

Your concerns are very important to us and endeavor to address all yourrequests promptly.

Note: The General Data Protection Regulation (EU) 2016/679 shall applyfrom 25 May 2018. Until then, the Processing of Personal Data (Protectionof Individuals) Laws 2001 till 2012 remain in force.