(a) “Us”, “our” and “we” refer to this website, or the owner of it, who is Z.S Neptus Media Group Ltd (including any personnel and/or management of it). “Z.S Neptus Media Group Ltd” means, the business name registered with the Registrar of Companies of the Republic of Cyprus. “You” refers to you as the visitor or the customer or the user. This website means https://bonvivant-cy.com/.
(d) We ensure that our customers’ personal data is stored safely and securely. This policy has been drafted in accordance with the requirements of the EU Regulation 2016/679 General Data Protection Regulation (the “GDPR”).
(g) Regarding the GDPR, Innovium Digital Ltd is the data administrator of the collection or processing of the customers’ data and any enquiry regarding the methodology of the collection and process of the data should be addressed to the following contact details:
Name: Innovium Digital Ltd
E-mail: [email protected]
Address: 178 Anexartisias Str.
Roussos Limassol Tower, 7th floor, Limassol, Cyprus
- Collection of personal information
(a) Upon the creation of an account on this website by you we may collect the following personal information:
• Date of Birth;
• Job title and profession;
• Search preferences;
• Email address;
• Phone number;
• Demographic information such as post code, preferences and interests;
• Financial information such as credit/debit card numbers;
• IP address (automatically collected);
• Web browser type and version (automatically collected);
• Operating system (automatically collected);
• A list of URLS starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
• Cookie information;
• Any content that you generate or it is connected to your account as a result of a transaction you are involved in;
• Any content that you may generate, or that is connected to your account and your use of our website including your use of various website functions;
• You may also provide us with your information by submitting a web form, updating or adding information to your account, through your participation in community discussions, chats, dispute resolution, or when you otherwise correspond with us regarding our services; and
• Additional information which we are required or authorized by applicable national laws to collect and process in order to authenticate or identify you or to verify the information we have collected.
(b) “Personal information” is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that we have or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
(c) This personal information is collected through enquiring regarding our services and/or goods and/or products that we promote and/or advertise on this website.
(d) We use your personal information in order to create a user account for you on this website and to provide our services to you, including publishing your advertisements on the website and facilitating introductions with other members of our website. However, we will not share your email address with other users of the website unless you have specifically chosen to disclose it. Our lawful basis for processing this information is that the processing is necessary for performance of a contract.
(e) Any information you include in any advertisement you post on our website will be collected by us and stored on our servers as long as it is necessary and relevant for our operations for the purposes of making the website and to enable our users and/or members to search for and respond to advertisements on this website.
(f) In the event you are asked to submit any sensitive personal data as part of the process for posting advertisements on this website you will be asked to tick a box to demonstrate your consent to our collecting and storing that information and to us making that information available to other users through this website. Our lawful basis for processing this information is ‘consent provided by the data subject’.
(g) Please note that any materials or information you post to our website will be visible to other users of the website. We therefore advise you to be selective about what information you include in your advertisements and not to include any information you are not happy to be publically available.
(h) We may also collect certain information about your visits to our website and how you use it (IP address, geographical location, browser type, referral source, length of visit, number of page views and similar information). We may use this information for website administration, optimizing the use and performance of the website, disclosing to third party contributors or for security purposes.
(i) We may collect any information contained in correspondence between you and us for the legitimate interest of Z.S Neptus Media Group Ltd.
(j) We may also collect and store any information contained in communications between yourself and other users on the website for the legitimate interest of the Z.S Neptus Media Group Ltd.
(k) We may also collect other information about your activity on the site that is specific to your user account, such as your search history, your search and account preferences and advertisements you have posted. Our lawful basis for processing this information is the legitimate interest of the customer.
(m) We may send you information about services and/or products that we think you may be interested for. If you have agreed to receive marketing, you may always opt out at a later date. You have the right to stop us from contacting you for marketing purposes by notifying us in writing.
(n) Unless we are obliged or permitted by law to do so your data will not be disclosed to third parties. This includes our affiliates and/or other companies within our group.
(o) All personal data is stored securely in accordance with the principles of the GDPR.
(p) Any or all of the above data may be required by us from time to time in order to provide you with the best possible service and experience when using our website. Specifically, data may be used by us for the following reasons:
• Internal record keeping;
• Improvement of our products/services;
• Transmission by email of promotional materials that may be of interest to you; and
• Contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customize or update the website.
- Methodology of Data Collection
(a) You directly provide to us the data we collect. We collect data when:-
• You register online;
• Complete a customer survey or provide feedback to us; and
• Use or view our website via your browser’s cookies.
- Changes of business ownership and control
(b) In the event that any data submitted by users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
(a) We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our terms and conditions and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal information, we dispose of it in a secure manner according to our data retention and deletion policies.
- Storage of Data
(a) We securely store your data at our operating offices and/or any other places where the parties involved in the processing are located.
- Personal Data Accuracy
(a) All users’ personal data must fully accurate and up to date. In case any personal data changes, please notify us immediately.
- Customer Information
(a) Any personal information we may obtain and process will be based to the GDPR.
(e) As per the above mentioned our website may contain content and links to other websites that are owned by third parties. In addition, advertisements contained on our website may operate as links to that advertiser’s website, and such advertisers and third parties may also use and place cookies on your computer. We do not accept any liability or responsibility for these third party websites and their content.
(f) We collect data from the location of our users. The information we collect will be transferred to Cyprus from any other country in which our users may be located and will be subject to the GDPR and not to the laws of the country in which our users are residents.
- Your rights
(a) You are entitled to know what personal data we hold about you and you may ask us to make any necessary changes to ensure it is accurate and kept up to date.
(b) Under the GDPR, you have the right to ‘request the deletion or removal of your personal data. This is referred to as the right to erasure and can be enforced:-
• Where your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• Where you withdraw consent;
• When you object to the processing and there is no overriding legitimate interest for continuing the processing;
• Where the personal data was unlawfully processed; and
• Where the personal data has to be erased in order to comply with a legal obligation.
(c) Furthermore, other rights include:-
• The right to access – You have the right to request for copies of your personal data; We may charge you a small fee for this service;
• The right to rectification – You have the right to request us to correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete;
• The right to restrict processing – You have the right to request us to restrict the processing of your personal data, under certain conditions;
• The right to object to processing – You have the right to object to us for processing of your personal data, under certain conditions;
• The right to data portability – You have the right to request the transfer of the data that we have collected to another organization, or directly to you, under certain conditions; and
• The right not to be subject to a decision based solely on automated processing including profiling – You have the right to obtain human intervention.
- Legal disclosure
(a) Data is of great importance to Z.S Neptus Media Group Ltd and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected online.
- Contacting us
(b) You are required to provide personal data in order to enter into a contract with us. Failure to provide this personal data may mean that we are unable to execute the contract, and could result in termination of our provision of services to you.