We ask that you read this website Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and/or the supervisory authorities in the event you have a complaint.

1. General information

This website is operated by A. NEOCLEOUS HOLDINGS LIMITED, with registration number HE 50646 (hereinafter referred to as the “Controller” or “Company” or “We” or “Us”).

We collect and use certain personal information about you. When we do so, we are regulated under The General Data Protection Regulation 2016/679 (hereinafter referred to as the “GDPR”), which applies across the European Union. We are responsible as ‘controller’ for that personal information pursuant to the GDPR.

2. Our Website

This Privacy Policy relates to Neocleous Tower Website, hosted at https://www.neocleoustower.com/  (hereinafter referred to as the “Website”), only.

The Website, is an informational website about the superior features, facilities and benefits of Neocleous Tower.

Throughout our Website we may link to other websites owned and operated by certain trusted third parties and partners. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

3. What information we collect

We collect personal information about you when you access our Website.

We collect personal information from you either directly, such as when you contact us and/or registering to our newsletter or indirectly, such as when you are browsing while on our Website, via cookies (see section ‘Cookies’ below).

The personal information we collect about you, depends on the particular activities carried out through our Website.

This information include cookies (hereinafter referred to as “Cookies”) and/or the below personal information, which are being collected when you are trying to connect with us via our ‘contact us form’:

• Name, and
• Email address.

Moreover, we are collecting your email address when you are requesting to be registered to our newsletter.

(hereinafter refer to as your “Personal Information”)

4. Purpose of the collection

The purpose of collecting Cookies is in order to,

• enable the smooth operation of our Website in general and provide you with constant, uninterruptible and error-free access to our Website;
• monitor how effective and popular our Website is, how to improve it, tailoring it to our visitors and their interests and needs.

While, the purpose of collecting your Personal Information via our ‘contact us form’ is to enable us to revert and respond to your request/inquiry.

Moreover, through our ‘contact us form’ we are providing you the option to opt-in to our newsletter in order to start receiving news and marketing material regarding Neocleous Tower. In case you opt-in to our newsletter, we will be giving you the option, through every email that you will be receiving from us, to opt-out from our newsletter list.

We do not collect and we do not use any personal information other than that specifically mentioned above, without your explicit consent.

This website is not intended for use by children, and we do not knowingly collect or use personal information relating to children.

We do not use automated decision-making processes or profiling while processing your personal data.

5. Our legal basis for processing your personal information

When we use Cookies and/or your Personal Information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely on, depending on what personal information we process and why.

The legal bases we may rely on include:

• Consent: where you have given clear consent for us to process your Personal Information for a specific purpose, such as when you are submitting a request/inquiry via our ‘contact us form’ or when you opt-in to our newsletter or when you enable analytic cookies on our Website;

• Legitimate interests: where the use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests), such as ensuring website and user security, improving user’s experience, user interface design and overall performance of the website, i.e. strictly necessary cookies.

6. Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device), when you use our Website. We use Cookies on our Website. These help us, amongst other things, to recognize you and your device and store some information about your preferences or past actions.

For further information on cookies, our use of ‘cookies’ and/or on relevant similar technologies, please see our Cookie Policy.

7. How we keep your data

We process your personal information at our head offices, in Limassol, Cyprus  where they are also safely kept and stored.

For the storage and security of your personal data the Company takes all the necessary technical and organizational measures to ensure that the processing is carried out in accordance with the applicable local laws and the GDPR (access control, firewalls, antivirus, cryptography, etc.).

8. Data Recipients

Within our Company, your personal data is only accessible by the strictly required personnel and only for the purposes mentioned above.

Outside our Company, recipients of your personal data may be any subcontractors or third parties who cooperate and/or provide services in the context of its business, such as companies that provide email services, web hosting services, information technology services, legal representatives, etc.    

We choose our associates very carefully, after the necessary checks have been carried out and sufficient guarantees have been provided to implement appropriate technical and organizational measures in such manner that processing will meet the requirements of the GDPR and the relevant laws and ensure the protection of your rights. 

We may also need to:

• disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
• share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring. Your information in such cases will be anonymized, but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

9. Retention Period

Personal data provided to us via our Website will only be stored until the purpose for which they were processed has been fulfilled or – in the case of consent – until you withdraw your consent.

Insofar as retention periods under commercial and tax law must be observed, the storage period for certain data can be up to 7 years. However, storage periods may also be amended due to our legitimate interest (e.g. to guarantee data security, to prevent misuse or to prosecute criminal offenders).

After this period, your personal data will be irreparably destroyed. Any data kept by us for marketing and information purposes, if applicable, will be retained until you inform us that you no longer wish to receive such information.

Any requests for further information in relation to the continued processing of specific data and requests for destruction of data should be made to [email protected].

10. Transfers of data outside the EU / EEA

We are not transferring personal data outside the EU /EEA. However, in case your data will be transferred to entities or other third parties whose headquarters or place of data processing is not located in a member state of the European Union or the European Economic Area, we ensure before forwarding the data that, outside of legally permitted exceptional cases pertaining to the recipient, either an appropriate level of data protection exists (e.g. through an adequacy decision of the European Commission, through suitable guarantees, or through the agreement of EU standard contractual clauses between us and the recipient), or your sufficient consent exists.

11. Security

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. These measures include, but are not limited to, access control, internal audit etc. Furthermore, we limit access to your personal information to those who have a genuine business and need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. Your Rights

As a data subject, you may contact us at any time to make use of your rights, which are, the right to:

• receive information about the data processing and a copy of the processed data;
• demand the rectification of inaccurate data or the completion of incomplete data;
• demand the erasure of personal data;
• demand the restriction of the data processing;
• receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to request the transmittance of these data to another controller in certain situations;
• object to the data processing;
• withdraw a given consent at any time to stop a data processing that is based on your consent;
• complain to a competent supervisory authority.

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below).

In the event that you wish to complain about how we have handled your personal data, you may contact us (see ‘How to contact us’ below). We will then look into your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you can submit your complaint with the Office of the Commissioner for Personal Data Protection, at 1 Iasonos Street, 2nd Floor, 1082 Nicosia, Cyprus, Tel. +35722 818456 Email: [email protected].

11. How to contact us

You can contact us by post, email or phone, if you have any questions about this Privacy Policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

1. NEOCLEOUS HOLDINGS LIMITED

Postal address: 195 Makarios III Avenue, Neocleous House, 3030 Limassol, Cyprus.

Email address: [email protected]

Telephone no.: +357 25 268600

12. Changes to this Privacy Policy

This Privacy Policy was last updated on 21^st of August 2024.

We may change this Privacy Policy from time to time and when we do so, we will inform you via a notification on our Website or via other means of contact, when this considered necessary.