thehoodmen

Data Protection Policy

The Hoodmen Ltd, 1 Arch. Makarios III Avenue. MITSI, Building 3, Office 306, Nicosia 1065 Cyprus

The primary purpose of this policy is to provide general guidance on issues about the privacy policy (collection, use, disclosure, monitoring, etc.) of this company, The Hoodmen Ltd, 1 Arch. Makarios III Avenue. MITSI, Building 3, Office 306, Nicosia 1065 Cyprus, tel …………………., …..[link of the site]………., email: …………………………………….

1. PURPOSE OF THIS POLICY

This policy explains how The Hoodmen Ltd, 1 Arch. Makarios III Avenue. MITSI Building 3, Office 306, Nicosia 1065 Cyprus (hereinafter referred to as the company) can collect information about its customers and use them to meet customer and regulation requirements.

It also describes some of the security measures the company takes to protect the confidentiality of data and provides some guarantees of what the company will not do.

2. LEGAL AND REGULATORY FRAMEWORK

The management and protection of the personal data of the visitor / user of the Company's services is subject to the terms of this section as well as to the relevant provisions of the Cypriot Law No. 125(I)/2018 on the protection of natural persons with regard to the processing of personal data and the free circulation of such data, as applicable, and the European General Data Protection Regulation (GDPR: 2016/679 of the European Parliament and of the Council of 27 April 2016, http://eur-lex.europa.eu/legal-content/EL/TXT/HTML/?uri=CELEX:32016R0679&from=EN).

These terms are drafted in light of both the rapid development of technology and in particular of the Internet and the existing - though not fully developed - legal framework on these issues.

In this context, any possible ratification to this effect will subject to this section.

In any case, the Company reserves the right to change the terms of personal data protection by informing visitors / users within the existing or future legal framework.

If any visitor / user does not agree with the terms of personal data protection provided in this section, he / she must not use the services of the Company.

3. COMMITMENT

The Company considers that privacy and customer data protection are of paramount importance and is committed to providing all customers with personalized services that meet their demands and in a manner that safeguards their privacy.

4. COLLECTION AND PROCESSING OF PERSONAL INFORMATION

The company manages and processes your personal data in full compliance with the relevant GDPR articles (5, 6, 7, 8, 9, 10, 11, etc.).

Specifically for Article 5 (Principles governing the processing of personal data) the company shall take appropriate measures to ensure that personal data:

(a) undergo lawful and fair processing in a transparent manner in relation to the data subject ('legality, objectivity and transparency');

(b) they are collected for specified, explicit and legitimate purposes and are not further processed in a manner incompatible with those purposes; further processing for archiving purposes in the public interest or for purposes of scientific or historical research or statistical purposes shall not be regarded as incompatible with them; pursuant to Article 89 (1) ('limitation on purpose'),

(c) are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ('data minimization');

(d) they are accurate and, where necessary, kept up to date. All reasonable measures shall be taken to immediately erase or rectify personal data which are inaccurate with respect to the purposes of the processing ('accuracy'),

(e) are kept in a form that allows the identification of data subjects only for the time necessary for the purpose of processing personal data; for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, according to the Article 89 (1) and, where appropriate, the technical and organizational measures required by this Regulation to safeguard the data subject's rights and freedoms ("limitation of storage period"),

(f) are processed in a manner that ensures the appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures ('integrity and confidentiality”).

Some of the personal information the Company holds about you may be sensitive personal data, within the meaning of data protection law and other relevant laws.

The company may collect personal information about you from a variety of sources, including:

(a) by you when you agree to receive a service from our company and in this may include your personal and / or business contact information and your consent;

(b) by you when you contact our company with a request for information, and

5. TYPES OF PERSONAL DATA WE COLLECT

When you interact with the company, we will ask or receive data with your consent, such as:

•Your name,

• Your email address,

• Your phone number,

• Your social media profile,

• Your gender,

• Your age,

• Information about the products and services you have purchased,

• Your use and activities on the company pages and

• Other information related to your behavior on the Internet.

We also collect personal information through cookies (see details on the link www ………………………), such as:

• Your IP address,

• Your cookie ID,

• Your browser,

• Your location,

• The websites you visit on our sites,

• The ads you see or click on.

6. RIGHTS OF INTELLECTUAL AND INDUSTRIAL PROPERTY

Except those expressly stated (copyright of third parties, affiliates and entities), all content of the Company, including images, graphics, photographs, drawings, texts, services provided, and generally all archives on this site, are copyright registered trademarks and service marks of the Company and are protected, in accordance to the relevant provisions of National law, European law and international conventions.

Consequently, none of these may be wholly or partly sold, copied, modified, reproduced, republished or downloaded, transmitted or distributed in any way.

7. USE OF INFORMATION

The information you provide to the company or the company holds will be used by the company to:

(a) Verifying your identity when asking questions,

(b) Communicate with you about improving the management of services and products provided by the company in the past, present or in the future;

(d) The prevention and detection of fraud or loss; and

(e) Contact you by any means (including mail, email, telephone, etc.) about other services and products offered by the Company.

8. CREDIT CHECK

The company may, in some cases, perform credit checks with the competent bodies when you apply for a service or product. If this is the case, then this will be explicitly stated in the terms and conditions of business conduct between you and the company.

9. DISCLOSURE OF INFORMATION

Under no circumstances will our company transfer your personal information to third parties in accordance with the new European General Data Protection Regulation (GDPR: 2016/679 of the European Parliament and of the Council of 27 April 2016).

Under no circumstances does our company sell or rent your personal data to third parties.

This information is used by our company to continually improve your service.

The company may disclose information only if it is lawfully requested for legal or regulatory purposes in the context of litigation or any legal process.

10. PROTECTION OF INFORMATION

The company has strict security and control measures in place to protect your personal data.

This includes, in accordance with GDPR (Articles 5, 28, 30, 32, 33, 34, 40, 55 - 58, etc.) a set of administrative measures, security policies, procedures and practices to verify your identity when you call us , encrypting data on our web pages and files, backing up data, etc. to ensure compliance with all applicable legal requirements.

We have taken steps to ensure that your personal data is held on our behalf by third parties (the company name that holds the server data and a link referring to its privacy policy) in accordance with European law, and we make sure the same safety standards are met.

We share your personal data with your consent or as required by law to complete a transaction or to supply a product you have requested or authorized. We share data to perform the contract with suppliers or carriers that work on our behalf, in cases required by law or in order to comply with legal procedures, for the protection of life, for the safety of our products, and for the protection of our rights or property of our company.

11. INTERNET ACCESS

If you contact the company over the Internet, if you give us your consent, then we will occasionally use e-mail to contact you about our services and products.

You should know that communications over the Internet, such as emails etc., are not secure unless they are encrypted.

The Company is not responsible for any unauthorized access or loss of your personal information that is beyond the control of the Company.

We may use 'cookies' to track the movement of the user of our website.

You can change your browser settings to prevent cookies from being used. However, the rejection of cookies may affect your ability to use some of the products and / or services on our company’s website.

12. MONITORING OF COMMUNICATIONS

All Company communications with you (including telephone conversations etc.) may be monitored and recorded by the Company for safety, quality assurance, and legal, regulatory and training purposes, in such case, you will be notified when the communication begins.

13. WHAT ARE YOUR RIGHTS?

In accordance with the European General Data Protection Regulation (GDPR: 2016/679 of the European Parliament and of the Council of 27 April 2016), as they are in force, you have the right to information, access, deletion, portability, correction and objection (Articles 15 - 22 of the GDPR). You have the right, on request, to receive free information about your stored personal data, and you have the right to object, on request, to the future processing of data concerning you. In addition, you have the right, in accordance with the law, to correct and delete such data.

MORE DETAIL:

You may exercise the following rights:

•the right of access in order to know what data we process, their purposes and recipients (Article 15 of the GDPR "Right of Access of the Data Subject")

•the right to rectification, in order to correct any deficiencies or inaccuracies in your data (Article 16 GDPR Right)

•the right to erasure (the right to be forgotten) the deletion of your personal data from our records, as long as it is no longer necessary to process it (GDPR Article 17 "Right of Exemption")

•the right to restriction of processing if your data is inaccurate (GDPR Article 18 'Right to limit processing')

•the right to be notified of any rectification or restriction of processing of personal data carried out in accordance with Article 16, Article 17 (1) and Article 18 (GDPR Article 19 ‘Notification obligation regarding rectification or erasure of personal data or restriction of processing’)

•the portability right: to receive your data in a structured and commonly used format (GDPR Article 20 'Right to Data Portability')

•the right to object, in particular if you do not wish us to use your data for the purpose of directly promoting our products and services, including profile profiling (GDPR Article 21 'Right of Opposition' and GDPR Article 22 'Automated Individual Decision Making, including profile training ').

To exercise your rights, please send a request to: …………….[e-mail of the company]…….

The Company is committed to provide you, as far as technically feasible, automated means to exercise your rights and to satisfy your requests in principle free of charge, unless your requests are frequently repeated and due to volume they have administrative costs for us, that you will bear.

The Company will make every effort to respond to any such request within thirty (30) days of receipt. However, in the event that due to the complexity of your request or the volume of information, your request cannot be satisfied within thirty days, the company will notify you within the above deadline, in writing, of the reasons for the delay and will make every effort to satisfy your request as soon as possible, and in any case, within two additional months.

In any case, you have the right to file a complaint with the Office of the Commissioner for Personal Data Protection, which may also receive complaints either in writing in its protocol (1Iasonos str., Postal Code 1082, Nicosia Cyprus) or electronically by sending an e-mail (commissionerdataprotection.gov.cy) or by sending fax +357 22304565 .

If you have given your consent to receive our Newsletter, you can revoke it at any time, you can send your request to …………….[e-mail of the company]……………. , as well as any information you receive.

14. SOCIAL PLUGINS - BUTTONS

Our company uses in our website Social Plugins (hereinafter "buttons") of social networks, such as ………….[names of the social media i.e. Facebook, Instagram]……….

When you visit our site, these buttons are normally disabled, meaning they do not send data to social networks without your active participation. To use these buttons, you need to activate them by clicking the mouse. After activation, a direct connection to the social network server is created.

If you are a member of a social network and do not wish the data collected when you visit our site, to be linked to your data stored on the social network, you must disconnect from the social network before activating the buttons.

We have no control over the amount of data that social networks process through their buttons. Information on the purpose and volume of data collection, individual processing and use of data from social networks, as well as rights and adjustment rights regarding your data protection can be found in the social media statements on data protection (in particular you can read the cookie and data protection policy for ………………..[name of each social media and links of its cookie and data protection policy]…………………………..

15. APPLICABLE LAW AND OTHER TERMS

Last update and amendment of this Policy: 21.12.2022

The above terms and conditions of use of the Company, as well as any modification, change or alteration, are governed by and supplemented by National law, European Union law and relevant international treaties.

Any provision of the foregoing terms is rendered contrary to law, shall cease to apply and be hereby repealed without prejudice to the validity of the other terms.

This is the entire agreement between the Company and the visitor / user of its pages and services and only binds them.

No modification of these terms will be considered and will form part of this Agreement unless it has been formulated in writing and incorporated into it.

16. COOKIE POLICY

Details on the company’s cookie policy can be found at the following link:

<company’s cookie policy link>.

17. CONTACT US

If you have any questions about the above privacy policy and / or cookie policy or to exercise your rights, please contact us.

Personal Data Controller: The Hoodmen Ltd, 1 Arch. Makarios III Avenue. MITSI, Building 3, Office 306, Nicosia 1065 Cyprus, tel ……………….., …..[link of the site]……………., email: ………………………… .