Privacy Policy

Custom PC Systems LTD having an address at Steliou Kyriakidi 45, Limassol, 3080, Cyprus (hereinafter, referred to as the “Company”, “us”, “we”, and “our”) collects from the individual user (hereinafter, referred to as “you” and “your”) certain personal data through the website http://www.custompc.com.cy (hereinafter, referred to as the “Website”). The Company acts as a data controller (i.e., the entity responsible for collection and processing of your personal data).

This Privacy Policy (hereinafter, referred to as the “Privacy Policy”) explains our procedures related to the collection and processing of your personal data through the Website. For the purposes of this Privacy Policy, the term “processing” refers to collection, storage, deletion, use, and disclosure of your personal data, and the term “personal data” refers to any information relating to a natural person who can be identified, directly or indirectly, by using such information.

We are committed to ensuring that your privacy is properly protected. Should we ask you to provide us with your personal data, you can be assured that it will only be used in accordance with this Privacy Policy.

Personal data collection and processing through the Website is conducted in accordance with the data protection laws of Cyprus and the applicable EU laws, including the GDPR.


Your consent

By using the Website and placing orders through the Website, you consent to our processing of your personal data for the specified, explicit, and legitimate purposes described in this Privacy Policy.

When you visit the Website, we may ask you for your explicit express consent to our collection and processing of your personal (e.g., via a click on the button “I agree” or ticking a box) if we would like to:

• Use your personal data for any purposes that are not explicitly indicated in this Privacy Policy;

• Provide you with marketing communication;

• Transfer your personal data to third parties that are not indicated in this Privacy Policy; or

• Significantly amend this Privacy Policy.


What personal data we collect

We adhere to data minimization principles. We collect and process only minimal amount of personal data that is strictly necessary for performing the operations requested by you through the Website (e.g., placing and processing orders) or for pursuing our legitimate interests, unless you decide, at your sole discretion, to provide additional personal data to us.

• When you visit the Website, we will collect your IP address.

• When you sign up for our newsletter, we will collect your email address.

• When you purchase products through the Website or create a user account on the Website, we will collect the following personal data:

o First name;

o Surname;

o Email address;

o Physical address;

o Billing address;

o Username;

o Password;

o Company name;

o Phone number; and

o Birth date.

If you do not provide us with the requested personal data, we may not be able to process your purchase order and you may not be able to use the full functionality of the Website.

By using the Website, you acknowledge and agree to submit personal data that is up-to-date, true, accurate, current, and complete, and you shall update your personal data as soon as any changes in your personal data occur.

Legal grounds for processing of personal data. Depending on the circumstances in which you provide us with your personal data, the collection and processing of your personal data is carried out on the basis of one of the following legal grounds:

• Ensuring the performance of a contract;

• Pursuing our legitimate business interests; or

• If you have provided us with your explicit consent for collection and processing of your personal data for a particular purpose.

Non-personal data. From time to time, we may collect your non-personal data, such as the browser types used by you, operating systems, and the URL addresses of websites clicked to and from the Website. Please note that such information does not contain any personal data and cannot be used to identify you. In case your non-personal data is combined with some of your personal data in a way that allows us to identify you, we will treat such non-personal data as personal data. We use your non-personal data to improve your user experience with us, including to offer you a better design of the Website and user traffic analytics purposes, such as to analyze what kind of users visit the Website, how they access it, how long they stay, from which other websites they come to the Website, what pages they look at, and to which other websites they go from the Website.

Personal data collected from third parties. We may receive some personal data from third parties, such as data authentication providers and social media service providers, if you access the Website through such providers. Please note that data processing of such providers is governed by their individual privacy policies. Please read carefully the applicable privacy policy and check your privacy settings in order to control the personal data you permit to send to us.

Sensitive data. Please note that we do not collect sensitive personal data (e.g., your health information, opinion about your religious and political beliefs, racial origins and membership of a professional or trade association), unless you decide, at your sole discretion, to provide such sensitive data to us through the Website.


What we do with the personal data we collect

We respect data protection principles and we collect and process the personal data only for the purposes for which personal data is provided.

• If you provide your personal data for the purpose of obtaining quotes for the products and services sold through the Website, we will use your personal data to provide you with quotes for products and services for which you have expressed interest.

• Your personal data provided during the process of purchasing products and services through the Website will be used to process and deliver your orders.

• We may also use your e-mail address to send you information about products or services that are the same as or similar to those that you have ordered from us and that we think you may find useful. We will do so only until you object to being contacted for these purposes (e.g., by unsubscribing).

The use of your personal data for the purposes that are different than the purposes mentioned above will be possible only if we obtain your prior explicit consent.


Marketing and newsletters

If you sign up for our newsletter, we will regularly send you newsletters and other news, offers, and information that can be of interest to you. Your subscription for a newsletter constitutes your consent to receive marketing communication.

After you purchase products from us, we may use your e-mail address to send you information about products or services that are the same as or similar to those that you have ordered from us and that we think you may find useful.

When you register a user account on the Website, you can opt in for receiving our newsletter and other direct marketing materials by expressing your preference and providing your consent. From time to time, we may also use your personal data to contact you for market research purposes. We may contact you by email, phone, fax or mail.

Opting-out from marketing messages. At any stage, you have the right to ask us to stop using your personal data for direct marketing purposes by the following ways:

• You can click on the “Unsubscribe” link contained in any newsletter provided by us;

• If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by contacting us. Our contact details are indicated at the end of this Privacy Policy.

Informational notices. In exceptional cases, we may send you important informational communications related to the Website and your orders, such as the status of your orders, announcements about important updates of the Website, information about security breaches, or other privacy-related matters. Please note that such communication will be sent only on an “if needed” basis and it does not fall within the scope of direct marketing communication.


Security

We adhere to current information security standards by employing organizational and technical information security tools, such as secured networks, pseudonymization, encryption, and limited access to your personal data by our staff, as well as suitable physical, electronic and managerial procedures, for the purpose of protecting your personal data. We put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data.

However, due to the inherent risks of using the Internet, we cannot be liable for any destruction, loss, leakage, and falsification of personal data caused by circumstances beyond our reasonable control. In case a personal data breach occurs, we will inform the local data protection authority, namely the Cyprian Commissioner for Personal Data Protection, without undue delay and immediately take reasonable measures to mitigate the breach, as stipulated in the applicable law.

Please note that you are solely responsible for keeping online credentials, such as login details and passwords, in a private and secure manner. Under no circumstances shall we be responsible for unauthorized access and any damage whatsoever occurred due to your failure to protect your online credentials.


Minors

The Website cannot be accessed and used by users under the age of 18. However, we cannot distinguish the age of people accessing the Website. If a person under 18 has provided us with personal data without obtaining parental or guardian consent in advance, the parent or guardian may contact us requesting us to destroy or de-identify the personal data. Our contact details are specified in the section “Contact details” at the end of this Privacy Policy.


Third party access to your personal data

If necessary, we may disclose or transfer your personal data to third parties. Please note that such a disclosure or transfer is limited to the situations when the personal data is required for the purposes of (1) provision of the information or services requested by you, (2) pursuing our legitimate interests, (3) law enforcement purposes, or (4) if you provide your prior explicit consent. For example, your personal data may be disclosed to third parties that:

Deliver a newsletter on our behalf. The personal data provided by you for signing up for our newsletter will be used by our newsletter provider MailChimp, which adheres to data protection principles contained in this Privacy Policy. MailChimp is a USA company, which complies with the U.S.-EU Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the Member States of the European Union. If you would like to read MailChimp’s privacy policy, please visit http://mailchimp.com/legal/privacy/.

Provide payment services. When you make payments through the Website, your payments will be processed by our third party payment processors, (i) PayPal (Europe) S.à r.l. et Cie, S.C.A. having an address at 22-24 Boulevard Royal, L-2449 Luxembourg and (ii) JCC Payment Systems LTD having an address at Stadiou 1, 2571 Nisou, PO Box 21043, 1500 Nicosia, Cyprus (hereinafter, collectively referred to as the “Third Party Payment Processors”). Our Third Party Payment Processors may collect payment information from you which is necessary to make the payments requested by you. Please note that we DO NOT store your credit/debit card information. Our Third Party Payment Processors handle all the steps in the payment process on their websites, including data collection and data processing.

Provide us with technical support. Third party service providers that provide us with technical services, such as software developers, hosting, website, and storing providers, customer support and marketing partners, and shipping partners may have access to your personal data for the purposes of service provision.

We may pass on your personal data to other third parties if this is necessary in order to achieve the purpose for which you provided the personal data to us (e.g., to provide you with a quote and deliver you the ordered goods) or if it is necessary to ensure the proper functioning of the Website and our business activities.

In case the Company is being sold partly or fully, the Company may also provide your personal data to a purchaser or successor entity.

Unless otherwise stated in this Privacy Policy, we will not pass on your personal information to third parties without first obtaining your prior written consent to do so, unless we are legally bound to do so.

The Company shall put reasonable efforts to assure that such third parties employ an adequate level of protection of personal data that is consistent with this Privacy Policy.

We do not sell your personal data to third parties, and does not intend to do so in the future.

Transfer of personal data outside the EEA. Some of the Company’s subsidiaries, affiliates, and third parties mentioned above may be located outside of the European Economic Area (EEA) and, if you are a resident of the EEA, we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located ensures an adequate level of protection of your personal data or we conclude an agreement with the respective third party that ensures such protection.


Integration of the Trusted Shops Trustbadge

The Website is certified by the Trusted Shops Trustbadge. We have integrated the Trusted Shops Trustbadge on the Website in order to display our Trusted Shops Trustmark and offer the Trusted Shops products to you after you place an order. This serves the protection of our legitimate interests in the optimal marketing of our offer according to art. 6 (1) 1 lit f GDPR that are overriding in the process of balancing of interests. The Trustbadge and the advertised trust badge services are offered by Trusted Shops GmbH, having a principal place of business at Subbelrather Str. 15C, 50823 Cologne, Germany.

With every use of the Trustbadge, the web server automatically saves a so-called server log file which contains e.g. your IP address, the date and time of the request, the volume of data transferred and the requesting provider (access data), and documents the request. Those access data are not analyzed and are automatically overwritten no later than seven days after the end of your visit of the Website. Other personal data are transferred to Trusted Shops only if you decide to use or have already registered to use Trusted Shops products after placing an order. In such a case, the contract concluded between you and Trusted Shops applies.


Exercising your rights

We take reasonable steps to ensure that the personal data collected and processed by us is accurate, complete, and up-to-date. Thus, we ask you to keep your personal data as current as possible and update your personal data through your user account on the Website as soon as any changes in your personal data occur.

You can manage your personal data collected and processed by us and request us to:

• Get a copy of your personal data that we store;

• Move your personal data to another processor;

• Delete your personal data from our systems;

• Object and restrict processing of your personal data;

• Withdraw your consent; or

• Process your complaint.

If you would like to exercise your rights listed above, please contact us by email at sales@custompc.com.cy. We may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 2 weeks.

Launching a complaint. If you would like to launch a complaint about the way in which your personal data is handled by us, we kindly ask you to contact us first. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are a resident of the EU and you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority. If you are a resident of Cyprus, more information about Cyprian Commissioner for Personal Data Protection is available at http://www.dataprotection.gov.cy.


Retention period

We will keep your personal information for as long as it is necessary to provide you with the requested service (e.g., replying to your enquiry, delivering your orders, and sending a newsletter). If your personal data is no longer necessary for the delivery of the requested services, we will immediately delete it, unless (1) we are required by the applicable law to retain such personal data for a specified period of time (e.g., maintaining accountancy records) or (2) you provide us with your explicit consent to retain the personal data for a specified period of time. Where possible, we will anonymize your personal data.


Links to other websites

The Website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave the Website, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any personal data which you provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.


Amendment of this Privacy Policy

We reserve the right to amend this Privacy Policy from time to time by posting an amended version on the Website, indicating the date of the last amendment, and sending you a notification by email or a message through your user account. Unless we require you to provide us with your explicit consent to the new Privacy Policy, your continued use of the Website after posting such an amended version or receiving a notification will constitute your acknowledgment of the amendments and your consent to abide and be bound by the amended Privacy Policy. Please regularly review this Privacy Policy in order to be aware of new amendments.


Contact details

Our contact details are listed below:

Company: Custom PC Systems

Address: Steliou Kyriakidi 45, Limassol 3080, Cyprus

Email: sales@custompc.com.cy


Last updated 01/06/2018