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Privacy Policy

1. Data controller
Custom PC Systems LTD having an address at Steliou Kyriakidi 45, Limassol, 3080, Cyprus (“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 (“Website”). The Company acts as a data controller (i.e., the entity responsible for collection and processing of your personal data).

2. About this Privacy Policy
This privacy policy (“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.

3. What personal data we collect and how we use it
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. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.

3.1 Sources of personal data. We obtain your personal data from the following categories of sources:
• Directly from you. For example, if you submit your personal data when you order our products or contact us;
• Directly or indirectly through your activity on the Website. When you use the Website, we automatically collect analytics information about your use of the Website; and
• From third parties. We may receive information about you from third parties (e.g., social media services) to whom you have previously provided your personal data, if such third parties have a legal basis for disclosing your personal data to us.
3.2 What personal data do we collect directly from you?
• User account. When you complete our user registration form or sign in through Facebook or Google, we collect your name, surname, email address, and mobile phone number. If you register by using Facebook or Google, we will also have access to your profile photo and other data that depends on your privacy settings. When you update your user profile, we collect your shipping address. We use such data to register and maintain your user account, process your orders, provide you with the requested information, contact you if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate interests’ (i.e., administer our business). We store such data in our systems until you delete your user account.
• Orders. If you decide to purchase products or services from us, we will collect your name, address, email address, payment details, and any relevant purchase information. We will use the said information to process your order, deliver you our products and services, contact you, if necessary, issue invoices, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyse, grow, protect, and administer our business). We will store this data for the time period required by tax law (in most cases, for 6 years).
• Payments. When you make a payment, you will be requested by a payment processor to provide your payment details that may differ depending on the chosen payment method (for example, your credit card number). Please note that we do not directly collect or store your payment details, as all payment transactions are handled by our payment processors. Your payment processor may provide us with access to a certain limited amount of your payment data to confirm a transaction. We use such data to process your payment, keep our business records, and comply with the applicable laws. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate business interests’ (i.e., administer our business and legal compliance). We keep your personal data for the time period required by our accounting laws.
• Enquiries. When you contact us by email, we collect your full name, email address, and any information that you provide in you message. When you call us, we collect your phone number and any information that is relevant to your inquiry. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to build our client base, engage clients, and promote our business) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us, unless your data is necessary for further purposes like concluding a service contract, in which case it we will keep it is along as necessary for the intended purposes.

3.3 What personal data do we collect while you are using the Website?
• Analytics data. While you are browsing on the Website, we collect analytics data that allows us to see what kind of users access and use the Website, which parts of the Website you find interesting, improve our content, develop new products and services, and investigate and prevent security issues and abuse. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyse, improve, and protect our Website) and ‘your consent’ bases. The analytics data that we collect includes:
• Your activity on the Website (time of visit, pages visited, time spent on each page, clicks, scroll depth, interaction with widgets);
• URL addresses from which you access the Website;
• Your browser type and version;
• Your operating system;
• Your device details;
• Your IP address; and
• Your other online behavior.
• Cookies. While you are browsing on the Website, we collect your cookie-related data. We use such information to analyze the technical aspects of your use of the Website, analyse your use of the Website, prevent fraud and abuse, and ensure the security of the Website. For more information on our use of cookies, please read our Cookie Policy . The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., analyze our content and protect the Website) and ‘your consent’. We will store this data as long as analytics records are necessary for our activities or you withdraw your consent.
• Social media widgets. The Website may include social media features, such as link buttons or other interactive mini-programs. These features may collect your IP address, which pages you are visiting on the Website and the Internet, and may set a cookie to enable the feature to function properly. Social media features and widgets are provided by third-party social media providers and, therefore, your interactions with these features are governed by the privacy statement of those providers.
3.4 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”), unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
3.5 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the Website, get your orders, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
3.6 Your feedback and de-identified data. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will remove all personal data that is not necessary for keeping such records. Also, we may use and share with third parties de-identified data for the purpose of facilitating research. Such data does not allow us to identify you as a natural person and, therefore, is not considered to be personal data.

4. Marketing and newsletters
4.1 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, or mail.
4.2 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.
4.3 Informational notices. We may send you important informational communications related to the Website and your orders, such as the status of your orders, invoices, 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.

5. 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. Our measures include:
a) Maintaining adequate access control mechanisms (e.g., two-factor authentication, password protection, and limited access);
b) Encryption;
c) SSL certificate;
d) Limiting access to personal data;
e) Conducting regular information security audits; and
f) Implementing up-to-date industry-appropriate technical security measures.
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.

6. 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.

7. Third party access to your personal data
7.1 List of data processors. 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 information, products or services requested by you, (2) pursuing our legitimate interests, (3) law enforcement purposes, or (4) if you provide your prior explicit consent. 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) JCC Payment Systems LTD having an address at Stadiou 1, 2571 Nisou, PO Box 21043, 1500 Nicosia, Cyprus, (ii) Viva Wallet Holdings 18-20 Amarousiou Chalandriou Avenue Maroussi, 151 25 Greece, (iii) Revolut Bank UAB Konstitucijos ave. 21B, Vilnius, 08130, Lithuania and (iv) PayPal (Europe) S.à r.l. et Cie, S.C.A. having an address at 22-24 Boulevard Royal, L-2449 Luxembourg, (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 shipping services. Our shipping service providers are (i) G.AP. Vassilopoulos Group having an address at 20 Strovolos Avenue, 2011, Nicosia and (ii) M.M. S. Must Courier LTD having an address at 15A Kerkiras Street, 4000, Limassol. We will disclose your Name, Surname, Address, Email address, and Phone Number to the shipping provider, so they can deliver your order and send you updates regarding the delivery status of your oder.
• Provide analytics services. We use Google Analytics, a web analytics service provided by Google LLC registered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”), to analyze your use of the Website. Google Analytics generates statistical and other information about the Website by means of cookies. The information generated by Google Analytics in relation to the Website is used to create reports about the use of the Website. The cookies served by Google are anonymous first-party cookies that do not allow us to identify you in any manner. The information generated by cookies will be transmitted to and stored by Google on servers in the United States. To ensure your privacy, your IP address will be anonymised and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For information on the privacy aspects of Google Analytics, please visit https://support.google.com/analytics/answer/6004245?hl=en. We use the following Google Analytics advertising features: (1) Remarketing with Google Analytics; (2) Google Display Network Impression Reporting; (3) Google Analytics Demographics and Interest Reporting; and (4) Integrated services that require Google Analytics to collect data via advertising cookies and identifiers. If you would like to opt out from Google Analytics advertising features, you can do so through Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI’s consumer opt-out). You can also install a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en .
• • 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.
• Provide us with other necessary services (Our independent contractors and consultants).
7.2 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.
7.3 In case the Company is being sold partly or fully, the Company may also provide your personal data to a purchaser or successor entity.
7.4 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.
7.5 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.
7.6 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.
7.7 Legal requests. If requested by a public authority, we will disclose information about the users of the the Website to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

8. 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 [email protected]. 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.

9. 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.

10. 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. For more details on how we store your personal data, please refer to section 3.

11. 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.

12. 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 ask you to provide us with your consent to some of the new amendments, your continued use of the Website after posting such an amended version or receiving a notification will constitute your acknowledgment of the amendments. Please regularly review this Privacy Policy in order to be aware of new amendments.

13. Contact details
Our contact details are listed below:
Company: Custom PC Systems
Address: Steliou Kyriakidi 45, Limassol 3080, Cyprus
Email: [email protected]

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