Introduction

Photos Photiades Distributors Ltd (Data Controllers) values the relationships with all its customers, website visitors and stakeholders (Data Subjects). This notice explains how the company collects, processes and manages your personal data. Photos Photiades Distributors Ltd will process all personal data in compliance with the General Data Protection Regulation (GDPR) and any applicable local privacy law. This is to provide you with a service you have requested and to meet our statutory obligations.

In this privacy statement “we”, “our”, “us”, “company”, “PPD” and “Distributors” refers to Photos Photiades Distributors Ltd.

1.    What personal data we collect

Photos Photiades Distributors Ltd collects personal data from you when you volunteer to provide such personal data, or when you interact with our services. Other personal data relating to you, may also be provided to us by other persons.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect the following types of personal data which we divided in groups:

Service Users / Clients / Visitors:

• Identity Data: first name, maiden name, last name, username or similar identifier, title, date of birth and gender, signature, National ID or Passport information, Visa information, footage, business related information (your Company identity information and your relationship with them).
• Contact Data: email address, home address and telephone numbers, your Company contact data.
• Financial Data: bank account and payment card details.
• Transaction Data: details about payments to and from you and other details of products or services you have purchased from us.
• Technical Data: We may collect internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website (for more detail read our Cookies Notice at https://photiadesgroup.com/cookie-policy/.
• Usage Data:details about how you use our website, applications or other products or services
• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
• Use of our social media pages or other interactive forums:  any comments, photos, videos or other information that you post online
• Our correspondence with you: this includes any feedback, complaints and comments from you via telephone, email or social media, or records of any online, paper or in-person correspondence and interactions between us.
• Voluntary information: other types of information that you voluntarily choose to provide to us.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data by law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

*We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so, pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (i.e. the provision of disability access).

Recruitment:

Photos Photiades Distributors Ltd collects personal data from candidates for recruitment purposes. The information that PPD may collect and hold about candidates includes:

• Name, address, telephone number(s) and email address
• Details of qualifications, skills, experience and employment history
• Details of current immigration status
• Details of criminal or pending criminal convictions in Cyprus or any other jurisdiction
• Any additional information contained in a candidate’s CV such as referee information disclosed at interview or otherwise provided to PPD during the recruitment process.

Photos Photiades Distributors Ltd needs to process data to decide whether to enter into a contract of employment with a particular candidate and may also process certain data to ensure that it is complying with its legal obligations. PPD has legitimate interest in processing personal data during the recruitment process and in keeping records of the process in order to manage the recruitment process. It is required to assess and confirm a candidate’s suitability for employment and decide to whom to offer a particular role. PPD may also need to process candidate`s data to respond to and defend itself against legal claims.

Photos Photiades Distributors Ltd will not share a candidate’s data with third parties, unless his or her application for employment is successful and an offer of employment is made to him or her. Once an offer of employment has been made and accepted by a candidate, PPD may also contact the previous employers named by that candidate as referees for the purpose of obtaining employment references. Additionally, a criminal record might be requested. The candidate may also be required to provide medical information to PPD’s occupational health provider for the purposes of assessing his or her capacity to work.

Minors:

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

2.    How we collect your personal data

We use different methods to collect data from and about you including:

Directly from you: you may give us your Identity Data, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and/or email.

From third parties on your behalf: we may receive your contact details from an affiliated company in order to contact you with regards to our services and products.

Automated technologies or interactions: as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please read our Cookies Privacy Notice at https://photiadesgroup.com/cookie-policy// or more information.

Third parties or publicly available sources: we may receive personal data about you from various third parties such as related Companies and associates or your social media pages.

Competition, Vouchers, Promotions, Survey:  we may receive your data if you choose to participate in any competitions.

Social Media:  We may receive your data if you choose to contact us through our social media pages.

Events: We may collect your personal data through the host of an event or by you directly, in order to organise an event in one of our venues.

CCTV: we may record or capture images of you in public areas, by using CCTV, principally for the purpose of protecting you, our visitors, and other guests and out staff.

Visitors: Visitors to our offices must sign in at the reception. A record is kept for a short period of time. This information is necessary for your safety in case of an emergency, so we know who is in the building at that time and for the security of our people, visitors and the firm’s assets. These records are kept secure and only shared where required for the detection or investigation of a crime or to ensure the safety and security of our offices.

3.    How we use your personal data

We need your personal data in order to provide you with our services. Some of our services are:

• Distribution of our products: We may need to process and disclose your data to deliver our products to your business.
• Business Partners: We will use your data in order to do business with you.
• Merchandizing: We may need to process and disclose your personal data in order to provide your business with our merchandizing services.
• Invoicing: We will need to process your data for financial purposes.
• To comply with legal obligation: Your data might be used to comply with the requirements imposed by our auditors, financial reporting requirements, government authorities and to cooperate with law enforcement agencies, government authorities, regulators and/or the court.
• Promotions: Your data will be processed if you are the winner in one of our social media promotions.
• Event Competitions: Your data will be processed if you are the winner in one of our competitions.
• Marketing: We may use your personal data to develop an idea of what products or services we think you may want or need, or what may be of interest to you.

You will receive marketing communication from us if you have requested information from us. If you have provided us with your details when you entered a competition or registered for promotional material and, in each case, you have not opted out of receiving marketing material.

We will get your express opt-in consent before we share your personal data with any company outside PPD for marketing purposes.

You can ask us or third parties to stop sending you marketing material at any time by contacting us above or clicking on the opt-out link included in each marketing message.

Should you choose to opt out of receiving our marketing material, we will continue to carry out our other relevant activities using your personal data.

4.    Lawful Basis for processing

Performance of a contract with you: the processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract. For example, we process your data in order to supply you with the requested product or service.

Legal Obligation: In circumstances where it’s our legal obligation to disclose or share your data in order to be compliant, pursuant to a legal request, subpoena or other legal processes, or in order to enforce or apply the company’s Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or our safety, or others, we may exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Legitimate interest: The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. For example, it is the legitimate interest of the company to record the time attendance of its employees.

Before we process your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law), we make sure we consider and balance any potential impact on you and your rights before we process your personal data.

Vital Interest: In certain conditions when your consent it is not possible to be obtained, it may be necessary for us to process your Personal Data, including Sensitive Personal Data you provided through our Services, where it is in your vital interest or in the interest of others. Vital interest or in the interest of others could be an event of a medical emergency, in which we may disclose your data, for example, to a hospital.

Consent: in case where you have given a clear consent for us to process your personal data for a specific purpose.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you, process information about your health, any disabilities and allergens that you, or someone on your behalf, volunteers to us to enable us to accommodate your needs.

You have the right to withdraw consent at any time by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

5.    Disclosure

Photos Photiades Distributors Ltd will not disclose your personal information without your prior consent however, depending on the product or service concerned and particular restrictions on sensitive information, this means that personal information may be disclosed as follows:

To Affiliates: We are part of Photos Photiades Group and may share your Personal Data with other companies within our group in order to help accommodate your needs.

Commercial Service Providers and Suppliers: We may outsource the processing of certain functions and/or information to third parties that provide services.

External Partners: We may share your Personal Data with other third party partners including consultants and advisors who provide services to us. Other third parties include financial institutions, external auditors and lawyers.

Third-party links: This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

When we share your personal data with third parties we make sure that they use the same level of protection we use and that they are complainants with GDPR.

6.    How long we keep your information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, primarily for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and also the applicable legal requirements.

In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7.    What are your rights?

In this Section, we have reiterated the rights that you have under data protection law (Your rights are not fully explained in this section). You should read the related legislation, published by the regulatory authorities for complete clarification of these rights.

Your rights under data protection law are:

• the right to access;

You have the right to receive a copy of the personal data PPD holds on you as well as information about how it is used.

• the right to rectification;

You have the right to ask the organisation to correct personal data we hold on you where it is incorrect or incomplete.

• the right to erasure;

This right entitles you to require the erasure of your personal data from the organisation’s systems and records. However, this right applies only in certain circumstances (e.g. where the organisation no longer needs the personal data for the purpose for which we collected it or where you withdraw consent to our use of your personal data and where there is no other legal basis for continuing to use it).

• the right to restrict processing;

This right entitles you to restrict the processing of your personal data by the organisation. Where this right is exercised, the organisation is still permitted to store your personal data but other use of the data is prohibited, save in certain limited circumstances.

• the right to object to processing;

You have the right to object to the organisation’s use of your personal data in certain circumstances. However, the organisation may continue to use your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to use your personal data in connection with any legal claims.

• the right to data portability;

This right allows you to obtain your personal data in a format that enables you to transfer that personal data to another organisation where the organisation is processing your personal data on the basis of consent or on the fulfilment of a contract and if processing is carried out by automated means.  You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.

• the right to complain to a supervisory authority;

You have the right to lodge a complaint with the Data Protection Commissioner if you think that the organisation has not processed your personal data in accordance with data protection legislation and,

• the right to withdraw consent;

You have the right to withdraw your consent to the processing of your personal data by the organisation at any time. This will not affect the lawfulness of our processing before the withdrawal.

If you wish to exercise any of the rights set out above, please contact us through our DPO Office via email at dpo@photiadesgroup.com so we provide you with the necessary information.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you believe that our processing of your personal information trespasses data protection laws, you have a legal right to report a complaint with a supervisory authority accountable for data protection as state above.

8.    Failure to provide personal information

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

9.    Modifications of this policy

We may revise this policy occasionally by publishing a new version on our website.

You may choose to check this page on a regular basis to note any changes to this notice.

We might inform you of significant changes to this policy by email or through a private messaging system on our website.

10.Contact Us

If you have any question about this Privacy Notice or our data protection practices, please contact us by writing to our Data Protection Officer.

Our Data Protection Officer’s contact details are:

E-mail: dpo@photiadesgroup.com

Tel.: +35722471137

Address:  Ellispontou Street 4, 2200, Latsia, Nicosia, Cyprus