Legal

Privacy Policy

Information on the processing of your personal data

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. Detailed information on data protection can be found in the privacy policy set out below this text.

Data collection on this website

Who is responsible for collecting data on this website?

Data processing on this website is carried out by the website operator. You will find their contact details in the section headed “Information on the controller” in this privacy policy.

How do we collect your data?

Some of your data is collected because you provide it to us. This may, for example, be data you enter in a contact form.

Other data is collected automatically, or with your consent, by our IT systems when you visit the website. This is primarily technical data (for example your internet browser, operating system or the time the page was accessed). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected in order to ensure that the website is provided without errors. Other data may be used to analyse how you use the site. Where contracts can be concluded or initiated via the website, the data transmitted is also processed for contract offers, orders or other enquiries.

What rights do you have regarding your data?

You have the right at any time to obtain information, free of charge, about the origin, recipients and purpose of the personal data stored about you. You also have a right to request that this data be corrected or erased. If you have given consent to data processing, you may withdraw that consent at any time with effect for the future. You also have the right, in certain circumstances, to request that the processing of your personal data be restricted. In addition, you have a right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the subject of data protection.

Analytics tools and third-party tools

When you visit this website, your browsing behaviour may be analysed statistically. This is done primarily using so-called analytics programmes. Detailed information on these analytics programmes can be found in the privacy policy below.

2. Hosting

We host the content of our website with the following provider: lima-city (TrafficPlex GmbH).

External hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host or hosts. This may primarily involve IP addresses, contact requests, metadata and communications data, contract data, contact details, names, website access data and other data generated via a website.

External hosting takes place for the purpose of performing our contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (for example device fingerprinting) within the meaning of the TDDDG. Consent may be withdrawn at any time.

Our host or hosts will process your data only to the extent necessary to fulfil their performance obligations and will follow our instructions in relation to this data.

We use the following host:

Hosting provider
TrafficPlex GmbH
Konsul-Smidt-Str. 90
28217 Bremen, Germany

Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the service named above. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General information and mandatory disclosures

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection provisions and this privacy policy.

When you use this website, various items of personal data are collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would point out that data transmission over the internet (for example when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

We use lima-city as a platform for managing our website, for lead generation and for our email marketing. The provider is TrafficPlex GmbH, based in Germany. Personal data collected via our forms (for example name, email address) is stored on lima-city's servers. We have concluded a data processing agreement with lima-city. Further information on data processing by lima-city can be found in their privacy policy.

Information on the controller

The controller responsible for data processing on this website is:

Controller
Luca Bellanti Consulting Ltd
Represented by its Director: Gian Luca Bellanti
Palaion Patron Germanou 11
8011 Paphos, Cyprus

Phone: +357 97 848671
Email: contact@nostos-cy.com

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of processing personal data (for example names, email addresses or similar).

Retention period

Unless a more specific retention period is stated within this privacy policy, your personal data will remain with us until the purpose for processing it no longer applies. If you assert a justified request for erasure or withdraw your consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (for example retention periods under tax or commercial law); in the latter case, deletion will take place once those grounds cease to apply.

General information on the legal bases for data processing on this website

Where you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, where special categories of data under Art. 9(1) GDPR are processed. In the case of express consent to the transfer of personal data to third countries, processing is additionally carried out on the basis of Art. 49(1)(a) GDPR. Where you have consented to the storage of cookies or to access to information on your device (for example via device fingerprinting), the processing is additionally carried out on the basis of § 25(1) TDDDG. Consent may be withdrawn at any time. Where your data is required for the performance of a contract or for pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, where your data is required to fulfil a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest under Art. 6(1)(f) GDPR. The legal bases applicable in each individual case are set out in the following sections of this privacy policy.

Recipients of personal data

In the course of our business activities we work with various external parties. In some cases this also requires the transfer of personal data to these external parties. We only pass personal data on to external parties where this is necessary for the performance of a contract, where we are legally obliged to do so (for example disclosure of data to tax authorities), where we have a legitimate interest in the disclosure under Art. 6(1)(f) GDPR, or where another legal basis permits the disclosure. Where we use processors, we pass on our customers' personal data only on the basis of a valid data processing agreement. In the case of joint processing, a joint controllership agreement is concluded.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You may withdraw consent you have already given at any time. The lawfulness of the data processing carried out up to the point of withdrawal remains unaffected.

Right to object to data collection in particular cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS THE PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES TO ESTABLISH, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of breaches of the GDPR, data subjects have a right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. This right to complain is without prejudice to any other administrative or judicial remedy.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done where it is technically feasible.

Information, correction and erasure

Within the framework of the applicable statutory provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to have this data corrected or erased. You can contact us at any time regarding this and any other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do so. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of the personal data we hold about you, we will usually need time to verify this. For the duration of that verification, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was or is unlawful, you may request the restriction of the data processing instead of erasure.
  • If we no longer need your personal data but you require it to exercise, defend or establish legal claims, you have the right to request the restriction of the processing of your personal data instead of its erasure.
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. For as long as it has not been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may, apart from being stored, only be processed with your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL and TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the padlock symbol in your browser bar.

When SSL or TLS encryption is enabled, the data you transmit to us cannot be read by third parties.

Objection to marketing emails

The use of contact details published as part of the legal notice obligation for the purpose of sending unsolicited advertising and information material is hereby prohibited. The operators of these pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising, for example by spam email.

4. Data collection on this website

Cookies

Our web pages use so-called “cookies”. Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are deleted automatically at the end of your visit. Persistent cookies remain stored on your device until you delete them yourself or until they are deleted automatically by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies make it possible to integrate certain services of third-party companies within web pages (for example cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary because certain website functions would not work without them (for example the shopping basket function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions you have requested (for example the shopping basket function) or to optimise the website (for example cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is stated. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of that consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent may be withdrawn at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are disabled, the functionality of this website may be limited.

You can find out which cookies and services are used on this website in this privacy policy.

Contact form

If you send us enquiries using the contact form, the details you provide in the enquiry form, including the contact details you give there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass this data on without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR where your enquiry relates to the performance of a contract or is necessary for pre-contractual measures. In all other cases, processing is based on our legitimate interest in effectively handling the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) where this has been requested; consent may be withdrawn at any time.

The data you enter in the contact form will remain with us until you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies (for example once your enquiry has been dealt with). Mandatory statutory provisions, in particular retention periods, remain unaffected.

Enquiry by email, telephone or fax

If you contact us by email, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass this data on without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR where your enquiry relates to the performance of a contract or is necessary for pre-contractual measures. In all other cases, processing is based on our legitimate interest in effectively handling the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) where this has been requested; consent may be withdrawn at any time.

The data you send us via contact enquiries will remain with us until you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies (for example once your request has been dealt with). Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

Data protection contact

If you have questions about the processing of your personal data, you can reach us at contact@nostos-cy.com. Full provider details can be found in the legal notice.