Posted: June 23, 2021

Elutor understands the significance of Your privacy in a digital age and advocates for strict adherence to personal data protection laws. 

We acknowledge that all users of our website https://elutoragency.com/ (“Website”) are entitled to obtain explicit information about the processing of personal data. Trying to be transparent about the privacy practices we have adopted this Privacy & Cookies Notice (“Notice”).

We are subject to the General Data Protection Regulation (“GDPR”) and implement its principles in personal data processing activity. 

In this Notice we are willing to inform You the following:

1. Important information, including our contact details and the role in personal data processing activity;
2. Personal data we process and sources of personal data;
3. Purposes and legal bases for processing;
4. Personal data retention;
5. Disclosure of Your personal data;
6. International transfers;
7. Your rights as a data subject.

Important information and who we are

This Notice implies to processing of Your personal data in the context of using the Website. 

The Website is operated by Elutor Limited, a company registered under the laws of the Republic of Cyprus, company number C398814, with its legal addressDorieon, 11, Latsia 2232, Nicosia, Cyprus (“Company”, “we”).

When You access and use the Website the Company acts as a data controller within the meaning of Article 4(7) of the GDPR. It means that we determine the purposes and means of the processing of Your personal data and are mainly responsible for security and confidentiality. 

If You need more details regarding the processing of Your personal data or want to exercise Your rights, feel free to contact us at info@elutoragency.com or our legal address stated above.

Personal data we collect and process 

Personal data means any information about You as an individual from which You can be identified. We may collect, use, store and transfer different kinds of personal data which we have grouped as follows:

Type of personal data	Includes
Technical data	internet protocol (IP) address, information about your location, information about your mobile operator or Internet provider; data related to your device: its operating system, browser type, and version, screen resolution, set time zone, language settings, device type: its model and manufacturer (if applicable); information about your browsing session and any interaction with the Website interface (for example, the number of pages you visited, the number of pages you clicked); information about the source from which you visited the Website; cookie data.
Contact data	Your name; Your email; Name of the organization You represent, country of incorporation; Other data voluntarily provided by You.
Search data	Name of the organization, You represent, country of incorporation, characteristics of services and products provided; Information about You available on the organization’s website, public pages on social networks concerning our position, work experience, career, etc.

How we collect Your personal data

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

Method	Description
Direct interaction	You may voluntarily provide us with Your Contact data by filling in a contact form on the Website or corresponding with us by post or email. You may contact us with general questions about our Company, our services, and the Website or to establish pre-contractual negotiation on behalf of an organization You represent.
Automated technologies	As You interact with our Website, we automatically collect from Your browser and process Technical data.
Open research	When You are interested in our Services and contact us, we may conduct further independent research and analysis of information from open sources about You or organization You represent.

Purposes for which we process Your personal data

In this part of the Notice we have set out a description of the purposes we pursue and the legal bases we rely on while processing Your personal data. We have also identified what our legitimate interests are where appropriate.

Purpose	Type of personal data	Legal basis for processing
The Website availability and usability	Technical data	Legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to make our Website available and usable. It means that we are willing to give You access to our Website and its complete functionality.
Correct operation and security of the Website	Technical data	Legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to ensure the proper functioning of the Website without mistakes and minimize any external threats to the Website (cyber attacks, malware).
Improvement of the Website	Technical data	Legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to enhance our Website and make it better for You.
Communication with You	Contact data Search data Technical data	Legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to communicate with You both on general matters and in negotiations before entering into the contract with the organization You represent.
Understanding the specificity of the organization You represent and its activity before establishing business relations	Contact data Search data	Legitimate interest according to Article 6 (1)(f) of the GDPR. Ourlegitimate interest is to understand the context of future communication with prospective clients.

Personal data retention

In compliance with the principle of storage limitation, we will store Your personal data for as long as reasonably necessary to fulfill the purposes we collected it for.

We have determined the following periods of personal data storage:

Type of personal data	Period of personal data storage
Technical data (except for cookie data)	No longer than 14 (fourteen) months from Your last visit to the Website
Contact data and Search data	During our communication with You

Note that we may store Your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Disclosure of Your personal data

We may share Your personal data with third parties for the purposes set out in this Notice. Now the list of recipients includes:

1. Services providers, namely hosting services, analytics services,and providers of other technical solutions. Providing services, they may have access to Your personal data. 

We currently use Google services:Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Dublin, 368047, Ireland that provides Google Analytics services, and Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA that provides reCAPTCHA services. Please read more in Google Privacy Notice. 

1. Employees, contractors, agents, affiliates, external consultants. We may engage a wide range of specialists to conduct our business activity. Since we need to disclose Your personal data to them. We ensure that these persons have committed themselves to confidentiality.

International transfers

We primarily store Your personal data within the EEA; however, we may share Your personal data with the recipients outside the EEA. We inform You that in some cases we may transfer Your personal data to the recipients in third countries within the meaning of the GDPR. Nevertheless, we guarantee a similar degree of protection afforded to Your personal data according to Art. 45 and Art. 46 of the GDPR.

We use the services of Google LLC that is registered in the United States of America. Since the USA does not provide an adequate level of personal data protection, standard contractual clauses (SCC) apply to the transfer of your personal data.

Your rights as a data subject

We guarantee You the following rights:

1. a.The right to be informed (Articles 13, 14 of the GDPR);
2. b.The right to access data (Article 15 of the GDPR);
3. c.The right to rectification (Article 16 of the GDPR);
4. d.The right to erasure (Article 17 of the GDPR);
5. e.The right to restriction of processing (Article 18 of the GDPR);
6.   Right to object (Article 21 of the GDPR);
7. g. Automated individual decision-making and profiling rights (Article 22 GDPR);
8. h. The right to lodge a complaint with the supervisory authority (Article 77 of the GDPR).

If You believe that Your rights have been violated, You can file a complaint with the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our registration). Commissioner’s website: http://www.dataprotection.gov.cy.  

If you are within the EU You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of Your habitual residence or place of work. You can find the list of data protection authorities in the EEA at https://edpb.europa.eu/about-edpb/about-edpb/members_en. 

Review of this Notice 

We keep this Notice under regular review to be usually compliant with the data protection laws. The current version of the Notice will be posted on the Website.

Cookies

Cookies are small pieces of data that can be installed on Your web browser when You use different websites. We use some types of cookies, but we are not interested in identifying You as an individual with the data from cookies. We use the following cookies: 

Name of Cookie	Type of Cookie	Storage time	Purpose of use
_gid	and Analytics Cookies	1 day	Google Analytics uses these cookies in order to analyze how users interact with the Website. With this information, we can improve the Website and Your experience on the Website.
_ga		1 minute
_gat_gtag_UA_157896485_1		1 minute