Privacy Policy of MightyTips

Last updated August 24, 2023

This Privacy Policy governs the manner in which SEOBROTHERS CY LTD, with company no. HE 433634 (“We”, “Company”) collects, uses, maintains and discloses information collected from users ("User", “Private person”, “You”) of the mightytips.com website ("Website"). This privacy policy applies to the Website and all products and services offered by the Company.

The purpose of this Privacy Policy is to provide Data Subject (Private persons) with the information regarding the Personal data Processing and Data Protection in accordance with the requirements of the law.

This Privacy Policy explains when where and why we collect personal information about Users, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal information as well as how we keep it secure.

Any questions regarding this Privacy Policy and our services should be sent to email: [email protected] or to legal address: 11 Stratigou Papagou Street, 3091 Limassol, Cyprus.

General provisions

We believe that since you visited Website you are familiar with the main focus of our services and business, and you have also acquainted with our Terms and Conditions. We will point at it once more for better understanding of the purposes your personal information is being collected and processed according to this Privacy Policy. The controller and the processor of the personal data of the users on this Website is the Company.

This Privacy Policy constitutes the integral part of Terms and Conditions. All terms used in this Privacy Policy shall be understood and interpreted as set out in the Terms and Conditions.

We may change the Privacy policy from time to time and indicate the date of the last amendments on the top in the “Last updated” field, so please check this page to ensure that you’re updated with any changes.

Regulation

This Privacy Policy governs the Personal Data Protection and Processing that is carried out with or without automated means, where processing is any kind of operation with Data, including data collection, registration, structuring, requesting, storing, deletion, etc. (see the definitions in cl.4 of the Regulation).

The Regulation means REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Principles of Personal data Processing and Protection shall be observed in all processes of Data Processing, including when servicing existing and potential customers, recruiting new employees and managing information about existing employees, entering into cooperation agreements, initiating new processes and introducing new services, improving data processing technologies, transferring documents for archiving, destroying documents after expiration of storage period.

Personal Data

Personal data is a term defined by the Regulation concerning all types of information that can help to identify Private person using this information or using this information together with other information in Company’s possession (or together with the data Company has access to).

The following Personal data may be processed by Company: Name, Surname, contact information, tax residence, citizenship; information you provide when you enter prize draws, quizzes, competitions or answer surveys, such as information about your lifestyle including your favourite sports, interests and gambling habits, information which we may obtain about you from third parties (for example, because you have given third parties permission to share that information with us), information we collect about how you use the website; customer servicing, and personnel needs, information about users of the Website (cookies, IP address).

Company requests and processes Personal data only when there is a certain purpose and legal basis for the processing.

Personal data can be obtained by Company in various ways, for example, when: (i) conducting a potential customer identification; (ii) receiving a letter or e-mail message from a Private person; (iv) Website is being used by a Private Person; (iii) using information about Private person from Internet resources, requesting information about Private person from various registers, and from other publicly available sources; (iv) reviewing applications in response to job advertisements, when recruiting new employees;

Excluding cases in which we receive your confirmation for the use of your Personal data for other purposes, or when Personal data processing will be necessary in order to protect the Company’s legitimate rights (based on paragraphs a) and f) of the first section of article 6 of the Regulation).

Legal basis for processing of Personal Data

We comply with the principles established by the Regulation namely, personal data:

  • are processed legally, honestly and "transparently" by us;
  • are collected for certain, explicit and legitimate purposes and are not processed further in a way that is incompatible with these purposes ("purposes limitation");
  • are adequate, appropriate and limited to what is necessary for the purposes for which they are processed ("data minimization");
  • are accurate and, if necessary, updated; every reasonable step should be taken to ensure that personal data which were inaccurate, taking into account the purposes for which they were processed, were erased or corrected without delay ("accuracy");
  • are stored in a form that allows identification of users no longer than it is necessary for the purposes for which personal data are processed; ("limitation of storage");
  • are processed in a way that provides proper protection of personal data, including protection from unauthorized or illegal processing, as well as from accidental loss, destruction or damage using appropriate technical or organizational measures ("integrity and confidentiality").

The legal basis for processing of Personal data may be the following:

  • provision of services.
  • compliance with the legal obligation (the relevant activity is governed by the provisions of applicable regulatory enactments of the EU or Cyprus).
  • compliance with public interest or exercise of official authority (the relevant activity is governed by the provisions of applicable regulatory enactments of the EU or Cyprus).
  • protection of the vital interests of Private person or a third party (data processing is carried out, for example, with the purpose to protect life or health of Private person).
  • the legitimate interests of Company (for the purpose of implementing the lawful (legitimate) interests of Company arising from the existing obligations or from the concluded contract, or from the law: (i) to engage in commercial activities; (ii) to maintain applications and submissions regarding the provision of services, other applications and submissions, comments regarding the same, including those made verbally and at Website; (iii) to develop and improve services; (iv) to advertise products and services; (v) to ensure and improve the quality of services; (vi) to apply to the state administration authorities, to the bodies performing operational activities, and to the courts for protection of its legal interests; (vii) to inform the public regarding their activities.
  • the consent of a Private person (the consent of Private person is used as a legal basis, for example, for marketing purposes. Private person has a free choice to give its consent to data processing or not. Private person has the right to withdraw this consent at any time).

Personal Data Recipients

Company does not request from Private person and does not process more information than is necessary to achieve the certain purpose, thus observing the so-called principle of data minimization. The amount of Personal data required for a number of purposes is determined by the regulatory enactments of Cyprus Republic. In other cases, Company itself estimates what information should be requested from Private person in order to be able to achieve the purpose (for example, to provide the certain service), while observing the principle of data minimization.

Company ensures that access to Personal data is restricted to those employees who need it for the performance of their duties.

To minimize the risk of a Personal data breach, Company monitors personal data processing activities, records every incident effecting data protection and takes measures to prevent any further data breaches. Company carries out training of its employees, improves Information Systems and documents circulation procedures.

We may from time to time involve third parties for the processing of Personal data for the purposes indicated above, provided that such processing will be governed by contractual arrangements in the form prescribed by law. These third parties may fall into the following categories:

  • marketing agencies who help us promote ourselves or deliver our services,
  • e-mail service providers who help us to send our newsletters and communications with you have requested from us.

Personal data may also be disclosed to the appropriate governmental, regulatory or executive body in case it is prescribed or permitted by law.

Duration of Personal Data Storage

Personal data is processed for no longer than is necessary to achieve the certain purpose.

The durations of Personal data storage are established taking into account the purpose of Personal data processing and its legal basis, and as long as at least one of these criteria exists:

  • The consent of the Private person to the Private data processing is in force.
  • The Controller needs to fulfill its contractual obligations.
  • The Controller has a legal responsibility to keep the data.
  • The Controller needs to realize its legitimate interests.

You Have the Rights to:

Private person has the following rights regarding the processing of his or her information:

  • to receive information on the type, purpose and legal basis of private data processing;
  • to access your data and obtain approval for your data processing. Upon receipt of Private person request for information on Personal data processing, Company may request Private person to specify in more detail to which information and to which data processing activities the request relates;
  • to rectify their data if it is incorrect or inaccurate;
  • to erase their data or "right to be forgotten", for example, if the data is no longer necessary in relation to the purposes for which it was collected or if Private person has withdrawn his/her consent on which the processing is based;
  • restrict data processing, for example, the accuracy of the Personal data is contested by Private person, Private person no longer needs the Personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defense of legal claims, etc.;
  • to object to processing of data (on grounds relating to Private person’s particular situation) if processing is based on Company’s legitimate interests or public interest. The right to object cannot be realized if the legal basis for processing is the consent of Private person, the establishment and performance of contractual relations, fulfilment of a legal obligation, protection of vital interests of the data subject or third parties;
  • right to data portability or transfer in order to store or to enable the reuse of data, for example, by transferring to another service provider. The right cannot be realized for absolutely all information.
  • you can unsubscribe from receiving e-mail marketing or newsletter communications to which you have subscribed before, by using the instructions in any email communication we send you which will be an ‘unsubscribe‘ or ‘STOP‘ link.
  • file a complaint to the supervising authority about a possible violation of the Regulation.

Company shall examine Private persons’ requests without undue delay and, in any case, inform Private person about the actions performed within a month. Company may extend the period of examination of the claims for another two months on a reasonable basis (for example, large number of requests or complexity of requests).

Profiling

Profiling is automatic Personal data processing of any kind. The Controller does not engage in this practice.

Cookies

We collect anonymous statistics regarding each user’s visits, such as which pages on the website were viewed and for how long. This information can’t be linked back to any specific individual and is collected via Google Analytics. If you wish to opt out of Google Analytics you can do so here, or you can learn more about it here.

Facebook and Twitter may use cookies to track that you are logged in and allow for sharing of our articles. We do not have any access to this information. You can configure your advertising preferences on social media such as Facebook, Twitter or Instagram by accessing your settings or preference options on the relevant platform.

Most web browsers allow some control of most cookies through the browser settings. For more information on this, and more information about cookies in general, you may wish to visit www.aboutcookies.org. For information about how to delete cookies from your mobile phone, you will need to refer to your handset manual. Please be aware that restricting cookies is likely to impact on your ability to use our website effectively and may make areas of our website inaccessible or inoperable.

If you no longer want to receive personalized advertising on any website you visit, you can usually opt-out directly through the privacy policy of the particular website you are accessing. Please note that this will not block ads that are displayed on the websites you visit, it will simply stop you receiving advertising that has been tailored to your interests. This opt-out relies on a cookie, so if you wipe all your cookies then that website will no longer know that you have opted out. The same applies if you use a different internet browser, or use a new computer to access the internet. You can also opt-out of such advertising by visiting the IAB opt-out platform at www.youronlinechoices.com. Please note that this and other platforms allow you to optout of interest-based advertising delivered by registered members.

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