Legal
Privacy Policy
Last updated: 25 May 2025
1. Data Controller
The data controller for personal data collected through this website is Elegant Cyprus Services, with registered office at 8 Ayia Kyriakis, Peyia 8560, Paphos District, Cyprus. Email: info@connect4change.eu. Tel: +357 99 879136.
2. Data We Collect
We may collect and process the following categories of personal data:
- Identity data: name, surname.
- Contact data: email address, telephone number.
- Communication data: messages sent via the contact form or by email.
- Technical data: IP address, browser type and version, time zone, browser plug-in types, operating system and platform, and other technology on the devices used to access this website.
- Usage data: information about how you use our website, products and services.
- Marketing and communications data: your preferences in receiving marketing from us.
We do not collect any Special Categories of Personal Data (such as data about race, ethnicity, religious beliefs, health, sexual orientation, or criminal convictions).
3. How We Collect Your Data
We collect data through:
- Direct interactions: when you fill in the contact form, send us an email, or call us.
- Automated technologies: as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this data using cookies and similar technologies. Please see our Cookie Policy for further details.
4. Legal Basis for Processing
We process your personal data on the following legal bases under the EU General Data Protection Regulation (GDPR) 2016/679:
- Consent (Art. 6(1)(a)): where you have given explicit consent to the processing of your personal data for one or more specific purposes (e.g., marketing communications, cookie consent).
- Contract performance (Art. 6(1)(b)): where processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract.
- Legitimate interests (Art. 6(1)(f)): where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.
- Legal obligation (Art. 6(1)(c)): where processing is necessary for compliance with a legal obligation to which we are subject.
5. How We Use Your Data
We use your personal data for the following purposes:
- To respond to enquiries submitted via the contact form or by email.
- To provide advisory and consulting services requested by you.
- To send marketing communications where you have consented to receive them.
- To improve our website and services through analytics.
- To comply with legal and regulatory obligations.
- To protect our legitimate business interests and legal rights.
6. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements.
- Contact form data: retained for 24 months from the date of submission, unless a business relationship is established.
- Client data: retained for the duration of the business relationship and for 7 years thereafter, in accordance with applicable legal and tax obligations.
- Marketing data: retained until you withdraw consent or object to processing.
- Technical/analytics data: retained for 26 months in accordance with standard analytics practice.
7. Data Sharing and Transfers
We do not sell, rent or trade your personal data to third parties. We may share your data with:
- Service providers: third-party companies and individuals who provide services on our behalf (e.g., IT services, email platforms, analytics providers). These parties are bound by data processing agreements and may only process your data on our instructions.
- Professional advisors: lawyers, accountants and auditors who provide consultancy, legal, accounting and audit services, subject to professional confidentiality obligations.
- Regulatory authorities: where required by law or regulation.
Where we transfer personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.
8. Your Rights Under GDPR
Under the GDPR, you have the following rights in relation to your personal data:
- Right of access (Art. 15): the right to obtain confirmation of whether we process your data and to receive a copy of it.
- Right to rectification (Art. 16): the right to have inaccurate data corrected or incomplete data completed.
- Right to erasure (Art. 17): the right to request deletion of your data in certain circumstances ("right to be forgotten").
- Right to restriction of processing (Art. 18): the right to request that we limit the processing of your data in certain circumstances.
- Right to data portability (Art. 20): the right to receive your data in a structured, commonly used and machine-readable format.
- Right to object (Art. 21): the right to object to processing based on legitimate interests or for direct marketing purposes.
- Right to withdraw consent (Art. 7(3)): where processing is based on consent, the right to withdraw it at any time without affecting the lawfulness of prior processing.
- Right not to be subject to automated decision-making (Art. 22): the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.
To exercise any of these rights, please contact us at info@connect4change.eu. We will respond within 30 days. You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of Cyprus (www.dataprotection.gov.cy) or with the supervisory authority in your country of residence.
9. Security
We have implemented appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security assessments.
However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
10. 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.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this page periodically. Where changes are material, we will notify you directly where we hold your contact information.
12. Contact Us
For any questions, requests or complaints regarding this Privacy Policy or our data processing practices, please contact:
Elegant Cyprus Services
8 Ayia Kyriakis
Cyprus
Email: info@connect4change.eu
Tel: +357 99 879136