Privacy Policy

Effective date: 1 December 2018

 

On our website (scm.com.cy, hereinafter referred to as the “Site”), you do not have to give your personal data, but you can indicate them for the purposes described below. We can also receive your personal data automatically according to procedures described below. 

We recognise that your privacy and personal data protection are important and undertake to process and store data responsibly according to the European General Data Protection Regulation ("GDPR").

This Privacy Policy ("Policy") describes the types of information we collect on this Site, including personally identified or identifiable information ("personal data"), purposes for which we use such personal data, with whom we may share the information, the rights and choices available to you regarding our use of your personal data. This Policy also describes how you can contact us about our privacy practices.

Please read this Policy before using or submitting any personal data on the Site.

By accessing and using this Site, you confirm that you have read this Policy and you understand the way we collect, process, use and disclose your personal data. 

As further detailed in Clause 2 below, we will use the data collected on this Site for the purposes of:

  • maintaining and upgrading the Site
  • providing information about the Company's operations
  • processing messages and reports of feedback users
  • processing messages and reports of Trust Line users and responding to the messages
  • storing data about the Site users’ personal preferences and settings
  • improving and developing our products and/or services
  • gathering statistics about Site visits
  • monitoring the status of the user's session (access).

 

1.    Data Controller

SCM Limited company (or "we, "us" or "our") is the controller of your personal data (within the meaning outlined in the GDPR), which are collected and processed through this Site.

SCM Limited
28 Oktovriou, 377 SOBOH HOUSE, 1st floor 
Neapoli, 3107, Limassol, Cyprus

Tel: +357 25245686 
Email: scm@scm.com.cy

 

2.    What kind of data we collect/for which purposes/on which legal basis

a)    Name and e-mail address 

The Site uses a Feedback Form where you can put your name and email address. When completing the form, the data will be saved and can be used for providing you with the information requested or for communicating with you.

Your email address is stored in the system within 36 months after the form is completed. 

The legal basis for such processing of your email address is your consent given by ticking a specific box displayed in the form. You can withdraw your consent to the storage and use of your email address for the purpose described above at any time by sending a request to pd@scm.com.cy. In this case, the specified email address will be deleted and we will no longer be able to contact you, using this email address.

b)    Full name, email address, telephone number and position

The Site features a Trust Line feedback form to report violations at SCM businesses. When completing the form, you can indicate your full name, email address, telephone number and position if you wish so. Reports on violations, other than your personal data, can be transmitted to a limited number of the third parties to investigate an incident you have reported. 

After the Trust Line form is completed, your personal data will be saved and can be used for communicating with you. 

Your data are stored in the Trust Line message database within 36 months after the form is completed. 

The legal basis for processing of data that you may wish to leave in the feedback form, is your consent given by ticking a specific box displayed in the form. You can withdraw your consent to the storage and use of your data left in the Trust Line service at any time by sending a request to pd@scm.com.cy. In this case, the specified email address will be deleted and we will no longer be able to contact you about the investigation of the incident you have reported. 

c)    Automatically collected data

Every time the Site is visited, the system automatically collects information about the device the visitor uses to browse:

  • Type and version of the browser
  • Operating system
  • IP address.

Collection and temporary storage of these data is necessary for the purpose of displaying the contents of the Site on the user's computer properly. The data will be deleted as soon as there is no longer a need for using them – at the end of the session (when the user leaves the Site) or the storage period indicated below in Clause 3 (a) elapses.

We do not link the data automatically collected by the information system to other personal data of individuals.

The legal basis for processing information about your device is your legitimate interest in the proper operation of the Site.

d)    Cookies

A cookie is a file stored on the hard disk of the user's personal computer when he/she visits the Site pages. Such file contains a character set that allows identifying the user's device or browser when he/she visits the Site again.

We use cookies for the following purposes: to make the Site more user-friendly, to personalise the content or settings of the Site, and to collect statistical information anonymously. (We may use statistical information to improve and/or develop our products). Cookies also enable proper operation of some of the Site functions: for example, saving a session when the user navigates through the pages.

The legal basis for such processing of your personal data collected by means of cookies is:
-    The necessity to satisfy legitimate interests pursued by SCM Limited and the third parties, such as maintaining our Site and improving or developing our business operations; or 
-    Your consent given by clicking the ["continue" …] button on the Site cookie banner. You will always be able to withdraw your consent and change your choice by amending your browser settings as detailed below.


The processed cookies are deleted or anonymised after the above processing purposes are achieved, there is no further need to achieve these purposes, or the storage period indicated above expires.

You can limit the use of cookies in your browser settings.

Internet Explorer   |  Edge    |  Safari    |   Chrome    |    Firefox  | Opera


The way you may prevent your data from being used by Google Analytics is detailed in 
Clause 3 (a) below.

Please note that if you change the browser settings, the Site functionality may be limited and some content may be displayed incorrectly.


3.    Personal data recipients or categories of personal data recipients

We collect and store the data, including collection and storage on Google services as detailed below.


a)    Google Analytics

This site uses Google Analytics, Google LLC (“Google”) web-based analytics service, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies. The cookie-created information about your Site visits is sent to a Google server in the United States and stored there.

With the help of cookies, Google Analytics can distinguish unique users, limit the frequency of demands, remember the number and time of previous visits, record the traffic source, determine the start and end of the session, and remember the values of the visitor level user-declared variables. Information about your device (the browser and its version, the operating system) you use to browse the Site can be sent to Google Analytics.

We use the IP anonymising feature on this Site, which means that your IP address will be shortened before it is sent. The IP address that your browser sends to Google Analytics will not be combined with other Google data.

We use the data in the Google Analytics system to maintain statistics and store them no more than 36 months.

Google will use the received information for statistical analysis and reporting, which will help optimise the Site and make it more user-friendly.

You can also prevent Google from collecting and processing the data generated by the cookies regarding the use of the Site (including your IP address) by downloading and installing the browser plug-in at the following link.


b)    Google Maps

This Site uses Google Maps features. Google Maps is a service operated by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. If you visit one of our pages containing Google Maps, you are connected to Google servers. In addition to your IP address, the servers can also identify pages of the Site you are currently visiting.

If you are logged in to your Google Account, Google can add this information to your profile.

We do not have control over these Google Maps features and over the relevant methods of processing of your personal data by Google through such features. We disclaim any responsibility for such processing. You should check Google Privacy Policy to learn about the terms and conditions applicable to your personal data processing, as this Policy applies only to this Site.


c)    Third parties
Please note that sometimes we may need to share your data with our associated companies or other third parties. For any such third parties, we will only disclose your data if you have given your consent or if we are required to do so by law or if it is required for the purposes, or in connection with, legal proceedings or for the protection of legal rights.

4.    Personal data transfers to third countries

The recipients identified in Clause 3 above may be located in the Unites States or other countries outside the EEA, which do not offer an adequate level of protection as determined by the European Commission. In any case, we will only transfer personal data to recipients that provide an adequate level of data protection or we will act as permitted by data protection laws and take appropriate safeguards. 

Google has certified adherence to the EU-US Privacy Shield Framework of the U.S. Department of Commerce. The Framework establishes an adequate level of data protection according to European Commission decision C/2016/4176 (Article 46.2 (f) of the GDPR). The current EU-US Privacy Shield certification is available at
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active#other-covered-entities

 

5.    Your rights regarding the personal data processing

In accordance with the legislation on the personal data protection, you have rights you need to know about.

a)    Your right to access your personal data (Art. 15 of the GDPR).

You have the right to know about the fact that we process or store your personal data. You can exercise this right by requesting a copy of your personal data (hereinafter referred to as the "Access Request").

You can make a written Access Request to the address below (Clause 6) to find out what data are processed and how they are processed.

In addition to receiving copies of the personal data we process, you have the right to know:

  • what your personal data are used for;
  • to whom your personal data are transferred;
  • duration of personal data storage;
  • information about your rights as described in this Clause 5;
  • your right to lodge a complaint with the supervisory authorities;
  • the source of your personal data where the data are not collected from you;
  • whether your personal data are used for automated decision-making, including profiling;
  • whether your personal data are transferred to non-EU countries or international organisations and the appropriate safeguards are provided for such transfer.

We will respond to your Access Request within one month. In certain circumstances, we may inform you that we need additional time to respond to your Access Request, but not more than two months.

Copies of your personal data are free of charge.

We have the right to charge a reasonable fee for administrative expenses if you request additional copies or if your Access Request is “manifestly ill-founded or excessive”.

b)    Your right to rectification (Art. 16 of the GDPR):

You have the right to ask us to rectify the information you consider inaccurate. You also have the right to ask us to complete information that, in your opinion, is incomplete.

For that purpose, you should inform us in writing at the address below (Clause 6):

  • that you question the accuracy of your data and want them to be rectified;    
  • clearly indicate which data you want to rectify or complete; 
  • explain how we should rectify or complete your personal data;    
  • provide evidence of your identity.

We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.

The rectification or updating of your personal data is free of charge.

We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.

c)    Your right to erasure or "the right to be forgotten" (Art. 17 of the GDPR)

You have the right to ask us to erase your personal data without undue delay, particularly if you:

  • withdraw your consent to process your personal data;
  • believe that your personal data are processed unlawfully;
  • object to the processing of personal data for direct marketing purposes.

To exercise your right to erase your data, you should inform us in writing at the address below (Clause 6) about your desire to do it and, if possible, explain why you believe that your personal data are processed unlawfully.

We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months. 

Erasing your personal data is free of charge.

We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.

d)    Your right to restriction of processing (Art. 18 of the GDPR):

You have the right to ask us to restrict your personal data processing (we will only store the data), particularly if you:

  • contest the accuracy of your personal data, for the period of our validation of your personal data;
  • believe that your personal data are processed unlawfully, but object to your data erasure;
  • require your personal data for establishing, bringing or defending against legal claims, although we no longer need your personal data for the processing purposes.

To exercise your right to restriction of data processing, you should inform us in writing at the address below (Clause 6):

  • that you want to restrict your personal data processing;
  • clearly indicate the processing of which data you want to limit.

We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.

Limitation of your personal data processing is free of charge. We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.

e)    Your right to data portability (Art. 20 of the GDPR):

You can exercise your right only with respect to the personal data that concern you and have been provided to us by you. You have the right to ask us to receive such data in a structured, commonly used and machine-readable format and/or to transmit the data to another controller. This right is exercised only if the data processing is based on your consent or necessary for the performance of a contract to which you are party and this processing is carried out by automated means.

To exercise your right to data portability, you should inform us in writing at the address below (Clause 6) about your desire to receive your data or to transmit the data and indicate the contact details of the addressee.

We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.

The transfer of your personal data is free of charge.

We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.

f)    Your right to object to the processing (Art. 21 GDPR):
 
You have the right to object, on grounds relating to your particular situation, at any time, to your personal data processing that is based on our (or third parties') legitimate interests, and we can be bound to stop processing your data, except when we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or data processing is required for establishing, bringing or defending against legal claims. You have the right to object, at any time, to the processing of your personal for direct marketing purposes.

For this purpose, you should inform us in writing at the address below (Clause 6) that you object to your personal data processing and indicate the reason why you object  to it (unless you object to the processing of your personal data for direct marketing purposes). 

We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.

Objecting to the processing of your personal data is free of charge. We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”. 

g)    The right to withdraw your consent (Art. 7(3) of the GDPR):

If you have declared your consent for any personal data processing as described in this Policy, you have the right to withdraw your consent at any time by contacting us at the address below (Clause 6). Such a withdrawal will not affect the lawfulness of the processing prior to withdrawal of the consent.

We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.

Withdrawing your consent of your personal data processing is free of charge.

We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.

h)    Right to lodge a complaint with a supervisory authority (Art. 77 of the GDPR):

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the country where you live, work or where the alleged violation occurred, if you consider that the processing of your personal data violates applicable law.

If you are in one of the EU Member States, you can lodge a complaint with one of the supervisory authorities listed with their contact details at the following link.

If you are in Ukraine, you can lodge a complaint with the Human Rights Commissioner of the Verkhovna Rada, whose contact details are indicated at the following link.

6.    Contact details

If you have any questions about this Policy or if you wish to exercise your rights listed in Clause 5 above, you can contact our personal data protection officer by sending a message to: pd@scm.com.cy

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