PRIVACY POLICY

 

This Privacy Policy is intended to help you understand the Data Protection Rules and Regulations and how we collect, process, use and store your personal information and data.
By visiting our website and/or any use of it, you unconditionally accept the practices described in this Privacy Policy, which is an integral part and integral to our Terms and Conditions, in conjunction with which it should be read and interpreted.
In the event that you do not accept this Privacy Policy in whole or in part, please cease to visit this Website and/ or make any use of it or its Services.

Purpose and Scope

PROFINITY LTD is a Cyprus Company incorporated under the Laws of Cyprus which has its principal place of business at Panikou Charaki 97, Mesa Geitonia, Panthea, 4007 Limassol, Cyprus, and registered with the Registrar of Companies in Nicosia under number HE422224 (hereinafter the “Company”).
The collection, processing and use of your Personal Data by Us is governed by the provisions of the Cypriot and European Law, such as the provisions of the Personal Data Processing (Personal Protection) of Law 138(I) 2001 and the European General Data Processing Regulation (GDPR) and laws, and/or directives issued pursuant to this Law, as amended from time to time.
This policy applies to former, existing and potential Members as well as to any visitors of the Company’s websites.
Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Data Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Member means any natural or legal person who has entered into a business relationship with the Company and actively using, or has used, the services of our Company until the termination of the business relationship. A prospective Member is a natural or legal person who intends to use our services and has made the initial registration for such use of the services without concluding the business relationship.
Personal Data means any information relating to your which identifies or may identify you and which includes, for example your name, address and identification number.
Third Party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
As data controllers, we determine how we process your personal data, purposes and means. It is our legal obligation to provide you with all of the following information, but we do so primarily out of the belief that a business relationship should be based on honesty.
As data processors we are responsible for ensuring that all processing activities comply with legal requirements, but also with your reasonable expectation of processing your personal data.
We will be your contact point so if you have any questions about the protection of your personal data in PROFINITY LTD you can also contact the Data Protection Officer at any time at the email address: info@profinder.com.cy.

Consent

Consent refers to your right as a data subject to freely and unambiguously agree to a specific condition related to our primary or supporting services by making a positive action. Such action might be a tick box in your client area, signature on a document, electronic signature or name placement in online questionnaires or other similar action. Most of the services provided by our company do not require a separate or explicit consent by data subjects to process their information in connection to the core services of the company when requesting to become a client of a regulated Cyprus investment firm based on the definitions for legal grounds of processing found in Article 6 of the GDPR.
By using (collectively, “Using” or “Use”) our Websites and/or our Apps, registering with us or submitting information to us you consent and agree with the terms of this Policy and you hereby consent to the collect, process, storage, use and disclosure of your personal data by the Company whether such use is by the Company or by another third party which may be required by them in order to effectively perform Services in connection with the Company’s Terms and Conditions or effectively execute any related operational function performed by the Company to its Clients (e.g. refunding Clients with their funds)in accordance with this Policy and as explained below herein. If you do not agree with this Privacy Policy, you must not use our Website and our Apps, access our services or submit information to us.

Privacy is your right

You can follow the steps below to restrict your information to us:
Cookies: You can install more add-ons in the browser that block unnecessary cookies. This will not allow you to view ads of interest. For more information about cookies click here.
Advertising: If you do not want to receive informative communication from us, you can unsubscribe at any time. In this case, we will not be able to send you exciting offers.
No data sharing: If you do not want to share any information with us it is a pity. In this case we will not be able to convince you how wonderful our services are.
You can also use the following permissions at any time:
Right of access
You have the right to be informed about the data we store about you and how it is processed.
Right of correction
If you notice that the stored data is incorrect, you can always ask us to correct it.
Right to delete
You can ask us at any time to delete the data we have saved for you.
Right to restrict processing
If you do not want to delete your data, but at the same time do not wish us to process it further, you can ask us to restrict the processing of your personal data. In this case, we will archive your data and reinstall it in our operating systems only if you wish. However, you will not be able to use our services during this period. In case of possible use of our services we will process your data again.
Right to data portability
You may request that we or another controller send the stored personal data in a machine-readable format. In this context, the data will be given to you in pdf format.
Right to object to the processing of your data
You can revoke your consent at any time or oppose further processing of your data. This also includes objection to processing that we carry out without your consent but based on our legitimate interest. This is true, for example, in direct marketing. You may object to future informational communication at any time. If you do not agree with one of the purposes of the proceedings based on our legitimate interest or want to oppose it, you may object to the processing at any time. Email: info@profinder.com.cy.
Automated decision making
We also process your personal data under algorithms to simplify our procedures. Of course, you have the right not to make decisions based solely on automated processing. If you believe that we have denied your access unjustifiably, you can always contact us at info@profinder.com.cy. In this case, we will consider your request and decide on a case by case basis.
Right to complain
If you believe we have made a mistake with your personal information or rights, you can file a complaint with the appropriate supervisory authority at any time.
The supervisory authority responsible for us is:
Office of the Commissioner for Personal Data Protection
Iasonos 1, 1082 Nicosia
Postal address
PO Box 23378, 1682 Nicosia
Telephone: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
To exercise your rights, you can contact info@profinder.com.cy at any time.
Requests for the exercise of your above rights are completed within 30 days and are provided free of charge. When requests are made electronically, we provide the information in a commonly used electronic form, unless otherwise requested. Although we provide the requested information free of charge, any additional copies and/or repetition of the same request by the subject may incur a reasonable administrative cost.
PROFINITY LTD always aims to provide the requested information as soon as possible, but no later than 30 days from the date of receipt of the application. However, when the retrieval or provision of information is particularly complex or subject to a valid delay, the time limit may be extended by an additional month. In this case, we will notify you by letter within 30 days and will keep you informed of the reasons for this delay.

What data we are processing

In the following description of processing activities, we refer to each category of personal data. A category includes a lot of personal data, which we process simultaneously for a specific purpose. Personal data is information based on which your identity can be verified or made identifiable. In general, we process the following categories of personal data for the following reasons:
Contact details: Name, business and/or personal and/or postal address, business and/or personal telephone number, business email address, social media ID (if applicable).
Reason: If you contact us, we collect this data because we need to know who we are talking to and why so that we can help you. Also, these data will be available online in our website concerning the Members.
Device information and access data: Device ID, operating system and corresponding version, access time, internet connection information (IP address).
Reason: At each access this information is stored by us for technical reasons. We also use some of this information to detect suspicious behaviour in a timely manner and to prevent damage.
Contact info: Full Name, email address, phone number, device ID
Reason: If you want to receive informative communication or notifications, we need some information. We consider it friendlier to address you by your name.

For what purposes do we process data

We process your personal data strictly and only in accordance with legal requirements. We pay special attention to taking into account all the principles for the processing of personal data. PROFINITY LTD pays great attention to transparency. Therefore, we only process your data if it is legal and if you reasonably expect your personal data to be processed. If, during the evaluation, we conclude that the processing is not reasonably expected, we will carry out the processing only with your explicit consent.

Create an account, register through the single access system, manage your profile.

In order to be able to offer you our services, the processing of your personal data is necessary. Much of the data you send us is collected automatically when you use our platform. Nevertheless, we try to keep as little data as possible. You can help us by providing us with only the necessary data we need to fulfil our contractual obligations.

Create Account

When creating an account you will be prompted to enter your basic data. This is absolutely necessary, as we cannot create a user profile without this data. Your email address and phone number are very important data, as we can use them the next time you log in. In addition, we would like to ask you to choose your password carefully. Do not use the same password on multiple sites. Your password must be at least 8 characters long (including uppercase and lowercase letters, numbers, symbols).
Categories of personal data:
Profile data (basic data)
Device information and access data
Legal basis:
Article 6 (1) (b) of the General Data Protection Regulation, performance of the contract.

Connection
If you already have a user account, you will need to enter your email address and password to log in.
Categories of personal data:

  • Profile data (basic data)

Legal basis:

  • Article 6 paragraph 1 (b) of the General Data Protection Regulation, performance of the registration contract
  • Article 6 paragraph 1 (f) of the General Data Protection Regulation, legal interest in security measures

Manage your profile
You can log in to your profile at any time and change your personal information, such as name, phone number and email address.
Categories of personal data:

  • Profile data (basic data)
  • Location data
  • Device information and access data
    information
  • Payment data Payment information

Legal basis:

  • Article 6 paragraph 1 (b) of the General Data Protection Regulation, performance of the contract

Tradition

Once you have successfully requested the service of your preference, various procedures are performed to ensure that the services you have will be provided quickly. The following processing activities describe how and why your data is processed as well as the corresponding processing purposes.

Transfer to our professional workers

We use different professionals to deliver you the best results of the services requested. These may be permanent employees, freelancers or third parties who provide us with professional workers under a service agreement. In all these cases we send your personal data to these professional workers so that they can quickly achieve the desired results.
Categories of personal data:

  • Shipping information

Legal basis:

  • Article 6 (1) (b) of the General Data Protection Regulation, performance of the contract

Calls from professional workers

If a service of your choice is not available or the professional workers cannot find you at the agreed meeting point address you provided, they have received instructions from us to call you to resolve the issue easily and quickly.
Categories of personal data:

  • Shipping information

Legal basis:

  • Article 6 (1) (b) of the General Data Protection Regulation, performance of the contract
  • Article 6 (1) (f) of the General Data Protection Regulation, legal interest when you are called by the professional workers. Professional workers have no claim to your personal information and in no case can they use it for their own purposes. If, however, a professional worker contacts you without your prior consent, we ask that you report it to us immediately at info@profinder.com.cy.

Advertising and marketing

Direct marketing
Informative communication
If you have provided us with your email address when registering and/or purchasing services, we reserve the right to send you regular queries via email. The content of our information communications varies, as the technologies and criteria we use to design our communications and categorize our users into groups differ. We use different information from purchased services history and meeting point addresses. This is a profiling process in which we automatically process your data. This particular customer categorization may have legal or other significant implications for you if you receive certain informational communications that are not included in other campaigns.
If automated decision-making leads to a negative outcome for you and you do not agree with it, you can contact us at info@profinder.com.cy. In this case, we will evaluate your case individually.
Categories of personal data:

  • Contact
  • Data Location data

Legal basis:

  • The processing of data is done exclusively on the basis of our legal interest for personalized advertising according to art. 6 par. 1 (f) of the General Data Protection Regulation. If you object to using your e-mail address for this purpose, we will not send you an e-mail. You have the right to object to the use of your e-mail address for the aforementioned advertising purposes at any time and with future effect either through any e-mail we send you, or through your profile or by informing us at info@profinder.com.cy In this case, the use of your e-mail address for advertising purposes will be stopped immediately.

NPS

We are constantly trying to improve our services. Your constructive comment is very important to us. Therefore, we will occasionally send you polls and ask you to tell us your opinion. If you do not want to receive user polls, you can unsubscribe at any time. In any poll request you can click on the “unsubscribe” at the end of the message and we will not contact you again.
Categories of personal data:

  • Contact details

Legal basis:

  • Article 6 paragraph 1 (f) of the General Data Protection Regulation, legal interest.

Our legitimate interest is the purpose described above.

SMS

In addition to other means, we continue to use SMS to inform about new offers in your area. You will only receive an SMS from us if you have given your consent. You can revoke your consent at any time for the future. Send us an e-mail at info@profinder.com.cy. Registration as well as cancellation is free for you.
Categories of personal data:

  • Contact details

Legal basis:

  • Article 6 paragraph 1 (a) of the General Data Protection Regulation, consent.

Internet marketing

Targeting
First of all, targeting is about activating and displaying ads on web pages tailored to specific groups. Our goal is to display the most attractive advertising messages personalized for our existing and future user. We first assign a group and then outsource to the service providers we work with to show our ad to that group. We do not process personal data, as it has initially become anonymous. To better identify the groups we care about, we categorize users and place different ads on different websites.
Re-targeting
When you visit our website and place a service purchase in your shopping cart without completing it, we store this information in cookies. If you continue to browse other sites, our advertising partners will remind you that you have not yet completed your purchase. We do not want to miss the amazing experience we can offer you. You can turn off targeting by installing the appropriate add-ons for your browser. In addition, you can and should regularly delete cookies stored in the browser you are using.
Categories of personal data:
Contact details
Legal basis:
Article 6 (1) (f) of the General Data Protection Regulation, legal interest.
Our legitimate interest is the purpose described above.

Cookies

In order for the visit to our website/application to be attractive and to make it possible to use certain functions, we use the so-called cookies on various pages. These are small text files stored in your browser. Some of the cookies we use are deleted at the end of the browser session, i.e., after the closure of the browser (the so-called session cookies). Other cookies remain on your device and allow us to identify your browser during your next visit (permanent cookies). You can configure your browser to be informed about the setting of cookies and to decide individually for their acceptance or to exclude the acceptance of cookies for specific cases or in general.
Legal basis:
If the processing is carried out with your consent, the legal basis is Article 6 paragraph 1 (a) of the General Data Protection Regulation, i.e., your consent.
Otherwise, processing is based on our legal interest in accordance with Article 6 (1) (f) of the General Data Protection Regulation.
Our legitimate interest lies in the aforementioned purpose.
You can find our cookie policy in our website.

Fraud prevention and security of our platform

In order to protect our users and our platform from possible attacks, we are constantly monitoring the activities on our site. To this end, we use a variety of technical means to ensure that suspicious behaviours are identified and addressed in a timely manner. To achieve this goal, several monitoring mechanisms are used in parallel that prevent potential intruders from a possible access to our website.

The decision-making process is semi-automated and can have legal consequences for the person concerned or affect him in a similar way.

If semi-automated decision-making leads to a negative outcome for you and you do not agree with it, you can contact us at info@profinder.com.cy In this case, we will evaluate your case individually.
Categories of personal data:
Device information and access data
Contact details
Payment details
Service Purchased Information
Coupon information
Legal basis:
Article 6 (1) (f) of the General Data Protection Regulation, Legal Interest

Mergers & acquisitions, change of ownership

We would like to inform you that in case of merger or acquisition by another company, we will share information with that company. Of course, we will require the company to comply with data protection regulations.
Categories of personal data:

  • Contact details
  • Address of Meeting point information
  • Location data
  • Profile data (basic data)
  • Device information and access data
  • Contact information
  • Payment information
  • Coupon information

Legal basis:

  • Article 6 (1) (f) of the General Data Protection Regulation

The legal interest Our legitimate interest is the purpose described above.

Call center

If you contact us by phone, we save the conversation for quality assurance reasons. In individual cases, we also use the recordings to improve the quality of customer service, i.e., for educational purposes (guidance) with our employees. The content of the information we store depends on the information you provide to us as part of our communications. Saved phone calls are deleted after seven days at the latest or if their purpose, ie quality control, is fulfilled earlier.
Categories of personal data:
Contact details
Services Purchased Information
Legal basis:
Article 6 paragraph 1 (f) of the General Data Protection Regulation, legal interest

Who do we work with and share your data with?

We never provide your data to unauthorized third parties. However, in the course of our work, we receive services from service providers giving them limited and strictly controlled access to some of our data. However, before we transfer personal data to these processing companies on our behalf, each individual company is audited. All data recipients must meet the legal requirements regarding data protection and demonstrate the level of data protection by appropriate technical and organizational means.

Service providers

We use different data processors for our day-to-day processing activities. They process your personal data in accordance with the requirements of Article 28 of the General Data Protection Regulation, only in accordance with our instructions and have no claim to it.
We monitor the processors and only work with those who meet the high privacy requirements we set. Because we use different data processors that we may change from time to time, it is not possible to identify specific recipients of personal information. However, if you are interested, we will share the details of the processor (s) used in the given period, upon request.

Third parties

In addition to the data processors, we also work with third parties, to whom we transmit your personal data, but are not bound by our instructions. These are, for example, our consultants, lawyers or tax experts who take your information from us on a contract basis and process this data for legal reasons or to protect our interests. Under no circumstances do we sell or rent your personal data to third parties. This will never happen without your explicit consent.

Prosecution authorities and legal proceedings

Unfortunately, some of our users and service providers may misbehave and wish to harm us. In these cases, we are not only obliged to provide personal data under legal obligations, it is also in our interest to prevent damages, strengthen our claims and reject unjustified claims.

Responsibility

 

We and the respective operators of social networking platforms act as jointly responsible for processing. When two or more controllers jointly define the purposes and means of processing, they are designated as joint controllers.

Facebook and Instagram social networking platforms are operated by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland.

We are responsible for all interactions with our platforms. Social media operators are themselves responsible for processing data for general interactions and interactions outside of our profiles. The only exception is the data processing described below for usage analysis (Page Info). We are jointly responsible with Facebook for this.

How long do we store your data?

Generally, we delete your data after fulfilling the purpose for which it was collected. Precise deletion rules are set out in national data retention provisions. Different deletion rules apply depending on the purpose of the processing. Through these deletion rules we have defined various categories of data and classified them into deletion rule periods. The data collected is characterized by a deletion rule. At the end of the retention period, the stored data will be deleted accordingly.

We will delete your personal data if you wish and let us know at info@profinder.com.cy.

In addition to the deletion rules we have set, there are other legal retention periods that we adhere to. For example, tax records must be kept for a period of between six and ten years or even longer in some cases. These special retention periods vary according to national legal requirements.

Therefore, despite your request to delete your data, we may need to save some of the data due to legal requirements. In this case, however, we will restrict your data from further processing.

In addition, we will continue to store your data if we have the right to do so in accordance with Article 17(3) of the General Data Protection Regulation. This is especially true if we need your personal information to make, exercise or defend legal claims.

How to Make a GDPR Complaint?

If you have a complaint about the way in which your personal data is being processed, please contact us. In the event that you are not satisfied with our handling of your complaint, you have the right to report your concern to the Data Protection Commissioner at 1, Iasonos Street, 1082 Nicosia, P. O. Box 23378, 1682 Nicosia Tel: (+357) 22818456, Fax: (+357) 22304565 email: commissioner@dataprotection.gov.cy.

Governing Law

Use of this site shall be governed by the Laws of the Republic Cyprus.

Right of modification

We reserve the right to change this data protection policy in accordance with legal provisions. We will notify you of any significant changes, such as changes in purpose or the use of new editing purposes.

 

 

Last updated: September 2021