This Privacy Policy (hereinafter the “Policy”) governs how the personal data of the visitors and users of https://castigat.net/ (hereinafter the “Website”) are collected, what data are collected, with whom these data may be shared, how long these data shall be stored, and how can you manage your personal data processing (by exercising your rights). Please note, that if you order any Services from Castigat, the terms and conditions of the processing of your personal data shall be governed by the terms of the Agreement, signed between you and Castigat.

What is the definition of Personal Data?

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter “General Data Protection Regulation”, or “GDPR”) defines “personal data” as any data relating to an identified or identifiable natural person (“data subject”). The identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The data about the Data Controller.

GDPR defines a data controller as the natural or legal person, public authority, agency or another body which, alone or jointly with others, determines the purposes and means of the processing of personal data. The data controller of the Website is CASTIGAT INVESTMENTS LIMITED, the Company, incorporated under the Laws of the Republic of Cyprus, under the registration number ΗΕ 311899, with its registered address at Spyrou Kyprianou 79, PROTOPAPAS BLDG, Floor 2, Flat 201, 3076, Limassol, Cyprus (hereinafter the “Castigat”, “We”, “Us”, “Our”).  You can always contact us for all the issues on this Policy and the processing of your personal data by e-mail address support@castigat.net.

Processing of your personal data.

When you use the Website, Castigat does not collect from you any data, that fall within the GDPR`s definition of the personal data. It means that We do not collect your personal data by automatic means.

When you submit a request to Us or contact Us via contact details, you may voluntarily provide to us the data, that may fall within the definition of “personal data”. These data include your name, your phone number, your e-mail, the details about your business or another data, by using which you can be identified.

We use the personal data, collected from you, for the following purposes:

– To contact you in order to provide the Services, offered on the Website;

– To respond to your request, message or e-mail;

– To conduct research and analysis. We may anonymize your data (delete all personally identifiable data from your data file) and then use these data for research and analysis. This procedure will help to find out how our clients use our Services, and what developments and enhancements should we make to meet the interests of our clients.

– To comply with the lawful request of the governmental agencies, state regulators, courts and other cases, when this may be required under the applicable legislation.

Legal basis of the processing of your personal data.

Your personal data is processed in accordance with the provisions of Article 6 of the GDPR, namely:

– Your Consent (Article 6, paragraph 1, point (a) of the GDPR).

– Processing is necessary for the performance of a contract to which you are the subject (Article 6, paragraph 1, point (b) of the GDPR).

– The processing is necessary for compliance with a legal obligation to which Castigat is subject (Article 6, paragraph 1, point (c) of the GDPR).

With whom your personal data, collected by Castigat, may be shared?

– Employees, affiliates, contractors of Castigat. Our Website and our Services are maintained, developed, and operated by a large staff. Thus, your personal data may be shared with those people or entities.

– Service providers. Please note that some of our Services and capacities may be operated by third parties, including host providers, providers of analytics and host providers.

– Governmental authorities when Castigat may be obliged to do this under the applicable legislation.

How long will Castigat store the personal data provided by you under this Policy?

Castigat will store the data, provided by you under this Policy, as long as may be needed for the purposes of the processing. Upon reaching the purpose(s) of the processing, personal data, provided by you, shall be erased. Anonymized data shall be stored for an unlimited period.

Your rights (how can you manage the processing).

As the data subject, you have the rights, which you can exercise by contacting us via email support@castigat.net.

These rights are:

The right to access. You have the right to obtain from Casigat confirmation as to whether or not your personal data is being processed, and, if Castigat indeed processes your personal data, to receive a copy of your personal data.

The right to rectification. You can always ask Castigat for rectification of inaccurate personal data about you.

The right to erasure. You can always ask Castigat to remove all your personal data. We will remove all previously collected personal data if we no longer need these data for the purposes these data were collected.

The right to object to processing. You have the right to object, on grounds relating to your particular situation, to processing of your personal data, if the grounds of this processing were necessary for the purposes of the legitimate interests pursued by Castigat. Additionally, you have the right to object to the processing of your personal data for direct marketing purposes (if applicable).

The right to restriction of the processing. You have the right to obtain from Castigatthe restriction of the processing of your personal data, in case if one of the following applies: a) the accuracy of your personal data was disputed by you; b) the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of the use of your personal data instead; c) Castigat no longer need these data for the purposes of the processing, but this procedure is required by you for the establishment, exercise or defence of legal claims; d) you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of Castigat.

The right to withdraw consent. If you previously consented to the processing of your personal data, you have the right to withdraw this consent at any time. It means that Castigat shall stop the processing of the personal data, for the processing of which the consent was required, starting from the date of the withdrawal. The withdrawal of the consent shall not affect the lawfulness of processing based on consent before its withdrawal.

The right to data portability. You have the right to receive from Castigat the data, which was collected from you, in a structured, machine-readable format and have the right to transmit these data to another controller (simply, to another company). Please note that this right shall be applied only to the data, that was collected by automatic means (if applicable).

The right to lodge a complaint with the supervisory authority. You can always contact Castigat to solve any of the issues concerning your privacy, including complaints. Nevertheless, if you deem, that your rights under the data protection legislation have been infringed, you can lodge a complaint with the Office of The Commissioner for personal data protection of the Republic of Cyprus. The Website of the Commissioner: dataprotection.gov.cy.

Cross-Border Data Transfer (for EU residents).

Please note that due to the global nature of our business your data may be transferred to the third country, data protection legislation in which may differ to the legislation, applicable in the European Union. Castigat singed all the necessary legal documents in order to secure these transfers. It means that all the non-EU recipients of your personal data shall apply all modern standards of the data security and will be legally obliged to follow this Policy and GDPR when processing your personal data. If you do not agree to those transfers, you should stop using our Website.

Third-Party Websites.

This Website may contain links to the third-party Website(s) (“Third-Party Websites”). You understand that these Third-Party Websites are outside the control of Castigat. Сastigat shall not be responsible for any of these Third-Party Websites. Castigat highly recommends you to visit “Privacy Policy” or “Privacy Notice” or another privacy document on the Third-Party Website before submitting any information to the latter.

Changes to this Policy.

Сastigatmay change this Policy from time to time. If Castigat does this, the revised Policy shall be published on the Website. Castigat encourages you to review the Policy whenever you access our Website.  By continuing to use our Website after Policy changes go into effect, you agree to be bound by the revised Policy.