BIXMON MANAGEMENT LTD
company number: HE 401952
VAT number: 10401952H
15 Nafpliou Street, 2nd Floor, 3025 Limassol, Cyprus
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Issued: February 26, 2020 |
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Company , or Data Controlle r means Bixmon Management Ltd , a company duly registered under the Law of Cyprus with registration number HE 401952, legal address at 15 Nafpliou Street, 2nd Floor, 3025 Limassol, Cyprus GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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) Client , or Data S ubject means user - individual who uses this website and provides his/her P ersonal D ata to the Company Website means www .bixmon.com Policy means this Data protection policy developed by the Company in accordance with GDPR Personal Data means any information relating to an identified or identifiable individual (‘ D ata S ubject’); an identifiable individual 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 individual |
This P olicy applies to all P ersonal D ata processed by the Company .
The Policy applies if the Client uses, has used or has expressed an intention to use or is in other way related to any of the services or goods provided by the Company.
The Company ensures, within the framework of applicable law (GDPR, national law), the confidentiality of P ersonal D ata and has implemented appropriate technical and organisational measures to protect P ersonal D ata from unauthorized access, accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, P ersonal D ata transmitted, stored or otherwise processed.
The Company may use data processors for processing P ersonal D ata. In such cases, the Company takes needed steps to ensure that such data processors process P ersonal D ata under the instructions of the Company and in compliance with applicable law (GDPR, national law) and requires adequate security measures.
Contact details of the Company are available on the Website.
Contact details on P ersonal D ata protection issues: dataprotection@ bixmon.com .
The Policy is available on the Website.
The Company is entitled to unilaterally amend the Policy at any time, in compliance with the applicable law.
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
The Company ensures that P ersonal D ata shall be:
processed lawfully, fairly and in a transparent manner in relation to individuals;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that P ersonal D ata that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
kept in a form which permits identification of D ata S ubjects for no longer than is necessary for the purposes for which the P ersonal D ata are processed; P ersonal D ata may be stored for longer periods insofar as the P ersonal D ata will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
processed in a manner that ensures appropriate security of the P ersonal D ata, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Personal D ata may be collected from the Client and from the Client’s use of the services. Personal D ata categories which the Company primarily, but not only, collects and processes are:
i dentification data such as name, surname, date of birth, data regarding the identification document (such as passport, ID card );
c ontact data such as address, telephone number, email address;
c ommunication data collected when the Client registers on the Website, communicates with the Company via e-mail and messages;
d ata related to the performance of the agreements or the failure thereof, executed transactions, submitted applications, requests and complaints;
d ata about habits, preferences and satisfaction such as the activeness of using the services, services used, personal settings, survey responses, Client satisfaction, the history of the actions using the account by the Client.
All data processed by the Company will be done on the following lawful ground and purposes:
C ontractual basis - for the conclusion and performance of a contract (identification of the Client; client support service; handling and processing of the objections, complaints; billing administration etc.);
C onsent basis – in case of the improvement of services, developing new products and services; advertising of services or commercial purposes; the Client loyalty increasing, satisfaction measurements etc.;
L egitimate interests - in order to protect the Client's and/or the Company`s interest; to provide evidence relating to the contracts and their performance (recordings, submitted documents and other information); prevent, limit and investigate dishonest or unlawful use of the services and products provided by the Company; conduct commercial activity.
The processing of P ersonal D ata for the purpose of providing information to public authorities and subjects of operational activities is carried out on the basis of the fulfilment of the obligations defined by the law, in cases and to the extent established by external regulations.
Where the Company intends to further process the P ersonal D ata for a purpose other than that for which the P ersonal D ata were collected, the Company shall provide the Client prior to that further processing with information on that other purpose and with any relevant further information.
Personal D ata is shared with other recipients, such as:
Authorities (such as law enforcement authorities, tax authorities, supervision authorities and financial intelligence units etc.);
Auditors, legal and financial consultants, or any other processor authorized by the Company;
Debt collectors upon assignment of claims, courts, out-of-court dispute resolution body and bankruptcy or insolvency administrators;
Other persons related to provision of services of the Company (product suppliers, goods sellers, credit institutions and financial institutions, etc.).
Profiling means any form of automated processing of P ersonal D ata, through the use of P ersonal D ata for the purpose of assessing certain Client related personal aspects, in particular to analyse or predict aspects in relation to the Client's personal preferences, interests, behaviour and location.
The Company can apply automated decision - making regarding to the Client. The Client will be informed about such activities of the Company separately in accordance with regulatory enactments.
Automated decision - making that creates legal consequences for the Client may only be made in the course of the conclusion or execution of the agreement between the Company and the Client, or on the basis of the Client's consent.
Data S ubject has rights regarding his/her P ersonal D ata processing. Such rights are:
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Right to withdraw consent : |
where the lawful basis relied upon by the Company is the D ata S ubject’s consent, the right to withdraw such consent at any time without having to explain why |
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Right to be informe d: |
the right to be provided with certain information about how we collect and process the Data S ubject’s P ersonal D ata |
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Right to access : |
the right to receive information if his/her P ersonal D ata is being processed by the Company and if so then to access it; |
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Right to rectification : |
the right to have inaccurate P ersonal D ata corrected or incomplete dated completed
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Right to erasure (right to be forgotten): |
the right to r equire the erasure of his/her P ersonal D ata, for example, that is being processed based on the consent, if he/she has withdrawn the consent. Such right does not apply if P ersonal D ata requested to be erased is being processed also based on other legal grounds such as agreement or obligations based on applicable law
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Right to restrict processing : |
to r estrict the processing of his/her P ersonal D ata under applicable law, e.g. during the time when the Company assesses whether the Client is entitled to have his/her data erased
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Right to data portability : |
to r eceive his/her P ersonal D ata that is provided by him-/herself and is being processed based on consent or in order to perform an agreement in written or commonly used electronic format and were feasible transmit such data to another service provider |
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Right to object : |
the right to o bject the processing of his/her P ersonal D ata, if the use of P ersonal D ata is based on a legitimate interests, including profiling for direct marketing purposes (such as receiving marketing offers or participating in surveys) |
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Right to object to decisions based solely on automated processing (including profiling) : |
the right not to be subject to fully automated decision-making, including profiling, if such decision-making has legal effects or similarly significantly affects the Client. This right does not apply if the decision-making is necessary in order to enter into or to perform an agreement with the Client, if the decision-making is permitted under applicable law or if the Client has provided his/her explicit consent; |
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Right to be notified of a personal data breach : |
the right to be notified of a P ersonal D ata breach which is likely to result in a high risk to the D ata S ubject’s rights or freedoms |
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Right to complain : |
the rights to l odge complaints pertaining to the use of P ersonal D ata to the supervisory authority according to the article 77 of the GDPR, if he/she considers that processing of his/her P ersonal D ata infringes his/her rights and interests under applicable law |
The Client may submit a request for the exercise of his or her rights regarding the processing of P ersonal D ata, including information on possible P ersonal D ata protection breaches:
by e-mail, indicat ing the Client`s registration number and user name to identify the Client, and send to e-mail dataprotection@ bixmon .com ;
on the Company's Website in the created Client Account.
Upon receiving the Client's request for the exercise of its rights, the Company verifies the Client's identity, evaluates the request and executes it in accordance with regulatory enactments.
The Company shall respond to the Client's request in writing or by other means, including, if necessary, in electronic form (by e-mail) taking into account, as far as possible, the manner in which the Client is provided with the response. When requested by the Client, the information may be provided orally, provided that the identity of the Client is proven.
The Company shall provide information on action taken on a request to the Client without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Company shall inform the Client of any such extension within one month of receipt of the request, together with the reasons for the delay.
If the Company does not take action on the request of the Client, the Company shall inform the Client without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
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THIS COOPERATION AGREEMENT ("Agreement") is made by and between
BIXMON MANAGEMENT LTD, company number - HE 401952, VAT number - 10401952H, with legal address at 15 Nafpliou Street, 2nd Floor, 3025, Limassol, Cyprus (hereinafter referred to as "Company) OF THE FIRST PART AND You (hereinafter called as "Business Partner") OF THE SECOND PART. The Company and Business Partner have individually been referred to as "Party" and collectively as "Parties".
NOW THEREFORE, in consideration of the premises, the mutual covenants, terms and conditions and understandings set forth herein, the sufficiency and adequacy of which is hereby acknowledged, the Parties with the intent to be legally bound hereby covenant and agree as follows: