- INTRODUCTION
1.1. This website is operated by Tiebreak Solutions Ltd, a company duly registered under the laws of the Republic of Cyprus, with registered number HE368029, having its headquarters and registered office at 14 Charalambou Mouskou, Artemisia Business Centre, 1st floor, Office 101, 2014 Strovolos, Nicosia, Cyprus affiliates (hereinafter interchangeably referred to as the “Company”, “we”, “us” or “our”).
1.2. The purpose of this Policy is to inform visitors and users of the website in relation to the collection and processing of personal data by the Company in accordance with General Data Protection Regulation (GDPR) and any other EU or domestic applicable privacy laws as amended from time to time.
1.3. The Company reserves the right to update this Policy at any time. It is your responsibility to check if any changes have been made to this Policy. We may also notify you in other ways from time to time about the processing of your personal information.
1.4. It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
1.5. This Policy supplements other notices and privacy policies and is not intended to override them.
2. DATA COLLECTION AND PROCESSING PURPOSE
What is personal data?
2.1. Personal data means any information from which the identity of a person can be made. Any personal data that is collected by the Company through the provision of the Services shall be processed according to the privacy laws, as amended or replaced from time to time, and according to the General Data Protection Regulation (EU) 2016/679 (the “GDPR” or “Regulation”).
2.2. The Company may collect, inter alia, the following personal data, when you visit the website or by using the Company’s services, or by interacting and/or submitting your details on the Company’s website:
i. Your identity such as your name/ surname.
ii. Your contact information (email address and phone number).
iii. Your C.V.
iv. Usage Data (through cookies) which includes information about how you use our website, products and services.
v. Your IP address, a unique identifier for your computer or other access devices.
vi. We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal in law, as this information will not directly or indirectly reveal your identity. For example, the Company may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
2.3. The Company does not collect any kind of personal information related to any individuals under the age of eighteen (18) (hereinafter “Minors”). In the event that the Company becomes aware that personal information relates to Minors, the Company shall proceed immediately with their deletion.
2.4. Where we need to collect personal information by law, or under the terms of providing you with the Company’s services and you fail to provide that information when requested, the Company may not be able to provide you with its services.
2.5. The Company does not collect, on this website, any Special Categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor does the Company collect any information about criminal convictions and offences.
Use of Personal Data
The Company may process your personal data for a variety of purposes, including but not limited to, the following:
(a) Performance of its obligations under a contract if one exists or in connection with our provision of services.
(b) Respond to emails sent by you or any other communication.
(c) Assess and communicate with you in relation to your suitability for recruitment services.
(d) To improve our website and our website’s visitors’ and users’ experience quality.
(e) To communicate with you upon request.
(f) To inform or send you material regarding our services upon your request.
(g) Verifying your identity
(h) Complying with applicable laws, regulations, codes of practice, guidelines or as per directions given to us by any law enforcement body.
Pursuant to the applicable data protection laws, we have a legal duty to respect and protect any personal information we collect from you and we will abide by such duty.
Save as otherwise provided in the Terms and Conditions of this website, or unless obliged to comply with any law, regulation or court order, we take all precautions necessary to prevent any unauthorised access and we will not pass and/or transfer any of your details, as collected through this website and any details collected from you as a visitor or user of our services, to any third party.
All personal information communicated to us are kept within our own records in accordance with the applicable laws and regulations.
Controller
The Company, as per the Regulation, is considered to be a data controller and therefore, responsible for the control of your personal data. The Company has appointed a Data Protection Officer (hereinafter the “DPO”) who is responsible for overseeing the implementation of this Policy. If you have any questions in relation to this Policy, including any requests to exercise your legal rights, please contact us at dpo@tiebreak.solutions.
Third Party Links
Our website may contain links to websites operated by third parties. The Company provides these links for your convenience but it does not review, control or monitor the privacy or other practices of websites operated by third parties. The Company is not responsible for the performance of websites operated by third parties or for your business dealings with them. We urge you to read the terms of use and policies of those third-party websites.
Change of Purpose
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Third Country Transfers
Whenever we transfer your personal data out of the EEA, a similar degree of protection is afforded by ensuring the necessary safeguards and safety measures are in place as deemed appropriate under the relevant national or international laws.
- MAINTAINING YOUR DATA
In determining the appropriate retention period for personal data, we take into consideration the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal obligations.
Notwithstanding the above, we shall retain your personal information for as long as we reasonably require it for legal or business purposes and in any case such retention period shall not exceed the period of seven (7) years, unless there is any legal and/or regulatory obligation to do so and/or further retention is permitted by the Regulation. When your personal information are no longer needed, we shall proceed with the deletion of your data. - FAILURE TO PROVIDE PERSONAL INFORMATION
In some occasions withdrawing or not providing your consent will have an impact on us for continuing the performance of services.
You have a choice to supply any or all of the personal data required. However, failure or unwillingness on your part to provide data requested may have as a result failure provision of services. - SECURITY
We endeavour to ensure that your personal data is protected. We strive to protect all data from loss, misuse, unauthorised access or disclosure, alteration, or destruction. The Company maintains policies and procedures and has measures in place in order to ensure high levels of protection of personal data which include, inter alia, appropriate restrictions on permissions of access to personal information, controls and monitoring of storing and distribution of data as well as Data Protection Impact Assessments.
We shall not however be liable for unlawful or unauthorised use of any personal information due to misuse or misplacement of the passwords, negligent or malicious use.
All our employees and providers are required to follow certain privacy and security policies and procedures. With regards to links to web sites controlled or offered by third parties which may appear on this website, we hereby waive any responsibility for the security and privacy of any third party or any information collected by them. It is recommended that a visitor or a registered user always reviews the said providers’ privacy policies. - TRANSFER OF DATA OUTSIDE EEA
The Company does not send your personal data outside the EEA and/or adequacy decision countries. In the unlikely scenario that the Company will need to transfer your personal data outside the EEA, it shall do so by ensuring at least one of the following safeguards is implemented:
i. We will only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal data.
ii. Where we may use certain service providers, we may use specific contracts (i.e standard contractual clauses) approved by the European Commission which provide the same personal data protection, as per the Regulation.
iii. Where the destination of the transfer is U.S., the Company shall comply with the U-U.S. Data Privacy Framework (EU-U.S. DPF).
In the event that your personal data may need to be transferred outside the EEA, relevant notice will be provided to you. - THE USE OF COOKIES ON OUR WEBSITE
8. RIGHTS
You have rights under data protection laws in relation to your personal data. However, those rights may not be exercised in certain circumstances for example if there is an overriding law and/or regulation.
You generally, have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data, in case we collect such, and to check that we are lawfully processing it. We can charge a reasonable fee for providing such record of personal data unless we are not permitted to do so under local laws. We may also need to confirm your identity.
Request to correct personal data. Any incomplete or inaccurate data we might hold about you may be corrected at your request, though we may need to verify the accuracy of the new data you provide to us. - Request erasure. You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing. You also have the right to object in case we will process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or that is needed further to regulatory or legal requirements. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
9. CONTACT US
For any questions or clarifications you may need, or if you wish to file a complaint, please contact us at dpo@tiebreak.solutions . We aim to respond to all data subject requests within one month but it could take us longer. We will in any event acknowledge your email in the first instance. Whilst you have the right to withdraw your consent for us to use your personal data in the future we may first need to ask you to prove your identity.
This version was last updated in July 2023. This version takes precedent over any other versions. We may amend this Policy and post updates to this Policy on our website. It is important therefore that you regularly check the website but rest assured we will inform you of any changes we consider to be important.