Privacy Policy

This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within the scope of providing our services as well as within our online offering and the websites, functions and content associated with it, as well as external online presences such as our social media profiles (hereinafter jointly referred to as the "online offering"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Information on the Controller

Website operator:

JT Digital Consulting Ltd.
Greenvale Villa 3
Agias Paraskevis
8220 Chloraka (Paphos)
Cyprus
VAT: CY60245644E

Contact:
Email: info@jt-digital-consulting.com
Phone: +357 97 487225
Website: www.jt-digital-consulting.com

Types of Processed Data

• Inventory data (e.g. personal master data, names or addresses).
• Contact data (e.g. email, phone numbers).
• Content data (e.g. text input, photographs, videos).
• Usage data (e.g. websites visited, interest in content, access times).
• Meta/communication data (e.g. device information, IP addresses).

Categories of Data Subjects

Visitors and users of the online offering (hereinafter referred to collectively as "users").

Purpose of Processing

• Provision of the online offering, its functions and content.
• Responding to contact requests and communicating with users.
• Security measures.
• Reach measurement / marketing.

Terminology

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an 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 (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

"Pseudonymisation" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person.

"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.

"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Legal Bases

In accordance with Art. 13 GDPR, we inform you of the legal basis for our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEA, the following applies unless the legal basis is stated in the privacy policy: the legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR; the legal basis for processing to fulfil our services and carry out contractual measures as well as to respond to enquiries is Art. 6(1)(b) GDPR; the legal basis for processing to fulfil our legal obligations is Art. 6(1)(c) GDPR; the legal basis for processing to safeguard our legitimate interests is Art. 6(1)(f) GDPR. The processing of data for purposes other than those for which they were collected is governed by Art. 6(4) GDPR. The processing of special categories of data (in accordance with Art. 9(1) GDPR) is governed by Art. 9(2) GDPR.

Security Measures

In accordance with statutory requirements and taking into account the state of the art, implementation costs and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection commensurate with the risk.

These measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, transfer, availability and separation. We have also established procedures to ensure that data subjects' rights are exercised, that data are deleted and that we are able to respond to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Cooperation with Processors, Joint Controllers and Third Parties

If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of legal permission, where users have given consent, where a legal obligation exists, or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

Transfers to Third Countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or do so in the context of using third-party services or disclosing or transferring data to other persons or companies, this only occurs if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Processing takes place exclusively on the basis of appropriate safeguards pursuant to Art. 44 et seq. GDPR.

Rights of Data Subjects

You have the right to request confirmation as to whether data concerning you are being processed and to be informed about such data, as well as to receive further information and a copy of the data in accordance with statutory requirements.

You have the right, in accordance with statutory requirements, to request the completion of data concerning you or the rectification of incorrect data concerning you.

In accordance with statutory requirements, you have the right to request the immediate deletion of relevant data, or alternatively, in accordance with statutory requirements, to request a restriction of the processing of the data.

You have the right to demand that the data concerning you that you have provided to us be received in accordance with statutory requirements and to request its transmission to other controllers.

You also have the right, in accordance with statutory requirements, to lodge a complaint with the competent supervisory authority.

Right of Withdrawal

You have the right to withdraw any consent given with effect for the future.

Right of Objection

You may object to the future processing of data concerning you in accordance with statutory requirements at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and Right to Object to Direct Marketing

"Cookies" are small files that are stored on users' computers. Different information can be stored within cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offering and closes their browser. "Persistent" cookies are cookies that remain stored even after the browser has been closed.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Excluding cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies set for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/.

Deletion of Data

The data processed by us are deleted or their processing restricted in accordance with statutory requirements. Unless expressly stated within this privacy policy, the data stored by us are deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations.

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require any action on your part (e.g. consent) or other individual notification.

Agency Services

We process the data of our customers in the context of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services.

In doing so, we process inventory data (e.g. customer master data such as names or addresses), contact data (e.g. email, phone numbers), content data (e.g. text input, photographs, videos), contract data (e.g. subject of the contract, term), payment data (e.g. bank details, payment history), usage and meta data (e.g. in the context of the evaluation and measurement of the success of marketing activities). We generally do not process special categories of personal data unless these are components of a commissioned processing. Data subjects include our customers, prospects as well as their customers, users, website visitors, employees and third parties. The purpose of processing is the provision of contractual services, billing and customer service. The legal bases for processing arise from Art. 6(1)(b) GDPR (contractual services) and Art. 6(1)(f) GDPR (analysis, statistics, optimisation, security measures).

Contractual Services

We process the data of our contractual partners and prospects as well as other clients, customers, mandators or contractual partners (uniformly referred to as "contractual partners") in accordance with Art. 6(1)(b) GDPR in order to provide our contractual or pre-contractual services to them. The data processed in this connection, as well as the nature, scope, purpose and necessity of their processing, are determined by the underlying contractual relationship.

The processed data include the master data of our contractual partners (e.g. names and addresses), contact data (e.g. email addresses and phone numbers), as well as contract data (e.g. services used, contract content, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).

Administration, Financial Accounting, Office Organisation, Contact Management

We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The legal bases for processing are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Data subjects affected by the processing are customers, prospects, business partners and website visitors.

Contacting Us

When you contact us (e.g. via contact form, email, phone or social media), the user's information is processed in order to handle the contact request and its processing pursuant to Art. 6(1)(b) GDPR (in the context of contractual / pre-contractual relationships) and Art. 6(1)(f) GDPR (other enquiries). User information may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation.

We delete enquiries when they are no longer required. We review the necessity every two years; statutory archiving obligations also apply.

Hosting and Email Delivery

The hosting services used by us serve to provide the following services: infrastructure and platform services, computing capacity, storage and database services, email delivery, security services as well as technical maintenance services, which we use for the purpose of operating this online offering.

In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offering on the basis of our legitimate interests in the efficient and secure provision of this online offering pursuant to Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

Collection of Access Data and Log Files

We or our hosting provider collect, on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR, data on every access to the server on which this service is located (so-called server log files). The access data include the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to clarify misuse or fraudulent acts) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes are exempt from deletion until the respective incident has been finally clarified.