Privacy Policy of Filuet

Filuet operates the https://filuet.com/ website, through which it promotes and presents its services. Filuet is the controller and responsible for your personal data collected via the website. 

This privacy policy gives you information about how Filuet collects and uses your personal data through your use of this website, including if you choose to share with us any information via our website.

If you choose to use our website, then you agree to the collection and use of information in accordance with the terms of this policy. The Personal Information that we collect are used for providing and improving our website and our services. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at https://filuet.com unless otherwise defined in this Privacy Policy.

Information Collection and Use

Personal data means any information about an individual from which that person can be identified. 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data and Contact Data in case you choose to communicate with us (as per the Contact Us option on our website) and provide us with any such information in your communication. 

• Technical data (Log Data) as per the below. 

We use different methods to collect data from and about you including through:

• through your interactions with us (as per the Contact Us option on our website); and 
• through automated technologies and/or analytics providers.

How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform a contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Log Data

We want to inform you that whenever you visit our website, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP“) address, browser version, pages of our website that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

Any Log Data (to the degree they contain any personal information) are retained for a period of one (1) year.

Cookies

Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.

Our website uses these “cookies” to collection information and to improve our website. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our website.

We only use two types of cookies for the operation of our website. Namely, we use cookies (i) to compile aggregate statistics that allow us to comprehend how users use our website so as to improve the structure of our website and identify and resolve any user related issues and (ii) to perform performance checks of the website.

Cookies are retained for a period of one (1) year.

Marketing

If you choose to provide us with your contact details via our website you may be asked to indicate your preferences for receiving direct marketing communications from Filuet via email.

You can ask to stop sending you marketing communications at any time by contacting us via email.

Third Parties

We may employ third-party companies and individuals due to the following reasons:

• To facilitate the operation of our website;
• To facilitate the provision of or to provide our services on our behalf;
• To perform service-related services; or
• To assist us in analyzing how our website and/or our services are used.

We want to inform our users that these third parties may have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

International Transfers

We do not transfer your personal data outside the EEA.

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Any data you provide us will only be processed on our instructions and they are subject to a duty of confidentiality. 

However, please note that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Children’s Privacy

Our website is not intended to be used by minors. Services do not address anyone under the age of 18. We do not knowingly collect personal identifiable information from children under 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider 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, regulatory, tax, accounting or other requirements.

Where there is no ongoing legitimate business need to maintain and process your personal data, we will retain the personal data for a period of one (1) year.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data. 

Specifically, you have the right to:

• Request access to your personal data (commonly known as a “subject access request“). 

In case you decide to exercise this right, you may request to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you.

In case you decide to exercise this right, you may request to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data in certain circumstances. 

In case you decide to exercise this right, 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 

Please 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 of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). 

Please note that we may, in some cases, demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes. 
• Request the transfer of your personal data to you or to a third party. 

In case you decide to exercise this right, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 

Please 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.

• Request restriction of processing of your personal data. 

In case you decide to exercise this right, you may ask us to suspend the processing of your personal data in one of the following scenarios:

• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• 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
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the contact details below. 

Please note that we will do our best to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.

Our Privacy Policy was created with the help of the Privacy Policy Template.

Complaints

You have the right to make a complaint at any time to the Cyprus Data Commissioner, the Cyprus regulator for data protection issues (https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_el/home_el?opendocument ). 

We would, however, appreciate the chance to deal with your concerns before you approach the commissioner so please contact us in the first instance.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Contact Us

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our Privacy Officer, Maria Tatarnikova, in the following ways at:

• Email address: privacy@filuet.com  
• Postal address: 5 Zenonos street, 3040, Limassol, Cyprus
• Telephone number: +357 25029390