Privacy policy

INTRODUCTION

RETAL INDUSTRIES LIMITED and its subsidiaries (“RETAL”) respect your privacy and are committed to protecting your personal information. This Privacy Policy covers both online and offline information that we receive either at our offices directly from you or by post or electronic means, or through our website on the Internet (the “Website”).

The provider of our Website, data controller for the information received through the Website, and the party responsible for data protection and privacy issues in relation to the Website is RETAL INDUSTRIES LIMITED, a limited liability company registered in the Republic of Cyprus under registration number HE 115887 and having its registered office address at Epimitheos, 6 Industrial Area A 3056 Limassol, Cyprus. The companies within RETAL will be the parties responsible for data protection and privacy issues in relation to the personal data that you provide to them directly. The references to “RETAL”, “we”, “us” and “our” are the references to the entity responsible for processing your personal information (“personal information” or “personal data”) as described above. The reference to “you” refers to you as the user of our Website.

In this Privacy Policy, we explain what information we collect, how we use it, with whom we share it, how we protect that information, how long we retain it, and what rights you have in relation to your personal data that we have collected. Please also read the notice issued to you at the time of collection of your personal data, so that you are fully aware of how your personal data are processed. Such notice, provided to you on specific occasions, will supplement this Privacy Policy.

This Website is intended for general audiences over the age of 16. We do not knowingly collect information from anyone under 16 years old. If we become aware that we have collected personal information from a person under the age of 16, we will promptly delete such information from our records.

By accessing this Website or by submitting information to us directly as described above, you accept this Privacy Policy and give your consent to our collection, processing, storage, use and disclosure of your personal data as described in this Privacy Policy.

If you have any questions about how your personal data are processed or wish to make a request regarding any of your rights as set out in the YOUR RIGHTS section of this Privacy Policy, please contact us as indicated in the CONTACT INFORMATION section below.

PERSONAL INFORMATION THAT WE COLLECT

We collect personal data only as necessary for the purposes set out in this Privacy Policy or for such new specific purposes which we will disclose to with you and that you will gave us your consent to. We do not collect excessive information.

Please note that providing your personal information to us is voluntary on your part. Where we are required to collect personal information by law or pursuant to, or for the purposes of entering into, a contract with you or another person, and you choose not to provide us with such information when requested (or to withdraw your consent to processing of your personal data), we may not be able to enter into or perform such contract or comply with legal requirements.

We aim at keeping your personal information correct and up to date.

We do not keep your personal information longer than necessary for the purposes it was collected or to comply with our legal obligations.

We collect information as follows:

• information that you provide directly to us including, without limitation, emails, letters, contracts (including any drafts), purchase (or sales) orders, powers of attorney, and other data medium;
• information that we collect about your use of our Website;
• information that we obtain from third parties or publicly available sources.

We may process personal information from and in relation to users of our Website, candidates for a job with RETAL, employees of RETAL (current and former), individuals who are our customers, suppliers, contractors, or service providers, individuals who are beneficial owners, shareholders or participants in our business customers, suppliers, service providers, business partners, or their employees, representatives, or agents, as well as other individuals stated in this Privacy Policy.

We may collect and process the following types of personal data:

• private and business contact information (name, last name, patronymic, phone and fax number, email and postal address, information about ID documents (including, without limitation, number, date of issuance and expiry, place of issuance, name of the issuing authority), job title, department, name of organization and information about your dealings with RETAL on behalf of yourself or the relevant business customer, supplier, service provider, business partner; other information that may be included into draft contracts, purchase (or sales) orders, powers of attorney, or other documents that you may sent to us);
• biographical and demographical data (including date of birth, age, gender);
• purchase and customer service history (including details of products purchased from us, dates of your orders);
• financial and payment information (including name, billing address and bank account information of a payor or payee);
• browser history, technical and location data (such as date of access, data derived from your internet protocol (such as IP-address), country and postal code, technical information on the devices that you use to access our Website, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website);
• employment-related information (that is, personal information that we receive if you apply for a job with us, such as your employment history, educational history, employment references, and other related information);
• also, to ensure that RETAL is compliant with certain trade control, currency control, anti-money laundering, anti-bribery, anti-corruption laws, and other regulatory requirements, we may additionally carry out screening on existing or potential counterparties before or after entering into contracts, to include screening on individuals such as directors, officers, shareholders or participants, and beneficial owners, performed against publicly available or government issued information and media sources in regard to suspected or actual criminal behavior, criminal records, or proceedings regarding criminal or unlawful behavior, as permitted or required by applicable law in the relevant jurisdiction;
• other personal data you submit to us.

JOB APPLICATIONS

If you apply for a job with RETAL, the following will apply to you as a candidate and to processing of your personal data.

We undertake to protect in accordance with this Privacy Policy all your personal data submitted to us for the purposes of your contemplated employment with RETAL (the “job application”) either unsolicited or in connection with a vacancy posted by RETAL or a job offer sent directly to you. In relation to your job application and personal information provided to us, you will have the rights set out in this Privacy Policy (see the YOUR RIGHTS section below for details).

We process personal data of candidates (including personal contact details) in connection with job applications, interviews and assessments only for legitimate purposes including:

• assessment of the fitness of the candidate to a vacant position;
• obtaining of a work permit or entry visa;
• verifying the information that a candidate provides during the interview process, including verification of information with current or previous employers and educational institutions, subject to a candidate’s consent;
• checking candidates against publicly available or government issued information and media sources, as may be necessary to comply with trade control, anti-money laundering, anti-bribery, anti-corruption laws, and other regulatory requirements;
• checking personal data regarding suspected or actual criminal behavior, criminal records or proceedings regarding criminal or unlawful behavior, that may be performed as part of the pre-employment checking, to the extent permitted or required by applicable law;
• management reporting and analysis, including statistical analysis, regarding quality of the recruitment process;
• internal audits and investigations.

For the purposes of recruitment, personal data concerning health may be processed only as permitted or required by applicable law for the purposes of adjusting the recruitment process, assessing eligibility for positions and fitness for work. Also, we may gather data regarding candidates including their nationality and ethnic origin as may be necessary or required by applicable law (for example, to obtain a work permit or entry visa).

Personal data of candidates is only processed:

• before entering into an employment contract when it is necessary to comply with local employment, social security laws and regulations;
• where it is necessary for the legitimate interests of RETAL (such as ensuring compliance with legal obligations, other than those related to employment or social security, protection of reputation of RETAL or its shareholders or participants, directors, officers, or employees), except where such interests are overridden by the interests or fundamental rights and freedoms of the candidate; or
• otherwise with the explicit consent of the candidate.

In cases where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of the consent.

Your personal data will be processed for the purposes referred to above (and for the related purposes, such as storage), and will only be shared on a need to know basis in accordance with this Privacy Policy with:

• other companies within RETAL, located either inside or outside the Economic European Area (“EEA”); and
• authorized third party agents, external service providers (such as the recruitment service providers) or subcontractors of RETAL, who may carry out reference and background checks on behalf of RETAL, have access to your application, check the information that you provided and your employment references, or contact you in connection with your job application; and
• a competent public authority, government, regulatory or fiscal agency, as may be necessary to comply with a legal or regulatory obligation to which the relevant RETAL company is subject or as permitted by applicable

Your personal information that we receive in connection with your job application will be kept for a period of three (3) years following the completion of the recruitment process. In all cases information may be held (a) for a longer time period if required for the legal or reporting purpose, or (b) for a shorter time period where the candidate objects to the processing of the personal data and there is no longer a legitimate purpose to retain it.

Personal data requested and provided by you as a candidate is necessary for us to fulfil legal requirements and/or to enter into an employment contract with you. Failure to provide the information requested may negatively affect your chances of being selected for any potential employment.

By submitting a job application, or any personal data to us in connection with your job application or otherwise in connection with your potential employment with RETAL (including any of its companies) in any country where we conduct business, you confirm and agree with the following:

• you have read and understood this Privacy Policy;
• we may process your personal data for the purposes set out in this Privacy Policy, including to process your job application, and to determine whether you may be suitable for other positions available within RETAL in any country where we conduct our business.

EMPLOYEES

If you are an employee of RETAL, we may process your personal data as follows:

• to comply with our obligations, to comply with applicable laws and regulations (including, without limitation, social security);
• for legitimate business interests (for example, to ensure that we have qualified and competent personnel or for health, safety and security purposes to ensure that only authorized personnel can access certain sites or assets); or
• where we have your explicit consent, including if such consent is required by applicable laws.

Personal data requested from RETAL employees is the minimum required in order to fulfil legal and/or contractual requirements or to provide a benefit. Failure to provide us with the information requested may negatively affect your ability to remain in employment or receiving a benefit.

When processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent. Withdrawal of the consent may however impact your ability to remain employed or receive a benefit.

USE AND SHARING OF INFORMATION

We may disclose or share your personal data as set out in this Privacy Policy or otherwise with your consent.

We may use information that we collect (and may combine it with other information about you) for the following purposes:

• Customer service. We may process your personal data in response to your enquiries in connection with the products you ordered, the status of your order, dates of shipment and delivery, payment details, delivery address, your feedback on our products, and other matters.
• Communication. We may use your personal information when we communicate with you, for example when you contact us with any questions or when we process and respond to your requests and enquiries.
• Entry into and performance of contracts. We may use your personal data in connection with entry into and performance of the contracts with you.
• Improving our Website. We may analyze information about how you use our Website so that we can improve your experience on our Website.
• Research and development. We may use your personal data for research and development purposes, including improving our customer support, products and processes.
• Business operations and internal administration. We may use your personal information to operate and improve our business or manage our employee resources.
• Processing job applications, employment matters, and management of our personnel. We may process your personal data for recruitment purposes or for the employment matters and the purposes of management of our personnel.
• Exercising our legal rights. We may use your personal information to exercise our legal rights, including receipt of payment for the products sold and debt collection or to enforce the terms and conditions of any contract. We may use your personal information, for example, where we believe it is necessary to investigate, prevent or take action regarding illegal activities, to protect our rights, safety, privacy or property, to prevent a possible physical harm or financial loss, to respond, detect and investigate fraud claims or intellectual property infringements, or violations of law.
• Compliance and dispute resolution. We may use your personal information for reporting to the governmental authorities as required by law or to comply with a court order or a legitimate request from the law enforcement authorities. We may use your personal information in response to legal proceedings, or to defend our legal rights in case of a dispute where we need to establish, exercise or defend legal claims, or to enforce a court judgement or an arbitration award.
• Mergers or acquisitions. In the event any RETAL company or its assets are, or are prepared to be, acquired by or merged into another company including private transactions, public offering or through bankruptcy, we may share your personal data with any of our prospective or actual acquirers and legal successors, as may be necessary to comply with our obligations and to protect our rights in connection with such merger or acquisition, or bankruptcy.
• Other. We may also use information that we collect in ways described to you in a notice sent to you at the time of collection, or otherwise with your consent.

We may share your information with the following parties:

• subsidiaries within RETAL (including their shareholders or participants, officers, directors and employees) – on a need to know basis for the purposes outlined in this Privacy Policy;
• our business partners, counterparties or external service providers, contractors, suppliers, agents, and advisors (including, without limitation, auditors and legal advisors) – companies that supply goods or provide services to or on behalf of RETAL;
• external debt collectors and credit reporting agencies – when we employ credit reporting agencies to confirm your creditworthiness or debt collectors to collect debts;
• third party recipients in connection with a merger, acquisition or bankruptcy – we may provide your personal data to actual or prospective acquirers and legal successors in connection with a merger, acquisition or bankruptcy to the extent necessary to comply with our obligations or to protect our rights in connection with such merger, acquisition or bankruptcy;
• law enforcement, courts of law and regulatory authorities—when we are required to do so or to protect the legitimate interests of RETAL.

Our legal basis for processing your personal data will be one of the following:

• your consent;
• processing is necessary for the performance of a contract with you or another person, or in order to take steps at your request prior to entering into a contract;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the individuals concerned;
• processing is necessary for compliance with a legal obligation to which RETAL is subject; or
• processing is necessary to protect your or other party’s vital interests.

Our Website may include links to third party websites and applications. Clicking on these links or using applications may allow third parties to collect or share data about you. We do not control these third-party websites and applications and we are not responsible for their privacy statements. We encourage you to read the privacy statements of the websites you visit.

DATA TRANSFER

Your personal data may be processed either inside or outside the EEA. When processed outside the EEA, we ensure that the appropriate safeguards are provided as follows:

• we only transfer your personal data to countries that are deemed to ensure an adequate level of protection of personal data by the European Commission, providing the personal data the appropriate safeguards as required in accordance with the EU General Data Protection Regulations; or
• we use the Standard Contractual Clauses approved by the European Commission, providing the personal data the appropriate safeguards as required in accordance with the EU General Data Protection Regulations; or
• we have received your explicit consent to such transfer; or
• transfer is necessary for the purposes of compelling legitimate interests pursued by us which are not overridden by your interests or rights and freedoms.

COOKIES

We use cookie files and other similar technologies (“cookies”) on our Website to personalize and enhance your experience as a user of our Website. For additional information about your choices in relation to our use of cookies, what types of cookies we use and how we use them, please refer to our Cookie Policy posted on the Website.

Our Cookie Policy applies together with and supplements this Privacy Policy. By using our Website, in addition to this Privacy Policy you agree to be also bound by our Cookie Policy.

YOUR RIGHTS

You have certain rights under the applicable data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us as indicated in the CONTACT INFORMATION section below. You have the following rights:

• Right of access. You have the right to access, review and request a physical or electronic copy of your personal data undergoing processing, including the right to be provided with information from which source the personal data originates, and if applicable, whether it came from publicly accessible sources.
• Right to rectification. You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you; and have the right to have incomplete personal data completed.
• Right to erasure (right to be forgotten). You have the right to obtain from us the erasure of personal data concerning you without undue delay, where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw your consent and where there is no other legal ground for the processing; (c) you object to the processing pursuant to the specific legal grounds relating to your particular situation and there are no overriding legitimate grounds for the processing or where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; (d) the personal data have been unlawfully processed; (e) the personal data has to be erased for compliance with a legal obligation to which RETAL is subject.

This right may not apply in cases set out by applicable law, including the compliance with a legal obligation to which RETAL is subject or the establishment, exercise or defense of legal claims.

• Right to restriction of processing. You have the right to obtain from us restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of personal data;

(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; (c) we no longer need your personal data for the purposes of processing but you required them for the establishment, exercise or defense of legal claims; (d) you objected to processing of your personal data on grounds relating to your personal situation, but the verification is pending whether exist the legitimate grounds for us to override your objection.

• Right to data portability. You have the right to receive the personal data concerning you, either yourself or require us to send it to a third party of your choice in a structured, commonly used and machine-readable format, where (a) the processing is based on your consent, or (b) the processing is necessary for the performance of a contract with you and (c) processing is carried out by automated means.
• Right to object. You have the right to object, on a ground relating to your particular situation, at any time to processing of personal data concerning you. Where processing is necessary for the purposes of legitimate interests pursued by RETAL or by a third party, we should demonstrate that such legitimate interests override your interests or the fundamental rights and freedoms.
• Right to withdraw consent at any time. Where we are relying on your consent in processing your personal data, you may withdraw your consent at any time. However, this will not affect the lawfulness of any processing performed before your withdrawal of the consent.
• The right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority depending on the country where you are located, if you believe that we do not properly process your personal data. You can lodge your complaint in relation to activities of RETAL INDUSTRIES LIMITED in Cyprus with the following supervisory authority in Cyprus:

Commissioner for Personal Data Protection

Iasonos 1,

1082 Nicosia,

Cyprus

Postal address:

P.O. Box 23378,

1682 Nicosia,

Cyprus

Tel: +357 22818456; Fax: +357 22304565

Email: commissioner@dataprotection.gov.cy

EXISTENCE OF AUTOMATED DECISION-MAKING

Our Website contains an automated decision-making mechanism, which is used to determine the user location. You have the right to object to the use of this mechanism. If you wish to exercise this right, please contact us as indicated in the CONTACT INFORMATION section below.

SECURITY

We have in place the appropriate technical and organizational measures to protect the personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and which provide a level of security appropriate to the risk represented by the processing and the nature of the data to be protected. We have in place procedures so that any third party we authorize to have access to the personal data will respect and maintain the confidentiality and security of the personal data and will process the personal data only on our instructions.

RETENTION

In accordance with applicable law, we will only retain your personal data only for the period necessary to fulfill the purposes for which it was collected. We may also have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period referred to above (as may be necessary, without limitation, to satisfy any legal or reporting requirements imposed on us).

CONTACT INFORMATION

If you have any questions about this Privacy Policy or the manner in which your personal data are processed, or if you wish to exercise any of your legal rights as specified in this Privacy Policy, please contact us at

RETAL INDUSTRIES LIMITED
Epimitheos, 6 Industrial Area A,
Limassol, 3056, Cyprus

info@retalgroup.com

UPDATES OF PRIVACY POLICY

This Privacy Policy may be updated from time to time, so we recommend you checking for updates each time you visit our Website or submit your personal information to us.

Last updated: March 2020.

COOKIE POLICY

INTRODUCTION

RETAL INDUSTRIES LIMITED and its subsidiaries (“RETAL”, “we”, “us” or “our”) may collect information (“information” or “data”) about users of our website on the Internet (the “Website”) using cookie files (“cookies”) to improve your user experience on our Website. We use cookies in accordance with this Cookie Policy (the “Cookie Policy”).

Not all cookies collect personal data. We treat information collected by cookies as personal data when it can be directly or indirectly associated with a particular user of our Website. For more information about how we use the personal data collected by cookies please refer to our Privacy Policy posted on the Website. This Cookie Policy applies together with and supplements our Privacy Policy.

Please note that this Cookie Policy does not apply to third party websites that may be linked to our Website and we are not responsible for privacy practices of such websites. We recommend you reading the cookie policies of third party websites when you visit such websites.

YOUR CONSENT TO USE COOKIES

By using our Website, you consent to our use of cookies in accordance with this Cookie Policy and our Privacy Policy.

We aim at providing you with enough information, so that you could make an informed choice regarding our use of cookies. You may choose to accept our use of all cookies or specific types of cookies only. After you have made your choice, you can change it and withdraw your consent any time as described in the “How to Control and Delete Cookies” section below.

WHAT ARE COOKIES?

Cookies are small text files that are managed by your browser and placed on your computer, smartphone, or another device when you visit our Website. A cookie file is stored on your device and allows us or our third-party partners to recognize you and make your visit easier and more useful to you when you revisit our Website. We may use third parties to assist us in collecting or processing information obtained through cookies.

TYPES OF COOKIES USED BY OUR WEBSITE

Necessary cookies

Necessary cookies are essential to navigate through our Website and use its features. The Website cannot function property without these cookies. These cookies do not collect any personal information about you that may identify you as a user simply through the cookies.

Preference Cookies

Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

COOKIES USED BY THIRD PARTIES

Statistics cookies

Statistics cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.

Marketing cookies

Marketing cookies are used to track visitors across websites. The intention is to display ads that are most relevant and engaging for the individual user, and thereby more valuable for publishers and third-party advertisers.

OTHER TRACKING TECHNOLOGIES

Apart from the cookies described above, this Website does not use any other tracking technologies. We will update this Cookie Policy, if there are any changes in the future.

HOW TO CONTROL OR DELETE COOKIES

You may choose to accept or refuse cookies. When you visit this Website for the first time (or after you have deleted our cookies by using your browser settings), you will see a popup window with a menu. You can choose which cookies you accept by ticking the relevant boxes on the menu and clicking the “OK” button to express your consent. Click the “Show Details” button to receive more information and facilitate your choice. However, if you choose not to accept cookies, our website may not be able to function properly to the full extent.

We will not use any cookies that you choose to opt out. However, we still may use the necessary cookies that allow our Website to function.

After you have made your choice about use of cookies, you will always be able to withdraw your consent and change the cookie settings on our Website any time by using the link “Renew or change your cookie consent” on our Website.

Also, you may restrict our use of cookies through your web browser settings. You may set up your browser to accept or refuse cookies, or to be notified when a cookie is sent to you, and choose whether you accept it. Also, you may delete all cookies at the end of each browsing session. Check your browser’s help section to find out how to manage your cookie settings.

CONTACT INFORMATION

If you have any questions about our use of cookies or this Cookie Policy, please contact us via email info@retalgroup.com.

Changes to this cookie Policy

This Cookie Policy may be updated from time to time. We recommend you checking for updates each time you visit our Website.

Last updated: March 2020.