Cyprus Trading Corporation Plc (hereinafter “we”, “us” or “our”) operates the website www.ctcgroup.com (hereinafter the “Website”) and is the controller of the information collected or provided via this Website.
- Who we are
Cyprus Trading Corporation Plc (CTC) is a leading Group, based in Cyprus, listed on the Cyprus Stock Exchange registered under registration number HE8958 having its registered office at 200 Lemesos Avenue, 2025 Strovolos, Nicosia, Cyprus.
If you have any questions or comments about our privacy practices or wish to contact us for any reason, please feel free to email us through our Data Protection Officer at firstname.lastname@example.org.
- What is personal data
Personal data is information that may identify you directly or indirectly. Indirectly means in conjunction with other information, such as your name, postal address, email address, phone number, or a unique identification device number.
- Information that this policy applies to
- This Website.
- E-mail, text, and other communications between you and this Website.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries).
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
We will not disclose your information to third parties, except where it is part of providing a service to you. We will only otherwise disclose your information where we have your express permission or we are obliged by the law to do so.
- Purpose of processing personal data
The information we collect automatically is statistical data and includes Personal Information, which we may maintain or associate with Personal Information we collect in other ways or receive from third parties. The above information helps us to improve our Website and to deliver better and more personalized service, enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The processing of personal data is carried out in accordance with the provisions of the General Data Protection Regulation (GDPR 2016/679) and the applicable Cypriot legislation on the protection of personal data.
- Legal bases for collection, use and disclosure of your Personal Information
There are different legal bases that we rely on to collect, use and disclose your Personal Information, namely:
- Compliance with legal obligation: We are permitted to use your Personal Information to the extent that this is required to comply with a legal obligation to which we are subject.
- Performance of Contract: We use your Personal Information where this is necessary for the performance of a contract you are a party to or at your request prior to entering into a contract.
- Information that we collect and how
We collect and use several types of information from and about users of our Website, including information by which you may be personally identified and that is defined as personal data or personally identifiable information under applicable law (“Personal Information”), such as your first and last name, e-mail address or IP address.
Categories of Personal Information we collect and use on or through our Website include:
- Information you provide by filling in forms or registering on our Website, particularly when submitting your CV.
- Records and copies of your correspondence (including e-mail addresses),f you contact us.
- Your search queries on our Website.
- When you access our Website from a mobile device like a tablet or phone, we receive information about your location (IP Address), your device, including one or more unique identifiers for your device.
- Data you provide when registering as a customer or as a member in our database.
- Data you provide when registering a person to receive notifications via e-mail or sms or other commercial communication.
We also collect information automatically, for example, by the use of “cookies”, as outlined in Cookies Policy, and certain types of information when your web browser accesses the Website or when you access content on other websites, which is served by the Website.
- Information collected through automatic data collection technologies
As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including any form of aggregate data, navigational data, location data, click-stream data, or historical data, number of clicks, and how you interact with links on the Website, domain names, landing pages, pages viewed, referral data (e.g. the URL of the last page you visited prior to clicking through to the Website and the address of the exit page when you left our Website), log files and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system and browser, platform type and language, access times, and the content of any undeleted cookies that your browser previously accepted from us. We use this information to track how users are accessing and using our Website.
- Processing of Sensitive Data
In some cases, we may process specific categories of personal data about you (“sensitive data”). For example, we may process sensitive data that you have made public. We may also process sensitive data, as the case may be, to support, exercise, or defend legal claims. We may also process your sensitive data if you have freely given your prior express and separate consent, in a specific context for a specific purpose.
- Recipients of your Personal Information
We may share your Personal Information with our agents, e-commerce partners, contractors, or other service providers, as this may be needed to carry out the performance and functionality of the Website. Such agents, e-commerce partners, and contractors, or other service providers enter into contractual agreements with us by which they observe confidentiality and data protection according to the data protection law and GDPR.
We may disclose your Personal Information for any of the reasons set out hereinabove, or:
- in case we are legally obliged to do so and to protect our rights, property, or safety, our customers, or others
- if we are authorized under our contractual and statutory obligations
- if you have given your consent.
This includes exchanging information with other companies and organizations for the purposes of fraud protection.
We do not transfer your personal data outside the European Economic Area (EEA).
- Management of Curriculum Vitae
By submitting your CV through our Website or via any other means, your personal data is being processed by the companies of the Group for employment evaluation purposes only. We provide you with the option to choose, should you wish to do so, to keep your CV for an additional period of time after the completion of the hiring process for the particular vacancy you have applied for, or for consideration for future potential vacancies, by filling in your details in the online form of our Website and clicking on the available tick-box, available for that purpose. If you do not do this, your CV will be deleted immediately after the vacancy is filled. Additionally, you have the right to retract your consent, as noted below.
Within the same framework, we process all other data you may provide to us or that we may obtain during the evaluation process, such as psychometric tests, which, if the necessary consent is not given, are also deleted immediately after the filling of the specific vacancy along with your other data.
If you have submitted a CV through our Website, we may contact you to update you on the status of your application or other vacancies.
When you communicate with us (via email, phone, through the Site, or otherwise), we may maintain a record of your communication (including call recordings).
- How we protect the security of your Personal Information
We take appropriate security measures (including physical, electronic, and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information.
The safety and security of your Personal Information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We urge you not to share your password with anyone and be careful about giving out information in public areas of the Website like message boards. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
We are protecting the data input by implementing the Secure Sockets Layer (SSL) protocol which encrypts the information you provide. No method of collection, storage, or disclosure is 100% secure, so we cannot guarantee its absolute security.
- Third party sites
Our site may contain links to and from the websites of our partner networks, advertisers, and other third parties. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
- Personal data retention
In general, we will delete the personal data we collect from you if it is no longer necessary to achieve the purposes for which it was originally collected. However, we may be asked to retain your personal data for a longer period of time due to legal provisions.
In addition, we will not delete all your personal data if you have asked us not to contact you in the future. To this end, the Company maintains files that contain information about individuals who do not wish to be contacted in the future (eg via group email). We categorize your request as consent for the storage of your personal data for the purposes of maintaining this file unless you give us different instructions.
- Your rights related to your Personal Information
Subject to local law, you have certain rights regarding the Personal Information we collect, use or disclose and that is related to you, including the right to:
- Receive information on the Personal Information we hold about you and how such Personal Information is used (right to access).
- Rectify inaccurate Personal Information concerning you (right to data rectification).
- Delete/erase your Personal Information (right to erasure/deletion, “right to be forgotten”).
- Receive the Personal Information provided by you in a structured, commonly used, and machine-readable format and transmit those Personal Information to another data controller (right to data portability).
- Object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object).
- Restrict, in some cases, our use of your Personal Information (right to restriction of processing).
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our Website and our services.
You may, at any time, send us an e-mail at email@example.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.
Please note that we may require additional information from you to verify your authorization to make the request and to honor your request.
- Right to lodge a complaint
If you have any concerns about the way we use your personal data, you may address those to the Data Protection Officer at firstname.lastname@example.org.
If you have exercised any or all of your data protection rights and still feel that your concerns are not addressed, you have the right to lodge a complaint to the Office of the Commissioner for Personal Data Protection. Find out on their website how to submit a complaint (http://www.dataprotection.gov.cy).
- Transfer of Business
- No error-free performance
- Contacting us
Cyprus Trading Corporation Plc is the data controller for the purpose of Processing of Personal Data under the General Data Protection Regulation (GDPR).You have the right to access the information which we hold about you and your right of access can be exercised in accordance with the GDPR. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you and this information will be provided within 30 days from the time you requested.
If you have any questions or comments about our privacy practices or wish to contact us for any reason, please feel free to email us through our Data Protection Officer at email@example.com