Privacy Policy

1. Introduction

The company ΠΟΛΙΤΗΣ ΤΩΡΑ ΛΙΜΙΤΕΔ (POLITIS TORA LIMITED) together with its affiliated entities (hereinafter referred to as the “Company”), is committed to respecting and protecting the personal data provided to it, as well as any data collected in the course of its operations.

The Company is headquartered at 8 Vasileiou Voulgaroktonou Street, 1010 Nicosia, Cyprus, and is the owner of the websites https://politis.com.cy and https://parathyro.politis.com.cy and https://gipedo.politis.com.cy (hereinafter the “Website”). The Company wishes to inform its readers, visitors, users, members, and subscribers (collectively the “Users”) of the type and scope of personal data it collects and processes as a Data Controller, when Users visit and browse the Website.

The Company assures Users that any processing of personal data is carried out in their best interests, adhering to the principles of lawfulness, transparency, accuracy, availability, and integrity at all stages of processing, and in compliance with the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the Cyprus Law 125(I)/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of such Data, and the relevant guidelines and/or recommendations of the Office of the Commissioner for Personal Data Protection (collectively the “Legislation”).

2. Data Controller

The Data Controller of your personal data is ΠΟΛΙΤΗΣ ΤΩΡΑ ΛΙΜΙΤΕΔ, with registered offices at:

• 8 Vasileiou Voulgaroktonou Street, 1010 Nicosia, Cyprus
• Tel: +357 22 861861
• Fax: +357 22 661583
• Email: dpo@politis.com.cy

3. Collection and Use of Personal Data

The Company collects and processes personal data of Users in the context of providing its services, in accordance with legislation. Data is collected in the following instances:

• When Users register for services and/or subscription packages provided by the Company, including the Politis Premium subscription or other services and/or products offered through its Website
• When Users utilise any of the Company’s products and/or services.
• When Users visit the Website and/or interact with the Company’s promotional or advertising activities.

Upon registration for Politis Premium, the following information is requested:

• Full name
• Residential address (Street, Number, City, Postcode)
• Telephone number
• Email address

These data are processed for the following legitimate and specified purposes:

• Personalisation of user experience and provision of tailored support through content aligned with User preferences
• Fulfilment of the Company’s contractual or pre-contractual obligations
• Delivery of communications concerning new services, offers, or operational changes to the Website, including newsletters consisting of articles, news, and commentary published on the Website
• Compliance with the Company’s legal obligations
• Establishment, exercise, or defence of legal claims
• Journalistic purposes, pursuant to Article 85 of the GDPR and national legislation on press freedom.

In addition, certain data are automatically collected when visiting the Website, such as:

• IP address
• Operating system type and version
• Browser type
• Pages visited and connection/traffic data to and from the Website

Such automated collection serves the purposes of improving the Website’s technical and functional performance ensuring system security, and statistical analysis.The accuracy, completeness, and lawfulness of the personal data provided rests solely with the User. The Company bears no responsibility for any voluntarily provided information which proves to be inaccurate, erroneous, or unlawful.

4. Retention Period

The retention of your personal data is determined based on the nature and purpose of the processing, as well as compliance obligations under applicable law. Where processing is carried out to comply with legal obligations or for the establishment, exercise, or defence of legal claims, the relevant data are retained for the period stipulated by applicable law and/or for as long as necessary to fulfil such purposes, as appropriate to each case.

5. User Rights

Data subject rights are exercised within the limits provided by the GDPR and may be subject to certain legal exceptions or limitations.

To exercise any of the rights below, you may contact our Data Protection Officer at: dpo@politis.com.cy

You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection via www.dataprotection.gov.cy if you believe that the processing of your personal data violates the GDPR.

5.1 Right of Access

You have the right to access your personal data free of charge, except in cases where a reasonable fee may be charged to cover administrative costs in instances of:

• Manifestly unfounded, excessive, or repetitive requests
• Additional copies of the same data.

5.2 Right to Rectification

You have the right to request the rectification of your personal data if they are inaccurate or incomplete.

5.3 Right to Erasure

You have the right to request the erasure of your personal data when they are no longer necessary for the purposes for which they were collected or there is no legal basis for continuing their processing. This right is not absolute, and may be limited where a legal obligation or other lawful basis exists for retaining the data.

5.4 Right to Restriction of Processing

In specific cases, you may request the restriction or suspension of processing. Where processing is restricted, your data will only be stored and not otherwise processed.

5.5 Right to Object

You may object, at any time and for reasons relating to your particular situation, to the processing of your personal data, unless the Company demonstrates compelling and legitimate grounds for such processing.

5.6 Right to Data Portability

You may request to receive the data you have provided in a structured, commonly used, and machine-readable format or request that it be transmitted to another controller.

5.7 Right to Withdraw Consent

You may withdraw your consent at any time, where processing is based on consent. The withdrawal shall not affect the lawfulness of processing carried out prior to such withdrawal.

6. Disclosure of Personal Data to Third Parties

The Company may transfer or disclose Personal Data:

• To Processors who carry out specific processing operations, in whole or in part, on behalf of the Company.
• For the purposes of providing our services, we may share information with our affiliated companies or business partners for internal management, billing, promotion of events, services, and products, and for the overall delivery of our services to you.

We do not disclose, sell, rent, or otherwise share your Personal Data with third parties or unaffiliated entities for their own independent use, unless expressly provided for in this Policy or with your prior consent. We may share data that does not reasonably identify you, to the extent permitted by applicable law.

In addition, we may disclose your data:

• To third-party service providers acting on our behalf, such as web hosting providers, postal service providers, data analytics providers, and technology service providers.
• To law enforcement authorities, other government bodies, or third parties in any jurisdiction, where permitted by applicable law, as required by contract, or where we determine such disclosure to be necessary or appropriate for the provision of our services and products. In such cases, we will make reasonable efforts to notify you before disclosing information that may reasonably identify you, unless prior notification is prohibited by applicable law or is impracticable or unreasonable under the circumstances.
• To our affiliated or partner companies, service providers, consultants, potential transaction counterparties, or other third parties in connection with the negotiation, evaluation, or completion of any transaction in which we are involved, including mergers, acquisitions, liquidations, or business transfers.

We process your personal data on the basis of the following legal grounds:

• Where the processing is necessary for compliance with a legal obligation to which the Company is subject.
• To ensure and improve the quality of our services, products, and Website, in line with your preferences, rights, or consents as required under applicable laws or regulations, including for marketing purposes.
• Consent: we will rely on your explicit consent for activities such as direct marketing or the collection of certain information from your device (e.g., cookies or device identifiers).

Third-party interactions:

Our Website may include content or links to third-party content. This Policy does not govern the privacy, security, or other practices of such third parties. We work with third parties, including data analytics providers, who assist in the operation of our Website. These third parties may use technologies to track your online activities over time and across different websites or platforms. For more information about the use of cookies and your related choices and rights, please consult our Cookie Policy.

7. Data Security

We implement appropriate technical and organisational security measures to protect personal data from loss, unauthorised access, alteration, or misuse. These include:

• Access control systems
• Encryption and anonymisation where required
• Secure storage and transfer protocols
• Restricted access to authorised personnel
• Staff training on data protection
• Incident response mechanisms

Compliance with measures above is subject to periodic review and is updated in accordance with the requirements of applicable law and technological developments.

Despite our efforts, we bring to your attention that no information system can be entirely secure, therefore, we cannot guarantee the absolute security of your information, nor can we be held responsible for the security of any information transmitted to us via networks beyond our control.

Our digital content is maintained and stored in Cyprus or in other countries where our affiliated companies or partners operate. Information may be transferred to countries which may have different data protection and privacy laws or regulations. We may transfer data to countries outside the European Union (EU) or the European Economic Area (EEA) where required by applicable laws or regulations, or subject to your consent. Any transfer of information from the EU to countries outside the EEA will be conducted in accordance with specific legal safeguards, including the Standard Contractual Clauses (SCCs) approved by the European Commission (EC) for such transfers between EU-based controllers and non-EU controllers. These SCCs are available on the official website of the European Commission.

8. Minors

The Company does not knowingly process personal data relating to children or minors under the age of 14, unless such processing is lawful and only to the extent that consent is provided or authorised by the holder of parental responsibility for the child. We will make reasonable efforts, taking into account available technology, to verify that such consent is indeed given or authorised by the holder of parental responsibility in such cases.

9. Updates

You may opt out of future communications by emailing dpo@politis.com.cy or using our opt-out mechanisms.

Please notify us if your data changes or is inaccurate so that we may update it accordingly.

10. Amendments to this Policy

The Company reserves the right to amend this Policy at any time without prior notice to Users. Any updates take effect upon publication on the Website. In the event of any material changes, we will notify you via our Website or through any other digital channels made available Users are advised to consult this Policy regularly before using our services to stay informed of any changes.

By submitting your personal data through Politis Premium or other services offered via the Website, you acknowledge and agree to the terms of this Policy as in force from time to time.