Privacy Policy
This Privacy Policy describes the method of data collection and its usage by CTC AUTOMOTIVE LTD (the “Company”).
The Company is committed to protecting your privacy and ensuring that your personal data are processed in accordance with all applicable data protection, privacy and electronic communications laws and regulations in force from time to time.
What is personal data?
‘Personal Data’ means any information relating to an identified or identifiable natural person (‘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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Gathering information
• information upon subscription to the newsletter, provided that you have explicitly consented to receiving marketing communications
• information upon the registration of a person to receive notifications via e-mail or sms or other commercial communication channels
• information that is automatically received when a user navigates on the website through the use of cookies and similar technologies (to learn more refer to the cookie policy)
• information when communicating with the Company (e.g. by email, social media, telephone).
The personal data collected may include:
• name,
• email address,
• telephone number,
• any information you choose to include in your message.
Purpose and Legal Basis of Processing
Personal data are processed solely for the following purposes:
• responding to your enquiries,
• sending newsletters, updates and marketing communications, only where you have given your explicit consent.
The legal basis for processing is your consent, in accordance with the law. You may withdraw your consent at any time.
Access to Information:
By providing your personal data you consent that your data will be used by the Company’s employees and partners for the reasons mentioned above.
Under no other circumstances may the Company share your personal information with others without your prior consent, unless required through any legal route. Please note that under certain conditions it is permitted, when required by law or on the basis of a court order, to collect, use and disclose of your personal data, which have been collected online without your prior consent (such as the case of a court order).
Use of personal data
Your personal data will be used for the purposes described above. We collect and process as much personal data as is necessary to meet the required purpose. If we will use your personal data that we process with your consent, for purposes other than those disclosed in such consent, we will inform you in advance and, in cases where the processing is based on your consent, we will use your personal data for a different purpose only with your permission.
For existing customers, we may use the information we have received as part of our existing customer relationship to inform you for products or services related to similar products or services that you have previously requested, used, or may be of interest to you. You may, however, object to such use at any time either at the time that your data is collected or whenever you send a message. To stop receiving emails for marketing purposes, follow the instructions in the email you receive.
Transfers of Businesses
In connection with any reorganisation, restructuring, merger or sale or other transfer of assets (known as “Transfer of Businesses”), we will transfer data; including personal data, on a reasonable scale, and as necessary for the Transfer of the Businesses, and provided that the recipient agrees to respect your personal data in a manner consistent with applicable data protection laws. We will continue to ensure the confidentiality of any personal data and will inform the affected subjects before the personal data becomes the subject of a different privacy policy.
Processing of children’s personal data
The Company will not collect or process personal data of children under the age of 16 unless parental consent has been granted, in accordance with applicable local law. If we realise that a child’s personal data was accidentally collected, we will delete that data without any delay.
Processing 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, where appropriate, to support, pursue 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.
Your legal rights
As a data subject you have specific legal rights relating to the personal data, we collect from you. The Company will respect your rights and will fully respond to any concerns you have as you address it.
The following list contains information about your legal rights arising from applicable data protection laws:
• Right to withdraw consent: Where the processing of personal data is based on your consent, you may withdraw such consent at any time.
• Right to correction: You can ask us to correct your personal data. We make reasonable efforts to retain your personal data that we control or have in our possession and are used on an ongoing basis, accurate, complete, and up to date, based on the latest information available to us. You can also check and correct your personal data by entering your personal account on https://ctcautomotive.cy/iveco/
• Right to limitation: You may request from us to limit the processing of your personal data, if
o You question the accuracy of your personal data for the period when we will need to verify the accuracy,
o Processing is illegal and you request that we restrict the processing of your data instead of deleting your personal data
o We no longer need your personal data, but you need it to support, exercise or defend legal claims, or
o You have an objection to the processing of your data for the period when we verify whether our legitimate interests take precedence over yours.
• Right to access: You may ask us for information about personal data that we store for you, including information about the categories of personal data we own or control, for what purpose they are used, from what source they were collected, if not by you directly, and to whom they have been shared, in each case. You can obtain from us free of charge a copy of the personal data we keep for you. We reserve the right to charge a reasonable fee for any further copy you may request.
• Right to transfer: At your request, we will transfer your data to another controller, where technically feasible, provided that the processing is based on your consent or is necessary for the procedure of a contract. Instead of receiving a copy of your personal data, you may ask us to transfer the data to another controller, that you will indicate to us, directly.
• Right to erasure: You may ask us to delete your personal data, where – personal data is no longer necessary in relation to the purposes for which they were collected or processed – you have the right to object to further processing of your personal data and you exercise this right – the processing is based on your consent, you withdraw your consent and there is no other legal basis for processing – your personal data have been processed illegally, except where the processing is necessary – to comply with a legal obligation, which requires processing by us – especially for a legal duty-fulfilling obligation – to support, pursue or defend legal claims
• Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interest or on a legitimate interest of third parties. In this case we will no longer process your personal data unless we can demonstrate compelling legitimate reasons and an overriding interest in processing or supporting, exercising or defending legal claims. If you object to the processing, please specify whether you wish to delete your personal data or restrict our processing.
• Right to lodge a complaint: In the event of an alleged breach of the applicable privacy law, you may lodge a complaint with the data protection supervisory authority in the country where you live or where the alleged infringement occurred.
Please note:
• Time period: We will try to satisfy your request within 30 days. However, the time limit may be extended for specific reasons relating to that legal right or the complexity of your request.
• Restricting access: In some cases we may not be able to provide access to all or some of your personal data under legal provisions. If we refuse your request for access, we will inform you of the reason for this refusal.
• Non-recognition: In some cases, we may not be able to search for your personal data because of the identifiers you provide in your application. Two examples of personal data that we cannot look for when you provide your name and email address are: – data collected through browser cookies, – data collected from social networks if you have posted a comment under an alias not known to us.
In such cases, where we cannot identify you as a data subject, we are unable to comply with your request to enforce your legal rights as described in this article, unless you provide us with additional information that allows you to be identified
Retention of your personal data
In general, we will delete the personal data that we collect from you if they are no longer necessary to achieve the purposes for which they were originally collected. However, we may be asked to store your personal data for a longer period of time due to legislation.
In addition, we will not delete all of your personal data, if you have asked us not to contact you in the future. For this purpose, the Company maintains records containing information about people who do not wish to be contacted in the future (e.g. through group e-mail messages). We categorize your requests as consent for the storage of your personal data for the purposes of maintaining that file, unless you give us different instructions.
Contact Info
Please address any questions on the issue of data protection and any requests to exercise your legal rights to the data controller at dpo@ctcgroup.com.cy
You can also contact the Office of the Commissioner for Personal Data Protection in Cyprus at commissioner@dataprotection.gov.cy
Amendments to This Privacy Policy
The Company reserves the right to amend this Privacy Policy at any time without prior notice to users. Any changes will be published on the website. We recommend that you read this policy occasionally in order to be informed of any changes to the content of this privacy policy.
Acceptance
By using the website, you acknowledge that you have read and understood this Privacy Policy.
