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Privacy Policy



1. Introduction


1.1 We are committed to safeguarding the privacy of [our website visitors and service users].

1.2 This policy applies where we are acting as a data controller with respect to the personal data of [our website visitors and service users]; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to Greycom LTD.[ For more information about us, see Section 13.]


2. Credit


2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).


3. How we use your personal data


3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is your consent.

3.3 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.


4. Providing your personal data to others


4.1 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.[ We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.


5. International transfers of your personal data


5.1 The hosting facilities for our website are situated in Germany. 


6. Retaining and deleting personal data


6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

Name, Phone Number, Email Address and Enquiry or a maximum period of 1 month following our receipt of your enquiry.


7. Amendments


7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.


8. Your rights


8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: 

(a) the payment of a fee (currently fixed at €20); and

(b) the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)].

8.2 We may withhold personal information that you request to the extent permitted by law.

8.3 You may instruct us at any time not to process your personal information for marketing purposes.

8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.


9. About cookies


9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.


10. Cookies that we use


10.1 We use cookies for the following purposes:

  1. Default - we use cookies to manage the session and visitor ID of the user [Default];
  2. Display - we use cookies to manage the options of the user in latest product modules and inside product options chosen.[Display];
  3. User session state – we use cookies to preserve user session state across page requests. [PHPSESSID]


11: Cookies used by our service providers


11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.[ The relevant cookies are: [identify cookies].]


12. Managing cookies


12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).


12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.


13. Our details


13.1 This website is owned and operated by Greycom LTD.

13.2 We are registered in Cyprus under registration number E48249, and our registered office is at 36A Grivas Dighenis Avenue 1066 Nicosia Cyprus

13.3 Our principal place of business is at 36A Grivas Dighenis Avenue 1066 Nicosia Cyprus.

13.4 You can contact us:

(a) [by post, to Greycom LTD. 36A Grivas Dighenis Avenue, Nicosia, 1066, Cyprus

(b) using our website contact form;

(c) [by telephone, on +357 22668535 or

(d) [by email, using [the email address published on our website from time to time]].