At Studio8 Ltd (hereinafter “we”, “us” or “our” or the “Company”) we are committed to protect our clients’ privacy and handling their personal data in an open and transparent manner.
2. Who we are.
- Identity and contact details of the Data Controller.
(a) Data Controller.
Studio8 Ltd, a Cyprus private limited liability company, having a registration number ΗΕ 339888, is the «Data Controller» pursuant to the GDPR, and related Cyprus Law, and determines how your personal data is kept and processed.
The main establishment and the central administration of the Data Controller is situated at 22, Panou Solomonide Street,3032, Limassol, Cyprus.
(b) Data Protection Officer (DPO).
The DPO may be contacted directly with regards to all matters concerning this policy and the processing of your personal data including the enforcement of all applicable and available rights.
Official requests may be made by post at 22, Panou Solomonide Street,3032, Limassol, Cyprus, or electronically at firstname.lastname@example.org.
5. How do we collect personal data?
We collect and process personal data including special categories of personal data that have been provided directly by you or from your parent or legal guardian through our enrollment procedure in order for you to attend in different courses, classes and other activities that we provide or organise. During the enrollment procedure we also collect personal data of your client’s parents and legal guardians. We also collect personal data of our clients during events and other activities that we organise.
We also collect and process certain browsing data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using .We collect first party Cookies that is set by the domain, such as the computer you are using to access the internet, or the specific website that you have visited. We use the two main types of cookies, persistent and session cookies. A persistent cookie remains on your device after you have visited our website. These cookies will help us identify you as a unique anonymous visitor to our website by storing a randomly generated number.
- Categories of personal data that we collect.
We collect and use several types of information about you, including information by which you may be personally identified and that is defined as personal data under applicable law such as your first and last name, gender, age, address, telephone number, email address, parent’s or legal guardian’s first and last name, ID number, telephone number, work address, working hours, work telephone number and email and emergency contact details. During events, activities and classes that we organise we also collect images and or video of our clients provided that we have obtained consent. We collect and process personal data of children which under GDPR are defined as persons under 16 years of age after we obtain consent from the parent or the legal guardian.
Should there be a need to further process the personal data for a purpose other than that for which they were initially collected, you will be informed about the additional purpose and the relevant details in respect to the further processing.
With your explicit consent or the explicit consent your parent or legal guardian we may collect special categories of personal data. Pursuant to the definition given by the GDPR, these data may include racial or ethnic origin, political opinions, religious or philosophical beliefs, health data, trade union membership, the processing of genetic data, biometric data, data concerning health, sex life or sexual orientation and criminal records.
8. What lawful reasons do we have for collecting, processing and disclosing personal data.
In accordance with GDPR we may rely on the following lawful reasons when we collect and process personal data to operate our business and provide our services:
- Legitimate interests- We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. A legitimate interest is when we have a business or commercial reason to use our clients’ information. Instances of such processing activities can include, initiating legal claims, preparing our defense in litigation procedures, initiating complaints to our regulator etc.
9.Why do we need Personal Data.
Studio8 Ltd will use personal data for the purposes of running all of the Company’s activities including the courses, classes and other events that it provides and organise. It is also used for the purpose of verifying client’s and parent’s or legal guardian’s identity, responding to enquiries, sending information to clients’ parents and/or guardians.
10. Do we share personal data with third parties?
In the course of our business relationship our clients’ personal data may be provided to various departments within our Company.
In addition, the following third parties may also be the recipients of the personal data under the certain circumstances:
- Supervisory and other regulatory and public authorities, whereby a statutory obligation exists that we are subject to.
- Financial institutions in the context of receiving payments from our clients.
- External auditors in the normal course of the audit of the Company’s financial statements.
- Associates for the organisation of various events.
Third parties to whom we may disclose Personal Data may have their own privacy policies which describe how they use and protect Personal Data. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.
- Do we transfer your personal data outside the European Economic Area?
We store personal data on servers located in the European Economic Area (EEA). We may transfer personal data to reputable third party organisations situated inside or outside the EEA when we have a business reason to engage these organisations. Each organisation is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.
You have the right to ask us for more information about the safeguards that we have put in place. Contact us as set out in Section 4 (b) if you would like further information or to request a copy where the safeguards are documented (which may be redacted to ensure confidentiality).
12. Personal data security.
We have put in place appropriate technical and organisational measures including physical, electronic and procedural measures to protect personal data from loss, misuse, alteration or destruction. We restrict access to information at our offices so that only officers and/or employees who need to know the information have access to it. Those individuals who have access to the data are required to maintain the confidentiality of such information. In addition, we have trained our employees on how to handle, manage and process personal data, applied upgraded technical measures and transformed our policies and procedures in a way that will comply with the GDPR.
Please be aware that the transmission of data via the Internet is not completely secure. Users should also take care with how they handle and disclose their personal data and should avoid sending personal data through insecure email.
13. How long do we retain personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We maintain a data retention policy which we apply to records in our care. When your personal data is no longer required and we do not have a legal requirement to retain it, they will be securely destroyed.
15. What are your data protection rights?
Subject to the provisions of the GDPR, you have certain rights regarding the Personal Data we collect, process or disclose and that is related to you, including the right:
- To receive access to your personal data (right to access).
- To rectify inaccurate personal data concerning you (right to data rectification);
- to request deletion/ erasure of your personal data (right to erasure/deletion, “right to be forgotten”);
- to receive the Personal Data provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Data to another data controller (right to data portability);
- to object to the use of your personal data where such use is based on our legitimate interests or on public interests (right to object);
- in some cases to request the restriction of processing of your personal data (right to restriction of processing);
- To withdraw the consent given to us with regard to the processing of your personal data at any time. Note that any withdrawal of consent will not affect the lawfulness of processing based on consent before it was withdrawn.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
16. How to raise a complaint.
To exercise any of the above rights, or for any questions or complaints about our use of your personal data, please contact our Data Protection Officer, either by post at 22, Panou Solomonide street, 3032, Limassol, Cyprus or electronically at email@example.com.
Complaints may also be lodged to the supervisory authority in Cyprus (Office of the Commissioner for Personal Data Protection, by post at 1 Iasonos Str. 1082, Nicosia, Republic of Cyprus. More information can be found at http://www.dataprotection.gov.cy.