Data Policy

1. TLF commits to protect your personal information

 

TLF is committed to protect your personal information and your privacy. We encourage you to carefully read this Data Protection Policy.
This Data Protection Policy informs you of our data protection and privacy practices and the way your personal information is collected online and how that information is used by us. This Policy will be readily available on our home page and at the bottom of every TLF Web page. TLF strongly supports the fundamental rights to privacy and Data Protection as well as compliance with national and international privacy laws. TLF commits to maintain confidential any personal information and to strictly limit any disclosure in accordance with local laws and regulations.
TLF has established this Data Protection Policy to implement the new GDPR in force on 1 December 2022, which is applicable to all TLF entities processing personal data of EU Residents. This data Protection Policy is applicable in all of our affiliates for the collection, processing, use, dissemination, transfer, and storage of personal information. It imposes common rules for all of our entities of all countries and aim at ensuring a high level of protection of personal information within TLF and its partners.

 

2. To whom this Data Protection Policy applies?

 

TLF is a global company, with legal entities, business processes, management structures, and technical systems that cross borders.

This Data Protection Policy applies to all TLF -owned websites, domains, services, applications, and products, and those of our wholly owned subsidiaries (“TLF sites or services”), except that a privacy policy or statement specific to a particular TLF program, product, or service may supersede or supplement this Data Protection Policy. This Policy bounds all TLF Entities and employees.

 

3. How do we process your personal information?

 

TLF respects the rights of each individual, employee, candidate or customer to have his privacy and personal data protected. TLF Entities will observe the following principles when processing your personal information:

  1. Processing your personal information fairly, lawfully and in a transparent manner;
  2. Collecting your personal information for specified, legitimate purposes and not processing further in ways incompatible with those purposes;
  3. Collecting your personal information which is relevant to and not excessive for the purposes for which it is collected and used.  We may render information anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
  4. Maintaining your personal information accurate, and where necessary, kept up to date. We will take reasonable steps to rectify or delete data that is inaccurate or incomplete;
  5. Keeping your personal information only as long as it is necessary for the purposes for which it was collected and processed;
  6. Processing your personal information in accordance with the individual’s legal rights;
  7. Taking appropriate technical, physical and organizational measures to keep your data safe and prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal information;
  8. Processing your personal information based on the following legal basis:
    • You have unambiguously given your consent; or
      The processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; or
    • The processing is necessary for compliance with a legal obligation to which TLF is subject; or
    • The processing is necessary in order to protect your vital interests or the vital interest of another natural personal;
    • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in TLF; or
    • The processing is necessary for the purposes of the legitimate interests pursued by TLF or by a third party except where such interests are overridden by your interests or your fundamental rights and freedoms.

All TLF entities ensure that these principles are observed.

 

4. Why do we collect your personal information?

 

Our primary goals in collecting information are to provide our clients and other users with best-in-class services and a smooth, efficient and personalized experience while using our websites. For example, if you purchase products or request information on the websites, we use your personal information to fill your order or to provide the requested information. TLF may collect personal Information from you to complete various transactions, such as:

  • product or service orders, activations and registrations;
  • profile creation;
  • information requests;
  • marketing or support subscriptions;
  • contest entries or survey participation;
  •  job applications.

 

5. What information is collected?


TLF collects and uses your personal information to better serve you and personalize your experience and interaction with TLF. Such collection is done with appropriate notice and consent, along with the maintain of record of our processing activities under the responsibility of each of our entities. Personal information (or ‘Personal data’) means any information relating to an identified or identifiable natural person (‘Data subject’). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.

This Policy does not cover personal information rendered anonymous. Personal data is rendered anonymous if individual persons are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or work. If Personal data rendered anonymous become no longer anonymous (i.e., individual persons are again identifiable), or if pseudonyms are used and allow identification of individual persons, then this Policy will again apply. It is always up to you whether to disclose personal information to us, although if you elect not to do so, we reserve the right not to register you as a user or not to provide you with any products or services.

The types of personal information we collect from you may include:

  • your name, surname, age, company, image, birth date, email address, phone number, billing address and shipping address;
  • customer type, job function, job title, purchasing authority, purchasing timeframe and others;
  • product and service preferences, contact preferences, educational and employment background, and job interest data;
  • your TLF user ID and password (where applicable);
  • Credit card information (where applicable);
  • IP address.

 

6. How do we use your Information?

 

We gather and use information in a number of ways, including the following:

Browsing and Searching: We collect certain personal information when you visit the websites or click on the various links for products and services. We collect this information to improve your web user experience for your next visits (ex: country selection, language), to help run the sites more efficiently, to gather broad demographic information, to monitor the level of activity on the websites, and to evaluate the effectiveness of our advertising. See also our Cookies Policy for our use of cookies.

Ordering: We collect personal information when you purchase products and services. We collect this information to deliver your order, to obtain payment, and to communicate with you about the status of your order.

Technical support: We may collect certain information when you request technical support for TLF services. This information is necessary to identify your systems, understand the configuration of the equipment, diagnose your questions, and provide solutions.

Online surveys and polling: We collect personal information from Clients who volunteer to complete surveys or participate in polls. We use this information to improve our offers and services.

Promotional activities: We collect personal information from you when you enter a promotional program or activity. We use this information to administer the program or activity, to send you promotional e-mails, notify winners, and make the winners’ list publicly available pursuant to applicable regulations and laws.

Newsletters and promotional e-mails: We collect personal information when you ask to receive newsletters, promotional e-mails, and other information. We use this information to provide you the information you request.

Contact information: If you contact us, we keep a record of your correspondence or comments, including personal information, in a file specific to you. We use this information to help us provide you better service in the event you contact us again. We may keep your information for a reasonable and limited period for the achievement of the purposes set out above.

 

7. How do we use your information for marketing?

 

We (including our group companies) and carefully selected third parties may use the information we collect to inform you, by letter, fax, phone, SMS and email about promotions, news and new products that we think may be of interest to you.

When providing us with your personal information you will be given the choice to be contacted by these methods for these purposes.

You have the right to object at any time to this kind of processing for such marketing.

 

8. What we do with your Personal data?

 

If you do provide personal information to us, either directly or through a reseller or other business partner, we will:

  • not sell or rent it to a third party without your permission — although unless you opt–in, we may use your contact information to provide you with information we believe you need to know or may find useful, such as (for example) news about our services and modifications to the Terms of Service;
  • take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;
  • not use or disclose the information except:
    1. As necessary to provide services or products you have ordered, such as (for example) by providing it to a carrier to deliver products you have ordered;
    2. In other ways described in this Data Protection policy or to which you have otherwise consented;
    3. In the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
    4. As required by law, for example, in response to a subpoena or search warrant;
    5. To outside auditors who have agreed to keep the information confidential;
    6. As necessary to enforce the Terms of Service;
    7. As necessary to protect the rights, safety, or property of TLF, its users, or others; this may include (for example) exchanging information with other organizations or public authorities for identification, fraud protection and/or risk reduction.

 

9. Your consent

 

By providing us with your personal information and/or using the websites and/or entering into a contract with us, you consent to our processing your Personal data for the above purposes. You also consent to our transferring your information to countries or jurisdictions which do not provide the same level of data protection as the EU, if necessary for the above purposes. If we do make such a transfer, we will provide appropriate safeguards to ensure that your information is duly protected. If you provide us with information about another person, you confirm that they have appointed you to act for them, to consent to the processing of their Personal data including sensitive personal data and that you have informed them of our identity and the purposes (as set out above) for which their Personal data will be processed. We do not process Personal data of minors under 16 without the express consent of their parents or legal representatives.

 

10. Links to third-party websites

 

TLF websites or services may provide links to third-party applications, products, services, or websites for your convenience and information. If you access those links, you will leave the TLF website. TLF does not control those third-party websites or their privacy practices, which may differ from TLF practices. We do not endorse or make any representations about third-party websites. The personal information you choose to provide to or that is collected by these third parties is not covered by the TLF Data Protection Policy. We encourage you to review the privacy policy of any website you interact with before allowing the collection and use of your personal information. We may also provide social media links that enable you to share information with your social networks and to interact with TLF on various social media sites. Your use of these links may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites. If you post, comment, indicate interest, or share personal information, including photographs, to any public forum, social network, blog, or other such forum, please be aware that any personal information you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor TLF have control over TLF is not responsible for the personal information you choose to submit in these forums.

 

11. Your Data protection rights

Right of access

As data subjects, you may inquire as to the nature of the personal data stored or processed about you by any TLF entity. You will be provided access to your Personal data regardless of the location of the data processing and storage. A TLF entity processing such data will cooperate in providing such access to you either directly or through a local entity.

 

Right to rectification

If your Personal data is inaccurate or incomplete, you may request that the data be amended.

 

Right to object

You have the right to object at any time to the processing of your Personal data for the purposes of TLF legitimate interests or for direct marketing purposes.

 

Right to erasure

You can ask for the deletion of your Personal data when it is allowed by applicable data protection laws and regulations.

 

Right to restriction of processing

You have the right to require a restriction of the processing of your Personal data when it is authorized by applicable data protection laws and regulations.

 

Right to data portability

If you meet the conditions settled by the applicable data protection laws and regulation, you have the right to receive a subset of your Personal data and to transmit them from TLF to another data Controller.

You can also require the direct transmission from TLF to another Controller when it is technically feasible.

 

Right to lodge a complaint

You have the right to lodge complaint with the competent supervisory authority.

All requests for access, rectification, limitation, erasure, restriction or portability of your Personal data, and any questions regarding this Data Protection Policy, may be sent to TLF Data Protection Officer:

 

TLF
Glasdtonos & 1 Evangeslistrias Street

1st floor-Agathangelou Business Center

3032-Limassol

Cyprus


or by email at [email protected].

 

12. Change in this Data Protection Policy

 

TLF reserves the right to modify this privacy statement as needed, for example, to comply with changes in laws, regulations, TLF practices and procedures, or requirements imposed by data protection authorities. In this case, TLF will inform TLF candidates, customers, clients and other persons of any material changes in this Policy. TLF will post all changes on relevant internal and external websites.

 

Last update: 14 december 2022