This Policy explains when and why, we collect personal information about visitors to our websites, namely, http://www.epiphaniou.com, http://epiphaniouenergy.com about natural persons in general, i.e., offline, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
Even though we are not expressly required by the law, specifically the EU General Data Protection Regulation (GDPR), our company has appointed a Data Protection Officer (DPO), specifically, Mr. Michalis Kythreotis.
Mr Michalis Kythreotis
Address: 21 Markou Drakou Street, Pallouriotissa, P.O.Box 29078, 1621 Nicosia, Cyprus.
Last updated: 25th of May 2018.
Who are we?
Phanos N. Epiphaniou Public Ltd group of companies.
Registered office: 21 Markou Drakou Street, 1040 Nicosia.
Mailing address: P.O.Box 29078, 1621 Nicosia
Tel: +(357) 22793333
Fax: +(357) 22431534
Nature of business: Trade of products and provision of services for the construction industry, including sanitary ware, air-conditioning systems, photovoltaic systems, and building; construction materials.
How do we collect information from you?
We obtain information about you when you use our website, for example, when you contact us about products and services, if you register to receive information from us, if you submit a complaint or if you submit your CV as a candidate for purposes of employment.
We also collect information about you offline or through other means of communication such as email or telephone, through our hard-copy forms, specifically, when you visit our shops or contact us requesting information about our products or services, when you request a written tender, when you place an order, when you receive delivery of products purchased, when you pay us for your purchases, when you refer a customer of yours to us (in case, you are a professional acting in the construction industry) or when you submit requests, queries or complaints to us.
We may also collect information about you, not directly from you, but from third parties such as a developer, contractor or architect, who refer you to us with your knowledge and/or consent.
The companies in our group may pass information to one another for the purpose of contacting you for related products or services, if you have previously consented to such processing.
What type of information is collected from you?
The personal information we collect may include your name, identity card number, telephone number, address, email address, IP address, and information regarding pages accessed and when. We also collect any other information you provide to us by filling in and submitting web forms on our websites such as a query, request or complaint.
We also collect all personal data you provide us with, through filling any of our written forms, such as the New Client Form, mainly consisting of your full name, identity card number, contact details and details of your property relating to our products, such as the address, the name of the architect, interior designer or civil engineer or through placing and/or paying for orders in which case, we additionally collect information about the products you ordered and payments made. We also collect your entrance and/or exit images in our stores or your image in other areas of our premises, where a relevant ‘video surveillance ‘ notice is in place.
If you are a professional of the construction industry, we may collect your information, such as your name, contact details and projects you have worked or are working on, when you submit it to us through business meetings with our staff, when you contact us for co-operation and from publicly-available sources such as advertising.
We have reviewed all our forms to ensure that we only collect and process information that is strictly necessary for the intended purpose specified or being apparent about you or is required by law, thereby avoiding excessive or unnecessary processing. We also do not collect any sensitive information about you, such as political beliefs or health, or sexual orientation, because we do not need it for conducting our business or servicing you
How is your information used?
We use your information lawfully in accordance with Article 6(a), i.e., for purposes you have consented to, Article 6(b), i.e., as necessary to conclude and perform a contract with you, Article 6(c), i.e., to comply with obligations imposed by law (such as tax legislation) and Article 6(f), i.e., as necessary for legitimate interests we pursue as a business.
More specifically, we may use your information to:
process orders or tender requests;
carry out our obligations arising from the contract entered into between you and us, such as to deliver purchased products and invoice you for products ordered;
send you communications which you have requested such as a reply to a query, a tender you have requested or invoices and receipts, and;
ensure fraud prevention and protect other legitimate interests of our company, such as to keep record of our customer base, get anonymized statistics relating to the needs and behavior of our customers, maintain centralized technical infrastructure, reduce credit risk and receive payment for purchases made, contact you for the purpose of notifying you of any possible delay in the payment of your invoices or for collecting any outstanding amounts or serving needs communicated to us, or to protect and secure our premises and property, only to the extent absolutely necessary for this purpose and without disproportionately interfering with your privacy.
We will not normally contact you for marketing purposes by email or text messages unless you have given your prior consent or in so far as is permitted by the law or if you are a professional acting in the construction industry such as an architect or civil engineer and we believe we have a legitimate interest in getting in touch with professionals or businesses operating in the same industry as us for mutual benefit.
Where and how long do we retain your information?
Your information is stored on physical (hard copy) files and some information not including any sensitive data, on computer servers situated in our premises in Cyprus. By way of exception, personal information in our corporate emails, data storage and calendar is stored by Google in its own servers. Information recorded through our social media Pages are stored on their own respective servers. Additionally, information we collect through our websites may be stored on servers situated in other countries, depending on where the hosting company is based. The servers of those companies are situated in Cyprus, the United Kingdom and the United States of America.
We, as a minimum, retain your information for as long as it is necessary for us to perform a contract we have with you or to comply with legal obligations to which we are subject, in particular, tax legislation. Other than that, we adhere to the maximum retention periods specified by the Data Protection Commissioner, if any.
When there are no specified maximum retention periods, we retain your data for 10 years, starting from the date of the termination or completion of the contractual relationship with you or from the end or settlement of any dispute arising between us. This period covers the period specified by the statute of limitations, after the lapse of which no legal claims can successfully be raised against us and the period specified by tax legislation and/or our accountants and auditors’ advice. Images of the video surveillance system are kept for a period of two weeks
We retain information we collect about you in your capacity as a mere visitor to our websites for one year.
After the lapse of the aforementioned periods of retention, we remove it from our systems by deleting it or we fully anonymize it so that you can no longer be identified by it. In this latter case, we do not delete all of the information but only those pieces of information such as your name, address, email address and any other information revealing that the said information belongs to you.
Should the Cyprus Data Protection Commissioner specify any maximum retention periods, shorter or longer than the above, we will immediately adjust our retention policy accordingly.
Who has access to your information?
We will never sell your information to third parties and we will not share it with third parties for marketing purposes apart from us between companies in our group.
We may pass your information to third party service providers. Such third parties may be messengers or technical service providers providing us with software systems (or their maintenance) necessary to conduct administrative tasks inherent in the provision of our services to you or in the conducting of our business. We only disclose to them the personal information that is absolutely necessary to deliver the service or perform the said task and, when legally required, we have a contract in place that requires them to keep your information secure and in accordance with the principles and rules of the General Data Protection Regulation and not to use it for their own direct marketing purposes or for any purposes other than to provide the service or complete the task as explained above. We also share your information with the companies that are members of our group of companies, as part of our centralised accounting and customer management technical infrastructure. If you have been referred to us by your building contractor, we may forward your order to the said contractor to the extent necessary for the purposes of work coordination, pricing or payment.
We also pass your information as may be contained in our emails, data storage or calendar to Google, which provides us with a relevant technical service of data processing for the said purposes. We have a contract in place that requires Google to keep your information secure and in accordance with the principles and rules of the General Data Protection Regulation and not to use it for their own direct marketing purposes or for any purposes other than to provide the relevant service.
Your information submitted or recorded by our social media Pages is also passed to those social media service providers enabling us to make available and administer such Pages. The said providers are data controllers in their own right and bound by all of the obligations of the GDPR with their own privacy policies displayed on their websites
We may also pass your information to our lawyers and accountants/auditors to the extent necessary to defend or institute legal claims and to comply with legal obligations with regards to financial accounts and tax reasons respectively.
We may also transfer personal information to our banks, namely Bank of Cyprus Ltd, Eurobank Cyprus, CDB Bank, Hellenic Bank, COOP, in particular when you pay us through a check. Banks are controllers of personal data themselves and are bound by all of the obligations of the General Data Protection Regulation. You can see their own privacy policies on their websites.
We may transfer your personal information to a third party as part of a sale of some or all of our business assets to any third party or as part of any business restructuring or reorganization in which case we will take measures to ensure that all data protection principles and related rights as derived by the General Data Protection Regulation are fully complied with, prior, during and after the relevant transfer.
Finally, we may disclose your information to public and/or regulatory authorities, if disclosure is required by law or an order issued by a court of law.
What are your rights?
You may at any time send us any of the following requests and we will meet them at the earliest possible and in any case, within a month from the date of receipt of your request and inform you about the action we have taken. If your request is for any reason complex to examine or meet, we will ask you for an extension before the aforementioned one-month period expires.
If we have legitimate reasons to refuse to satisfy your request, we will inform you accordingly and in this case, you have the right to submit a relevant complaint to the Cyprus data protection authority, namely, the Data Protection Commissioner, http://www.dataprotection.gov.cy/ if you believe that our decision is unjustified.
These are the requests you may submit to us:
A request to permanently delete all or some of your information from our records (right to be forgotten or to erasure), for example when we no longer have reasons to retain it.
A request for you to access your information that we keep in our records right of access.
A request that we provide you with a copy of information about you that exists in our records, in digital or hard copy form. If you require more than one copy, we may charge you a maximum of EUR10,00 as administrative costs. (right to a copy)
A request to update or correct information about you that we keep in our records (right to rectification), for example, in case it is outdated or contains errors or inaccuracies.
A request that we provide you with the information about you that we keep in our records in a structured, commonly used and machine-readable format or forward it in such form to another provider of your choice, if such forwarding or transfer is technically possible (right to portability). Please note that this right applies only in relation to data that you yourself have provided us with and which we process by electronic means in the context of a contract between you and our company or because you have consented to us doing so. Not all information you provide to us is processed by electronic means.
A request that we stop processing information about you, without however deleting it from our records (right to restriction of processing). In this case, we will restrict access to and use of your information.
If you wish to exercise any of the above rights you will be able to do so by contacting our DPO, Mr Michalis Kythreotis preferably by email and specify the type of right you seek to exercise.
Please note that before acting upon any of your above requests, we may require you to prove your identity, if we are in doubt about your true or correct identity. If we cannot identify you, i.e., we do not hold personal data belonging to the person you are saying you are, we will inform you accordingly and we will not act upon your request.
What security measures do we apply to protect your information?
When you give us personal information, we take organizational and technical measures to ensure to keep it secure and protected against unauthorized disclosure or access, alteration, accidental loss or other violation or unlawful processing. Such measures, amongst others, aim at restricting access to personal information, ensuring secure storage, limiting the risk of viruses and other harmful events, securing and keeping secure back-ups and effectively destroying unnecessary or outdated data.
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Transferring your information outside the European Union
We do not transfer your information outside the European Union except to the extent that as explained above, we use third party cloud services such as Google email and hosting services for our websites.
In case we will have to do so, we will inform you accordingly. The data protection laws of the such countries are not the same with those applying in the EU, however, when this is a country in relation to which there is not a European Commission decision on the sufficiency of its legal data protection regime as per Article 45 of the Regulation, we will ensure that your personal data will be given corresponding and/or appropriate respect and protection, specifically by signing with parties based outside the EU, relevant data sharing and/or processing agreements using standard contractual clauses approved by the European Commission, in accordance with Article 46 of the Regulation.