Privacy policy
SALUTRO LTD. Terms of ConDITION and PRIVACY POLICY.
January 2024
Who we are
a. SALUTRO LTD. is an international company with deep and successful experience in business consulting, investments, banking services, accounting and finance services, and marketing services.
b. This Privacy Policy sets out how SALUTRO LTD. and its affiliates collect and use your personal information when you use our website salutro.com ("Site"), including the contact form ("Services"), offered by SALUTRO and the choices available to you as the result of our use of your personal information (the Privacy Policy).
This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions (Terms) and our Cookie Policy (accessible online at http://salutro.com/privacy_policy). In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.
2. This Privacy Policy
a. We know how important is your personal information for you and we appreciate your trust.
By making available the Services we, acting reasonably and in good faith. That is why we also believe that you:
(a) provide true information about yourself to the extent necessary for the use of the Services;
(b) are aware of and accept this Privacy Policy.
b. We do not check the user information received from you, except where such a check is necessary in order we can fulfil our obligations to you.
3. Information we collect about you
a. We collect your personal information to communicate with our clients and partners and to provide and continually improve our products and services. That gives you the possibility to obtain access to all the Services that we provide and gives us the possibility to guarantee that you will receive a response to your e-mails.
Your personal information helps us to improve, develop and implement new features to our Services and enhance the available Services functionality. The personal data we hold about you must be accurate and current. Please keep us informed if your data changes during your relationship with us. To achieve the above-mentioned we will collect, store, aggregate, organize, extract, compare, use, and supplement the data that you choose to provide us with via e-mail (hereinafter “processing”) in compliance with applicable laws. We also receive and pass this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
b. We set out more detailed information that we collect when you use our Services, why we collect and process it and the legal bases below.
Information Collected
|
Information Collected |
Purpose |
Legal Basis |
|
1. Your e-mail address |
We use this information to manage and administer the Services provided to you. We use this information to communicate with you. |
Legitimate interests (to respond to customer enquiries) |
|
2 Data you provide for registering on the Site including your name, surname, date of birth, gender, mobile phone number, shipping and billing address and/or email |
We use this information to manage and administer the Site including providing our services to you. We also use this information to provide you with recommendations we feel you may be interested in, updates and information on our products and services we think you may be interested in. We use this information to generate recommendations and tailor and improve the adverts that are presented on the Site. |
Legitimate interests (to respond to customer enquiries) |
|
3. Additional data received when you access the Site, including information regarding technical devices, technical interaction with the Site (your host IP address, your operating system, type of a browser, geographic position, your installed apps, the Internet provider) and your browsing behaviour and further actions on the Site. |
Additional data received when you access the Site, including information regarding technical devices, technical interaction with the Site (your host IP address, your operating system, type of a browser, geographic position, your installed apps, the Internet provider) and your browsing behaviour and further actions on the Site. (to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the SALUTRO Services). |
Legitimate Interests. |
|
4. Information that is automatically received at the time of access to the Site with the use of cookies. |
Information that is automatically received at the time of access to the Site with the use of cookies. (We automatically collect and store certain types of information about your use of SALUTRO Services, including information about your interaction with content and services available through SALUTRO Services. Like many websites, we use "cookies" and other unique identifiers, and we obtain certain types of information when your web browser or device accesses SALUTRO Services and other content served by or on behalf of SALUTRO on other websites). |
Consent |
|
5. Information that is received as the result of your usage of payment functionality on the Site (e.g. first and last four digits of your card number that are needed for the option of matching these details with the user’s ID number). |
Information that is received as the result of your using payment functionality on the Site (e.g. first and last four digits of your card number that are needed for the option of matching these details with the user’s ID number). (We use your personal information to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, and promotional offers). |
Legitimate interests (to respond to customer enquiries) |
|
6. Information that you submit to us via the contact form when sending us an email (certain information about you including your name, address and other related details you provide) |
We use the information we collect from you for: |
Legitimate Interests (to respond to customer enquiries) |
c. We process your data for the purposes identified above, as necessary, (1) for our legitimate interests, including maintaining and administrating the Services; (2 for us to carry out a specific task in the public interest which is laid down by law.
d. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
In this case, we are unable to delete your personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
e. If we intend to further process your data for any other purpose different from those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4. Data sharing
a. Information about our customers is an important part of our business, and we are not in the business of selling our customers' personal information to others. We may share your personal information with companies, organizations and individuals inside and outside of SALUTRO LTD that either are subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy where one of the following circumstances applies:
• to other companies in our group: for administrative and management purposes as it was listed above. In this case, we are taking reasonable measures to ensure that your information is kept secure at all times;
• to trusted third parties who perform services and process your personal information for us for the purposes listed above, based on our instructions, while we are taking reasonable measures to ensure that your information is kept secure at all times; in particular, we may share your information with any delivery and shipment companies for the additional and exceptional use.
• to companies, organizations or individuals outside of the SALUTRO if we are strongly sure that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental request; detect, prevent or otherwise address fraud, security or technical issues; or protect against harm to the rights, property or safety of the SALUTRO, our customers or the public, as required or permitted by law. We require all third parties to respect the security of your data and to treat it by the law. We do not allow our third-party service providers to use your data for their purposes and only permit them to process your data for specified purposes and by our instructions.
b. SALUTRO or our selected third-party partners with our permission, using their ad servers, can show advertisements to you. SALUTRO Services may include third-party advertising and links to other websites and apps. Third-party advertising partners may collect information about you when you interact with their content, advertising, and services. We never share your name or other information that directly identifies you while advertising. Instead, we use an advertising identifier like a cookie or other device identifier.
Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.
5. International Transfers
a. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) to any third-party countries with our customer’s permission and based on domestic law and procedure.
b. The countries to which we transfer your data may not have the same data protection laws as it is in your jurisdiction. We take reasonable cyber security measures and/or apply the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is protected to a similar degree as within the EEA.
6. Retention Periods
a. We will retain your personal information as long as it may be required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations exist and/or permissible under applicable/relevant law.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal requirements.
b. You may request to remove your data on our Services by contacting the Service support (see Section 10 for details).
7. Your Rights
a. You are granted the following rights, concerning your personal information:
(a) Right to access your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Right to rectify your personal information: you can request whether we update, block or delete your data if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for processing.
(c) Right to restrict the use of your personal information. This enables you to ask us to suspend the processing of your data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) you have objected to our use of your data but we need to verify whether we have to override legitimate grounds to use it.
(d) Right to request for the erasure of your personal information. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(e) Right to object to the processing of your personal information. You can object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your data for direct marketing purposes.
(f) Right to data portability (in certain specific circumstances). This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Right not to be subject to an automated decision.
(h) Right to complain with a supervisory authority.
b. If you would like to exercise these rights, please contact our Support Service at info@salutro.com or send your request to us in writing to Paliokos 9, H109, Kalavasos 7733, Larnaca, Cyprus. We will aim to respond to you within 30 days of the receipt of the request. We will need to verify your identity before we can disclose any personal data to you.
8. Security Measures
a. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination. Our devices offer security features to protect your data against unauthorized access and loss.
9. Changes to this Policy
a. We may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We recommend you review regularly this page to ensure that you are always aware of our information practices and any changes to such. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.
10. Contact Us
a. If you have any questions as to how we collect and use your personal information, please do not hesitate to send your inquiries to Service support at info@salutro.com or send your request to us in writing to Paliokos 9, H109, Kalavasos 7733, Larnaca, Cyprus. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days of the receipt of the request.
b. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
c. The e-mail address of our DPO is info@salutro.com
