This Privacy Notice will inform you as to how "Intergo Telecom Ltd" (hereinafter referred to as the "Company", "we", "us" and "our") collects and processes information about you and in particular, your personal data. We hereby assure you that this Privacy and Personal Data Protection Policy ("Privacy Policy") fully respects and complies with the EU Regulation 679/2016 ("Regulation") and the relevant Law 125 / I / 2018 of the Republic of Cyprus.
Personal Data means any information relating to an identified or identifiable natural person (' data subject '); an identifiable natural person is one who can be identified, directly or indirectly, indicatively by reference to an identifier such as a name, an identification number, address, contact details, an online identifier, etc., or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Regarding the personal data, and in cases, we determine the purposes and means of the processing, the Controller is the legal person: INTERGO TELECOM LIMITED, Savvas Plaza, Nikolaou I. Nikolaidi Ave 3-Office 206, Paphos 8010, Tel: +357 26 913001, inquiries@intergotelecom.com
At INTERGO TELECOM LIMITED, we are committed to, and adhering to, the following principles of processing personal data in accordance with Article 5 of the Regulation. The personal data is:
Finally, we are able to demonstrate compliance with the aforementioned principles (principle of 'accountability').
We, as the Controller, collect Personal Data from you in the following cases:
In addition, it is noted that we process personal data, which third parties, usually legal entities, disclose to us when we act as Processors on their behalf. In such case these third parties hold the responsibility to properly inform you.
We do not collect and/or process minors personal data without verifiable parental consent, in cases when we are able to control it. For example, it is not possible to control information that is communicated to us without physical presence.
The categories of data subjects include:
Individuals or legal entities' executives, interested in our services and contacting us;
Natural persons receiving our services or are related to the delivery of our services, or natural persons and employees of our suppliers and other legal entities cooperating with us;
Candidates for employment;
Visitors of our premises or our webpage and our social media accounts;
Our employees.
Regarding the Categories of data subjects and the personal data we process when we have the role of the Processor, the Controller holds the responsibility to appropriately inform you.
Data from the following categories of personal information about you, may be collected and processed per case and not as a whole , when we are the Controller, in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:
It is noted that we collect some more kind of personal data about our employees; they are informed through documents, manuals, policies and procedures and information internally provided.
The processing of personal data from us as the Controller, is based on one of the "legal bases" as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data).
The legal bases on which the collection and processing by us of personal data is based (in most of the cases) are:
The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: when you communicate with us in any way directly or indirectly as interested in our services, when you are interested in working with us, when you fill in our documents, when you make a complaint, when you visit our social media accounts, when you give us your business card or when you agree to receive information from us.
Performance of a contract: when you have agreed to receive our services, when you are our employee or collaborator, during the payment of our liabilities or when we are contacting you in the framework of a contract.
Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.
Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, or for the assessment of persons and situations. In this specific legal basis is also based the CCTV operation in our premises that we operate for the protection of people and the property.
Our employees are informed internally about the processing purposes and the legal bases under specific documents.
We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose.
Data collected on the basis of contractual and legal obligations shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework.
Personal Data included in offers that does not lead to a cooperation agreement is kept for 2 years.
Cookies are stored depending on their nature as you may be informed in our cookies policy.
Personal data you disclose to us as candidates are stored for 6 months or until you revoke your consent regarding processing of these data.
The CCTV recording is maintained for 15 days and then it is anonymised by overwrite.
Data that may be needed for our legitimate interests as a Controller shall be kept until the reason for storing such data ceases.
Specifically, the data we process based on your consent, is kept from obtaining the consent until it is revoked or there is no longer need to store it.
Information that is no longer necessary is securely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for the specific purpose.
We have received reasonable organisational and technical measures to protect the personal data we collect, and in particular any specific categories of personal data. We follow international standards like the ISO 27001:2022 Standard and practices to ensure the security of our operations. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:
Access to personal data is restricted to a limited number of authorised employees under a need-to-know basis, and the necessary data transfer is done by secure procedures.
Our employees are bound to confidentiality rules and agreements, with limited classified access to the necessary data only.
We select trusted collaborators who are committed in writing, in accordance with Article 28 of the Regulation, to the same obligations regarding the protection of personal data. We reserve the right to audit them in accordance with Article 28 (3) (h).
In our ICT systems used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access or other illegal processing. In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.
Some of the security measures we take are not announced for obvious reasons.
We take measures to ensure that the recipients of personal data we process as the Controller are kept to a minimum. The personal data we collect is disclosed to third parties, provided that the legality of such disclosure is fully justified. Such processing by third parties is usually view only, and only under specific circumstances may include the retention of such data by the 3rd party – recipient, especially in relation to authorities, or during legal cases, or payments, or incidents' investigation. Specific personal data from those we lawfully collect as a Controller, may be accessed (or disclosed) on a case-by-case basis by:
Any relating supervisory authority within its role;
Any public or judicial authority where required by law or judicial decision.
The auditor of the company, for necessary data required to fulfil the audit (financial, employment, contracts and other controls), under confidentiality.
The legal advocate, for whatever data is required in legal cases, under confidentiality.
The Insurance cooperating company and only for the relevant part of the information.
Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
The training or systems consultants, for training or systems control issues and only for the necessary pieces of information and data under confidentiality agreements.
The Certification Body during their audits.
The personal data we collect is processed within the European Economic Area (EEA) and/or an adequacy decision area according Article 45.
You have the right to be informed, the right of consent when this is the legal basis of data collection and processing, the right of access to your personal data, the rights of rectification and erasure (in cases it is permitted), the right to restriction of processing, the right to data portability, the right to object. If processing is based on your consent, you may withdraw it at any time.
The right to be informed is exercised through this privacy and personal data protection notification. In some cases, it is also mentioned in documents – forms we are using.
We inform you that we are not using software of decision making solely based on automated processing including profiling.
The right of consent is provided by design as we have reviewed all processing activities and ask your consent when the case.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data is being processed as well as other relevant information, and, where that is the case, access to your personal data.
Right of rectification: you have the right of rectification of your inaccurate personal data as well as to have incomplete personal data completed by providing a supplementary statement.
Note: Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process.
Right to erasure (‘right to be forgotten’); we have to answer such right when:
We reserve the right to refuse this right if the processing is necessary for compliance with any legal obligation, we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according to Article 17 § 3).
Right to restriction of processing; you have the right to restriction of processing when:
Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and under an explicit request such data to be transferred to both you and another natural or legal person who will process it when:
Right to object: you have the right to object to the processing of your data at any time when the reason for the processing relates to direct marketing.
In the event that you make such request in a written or electronic form regarding any of the above rights, we will assess your request and respond within one month of its receipt, either for its satisfaction or to provide you with objective reasons preventing it from being satisfied, or, given the complexity of the request and the number of requests at the given time, request an extension of response for a further up to two months period (according to Article 12.3 of the Regulation).
The exercise of your rights is free of charge. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to answer or charge you an administrative fee.
If you are dissatisfied with the use of your data by us, or our response after exercising your rights, you have the right to lodge a complaint with a supervisory authority.
In the event of a breach of the security and integrity of the personal data processed, we will take the following measures (in accordance with Article 33 and 34 of the Regulation in case we are the Controller) and we will:
In the event we are the processor, we will inform the Controller as soon as possible.
Our website may contain links to other websites that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third-party site. We recommend that you review the Privacy Policy for each site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Cyprus Personal Data Protection Authority, e-mail: commissioner@dataprotection.gov.cy.
Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679 .
If at any time you want to contact us or make a request regarding your rights or any other matter relating to the protection of personal data, you may contact us: INTERGO TELECOM LIMITED, Savvas Plaza, Nikolaou I. Nikolaidi Ave 3-Office 206, Paphos 8010, Tel: +357 26 913001, inquiries@intergotelecom.com .
Communication languages are English and Greek only.
This policy was updated since 30th of November 2023, and may be reviewed when there is a significant change. This review will be available on our website, with a note of the effective date.