INTRODUCTION
The protection of your personal data is important to us!
Please take some time to read this Privacy Policy and find out how our Company, acting as a Data Controller, collects, stores, uses and generally processes your personal data when you create an account to our website, request marketing material to be sent to you, purchase our products, subscribe to our Newsletter, give us feedback or contact us. This Privacy Policy applies only to our Company solely and we take no respobsibility and accept no liability with respect to the processing of your personal data by third parties, who may sell or market or advertise our products, whether via an online or a physical store, or third party websites which you may visit through our website.
This website is not intended for children and we do not knowingly collect data relating to children.
If you have any questions in relation to the processing of your personal data, please contact our support team at the email address provided at the end of the present Privacy Policy.
Please kindly note that by ticking the box next to the statement “I agree to the Terms and Conditions and I have read the Privacy Policy” you grant us with your acceptance to be bound by the provisions of the present Privacy Policy.
WHO WE ARE
Our company, Hegemonic Project Limited, is a company duly incorporated and organised in accordance with the laws and regulations of the Republic of Cyprus, with registration number HE 386319, and with registered address at 3, Delfon, Episkopio, 2642, Nicosia, Cyprus (the “Company”). Our Company acts as the controller and determines the purposes and means of the processing of your personal data.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. [This version was last updated on [22/08/2024].
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
WHAT DATA WE COLLECT ABOUT YOU
Personal data means any information relating to an individual from which that person can be identified, directly or indirectly.
We collect your personal data only for the lawful purposes as provided under the laws and regulations of the Republic of Cyprus and the European Union.
The personal data we collect about you is the following:-
- Identity Data: your name and surname
- Contact Data: your residential and billing address, phone number, email address
- Transaction Data: data about your online purchases (for instance, the details of your credit card with which you will purchase the products, what you have bought, when and where you bought it, how you paid for it, gift vouchers, coupons etc)
- Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
- Usage Data: information about how you use our website, and which products you purchase from us.
- Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences for the purposes of receiving marketing from us about our new products and in receiving our newsletter
We do not collect any Special Categories of Personal Data about you (i.e. your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you, as per below:
- Direct Interactions: You provide personal data when you:
- Purchase our products or services: This includes information necessary to process and fulfill your order.
- Create an account on our website: This includes personal details such as your name, email address, and login credentials.
- Subscribe to our newsletter: This includes your email address and preferences.
- Request marketing to be sent to you: This includes your contact details and marketing preferences.
- Give us feedback or contact us: This includes the information you provide in communications with our customer service team.
- Automated Technologies or Interactions: As you interact with our website, we automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data using:
- Cookies: Small files placed on your device to track and store information about your website usage. Please see our Cookie Policy for further details.
- Server Logs: Logs that record interactions with our website, providing insights into user behavior.
- Other Technologies: Such as web beacons, pixels (e.g., Facebook Pixel), and tags used to track user behavior and interactions with our site.
- Third Parties or Publicly Available Sources: We receive personal data about you from various third parties, including:
- Courier or Delivery Companies: Companies that deliver our products to you, requiring your contact and shipping details.
- Payment System Services: Services like Stripe and PayPal that process your payments securely.
- Analytics Providers, such as:
- Google Analytics 4 (GA4): Tracks and reports website traffic and user behavior.
- Hotjar: Provides insights into user behavior through heatmaps, session recordings, and surveys.
- Site Kit by Google: Integrates multiple Google tools to provide insights into website performance.
- Advertising Networks, such as:
- Facebook Pixel: Tracks conversions from Facebook ads, optimizes ads based on collected data, builds targeted audiences for future ads, and remarkets to qualified leads.
- Search Information Providers.
HOW YOUR PERSONAL DATA IS PROCESSED
We only process your personal data in accordance with the lawful bases provided under the law. We may collect, use, store, transfer and disclose to third parties different kinds of personal data about you which we have grouped together as follows:
- Where we need to perform the contract we are about to enter into or have entered into with you (“Performance of Contract”);
- Where it is necessary for our legitimate interests. Legitimate Interest means the interest of our business in operating and managing our business to enable us to provide you with the best service or product, as the case may be, and the best and most secure experience. We put our best efforts to balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests (“Legitimate Interests”);
- Where you have granted your free and informed consent. We will get your consent before sending any marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us (“Consent”);
- Where we need to comply with a legal obligation (“Legal Obligation”).
PURPOSES OF PERSONAL DATA PROCESSING
In the table below, we corresponded the use of your personal data with on the legal bases we rely on to do so. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
|
Purpose/Activity |
Type of data | Lawful basis for processing including basis of legitimate interest |
| To create an account on our website |
|
Legitimate Interests (to keep our records updated and to be able to contact you when necessary) |
| To process and deliver your order |
|
Performance of a contract with you Necessary for our legitimate interests (to know which of our products are most sold to our customers, to grow our business and to inform our marketing strategy) |
|
To manage our relationship with you which will include:
|
|
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to improve our products and services and to grow our business) |
| To enable you to participate in a giveaway, competition or complete a survey |
|
Performance of a contract with you Necessary for our legitimate interests (to study which products our customers prefer and are most sold, to develop them and grow our business) |
| To administer and protect our business and this website (including anti-virus systems, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
Necessary for our legitimate interests (to allow us to run our business smoothly and without problems, to prevent any hacks or other problems to our website, to have network security, to prevent fraud) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, products and services, marketing, customer relationships and experience of our website |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define kinds and groups of customers, to keep our website updated and easy to use and navigate, to develop our marketing strategy and grow our business) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products and services and grow our business) |
Change of purpose
Your personal data will only be processed in accordance with the above purposes, unless the personal data must be processed for another reason or purpose which we reasonably believe is compatible with the original purpose. We may also process your personal data without your knowledge or consent, if we are required by law to do so, always in compliance with the present Privacy Policy. If your personal data is about to be processed for an unrelated purpose, we will contact you prior to taking any action in order to obtain your consent. If we do not get your consent, your data will not be processed for an unrelated purpose to the original purpose.
You may request to be furnished with information about the processing of your personal data by contacting us.
If you fail to provide personal data
There is no obligation for you to provide any of the personal data above. However, in order to be able to perform our side of the agreement between us, if such agreement exists, the personal data requested are absolutely necessary, and if you fail to provide us with the data requested, and at the time requested, we may not be able to perform the contract. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Marketing and Promotional Offers
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please note that you can unsubscribe from any marketing and advertising emails anytime you wish by clicking on the “unsubscribe” link on the bottom of each email.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Irrespective of the fact that you opt out of receiving these marketing messages, personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions will be still kept by us as per the terms of the present Privacy Policy.
COOKIES
Cookies are small files, may be placed on your computer’s hard drive once you give them permission by accepting them. They usually allow web applications to identify the use you make as an individual and then tailor them in accordance to your likes and dislikes by gathering information about your preferences.
Our website uses traffic log cookies to identify which parts of our website are most visited in order to improve our wensite to the customer needs. We use this information only for statistical purposes and for the betterment of our business and then the data is removed from our system.
A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies through your web browser. However, this may prevent you from taking full advantage of our website.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above:-
Internal Third Parties:-
- Employees and associates of our company who need access to your personal data to perform their duties (e.g., sending newsletters, processing orders, and handling customer service).
External Third Parties:
- Payment Processors: Companies such as Stripe and PayPal, which will process your credit card details to accept and process your payment.
- Delivery Services: Courier services that will receive your contact details to deliver your order.
- Analytics Providers: Companies such as Hotjar and Google Analytics 4 (GA4) that help us analyze website usage and improve our services. These providers may collect information such as IP addresses, browsing behavior, and interactions with our site. Additionally, we track UTMs and QR codes to analyze the effectiveness of our marketing campaigns.
- Marketing Partners: Companies that assist us in delivering marketing communications and tracking the effectiveness of our campaigns using UTMs and QR codes.
The above third parties process personal data on behalf of us. Where processing is to be carried out on our behalf, we only use processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that complies with either the EU law or the law of the country in which they are located to ensure protection of your rights. Where the third parties are based outside the European Union, we ensure that we collaborate with entries that provide adequate level of protection of personal data, similar to ours, to the best possible extent. Also, for further safeguard of your rights, we only share with each third party only the personal data information needed for the purposes of providing their services and we also execute a Data Protection Agreement with them for that matter. In the event that we stop collaborating with any of the above third parties, any of the personal data shared with them will be erased.
DATA SECURITY
Our website has been equipped with security safeguards to ensure that your personal data will not be accidentally lost, used, altered, or accessed by unauthorized entries. We use advanced security measures, including encryption and secure servers, to protect your personal data. In the event of a data breach, hack, or other unexpected events, both our company and our hosting provider will take immediate action to contain and mitigate the breach. We will notify affected users promptly as required by law and will provide information on the nature of the breach, the data affected, and the measures taken to address the issue.
While we implement stringent security measures to protect your personal data, no system is entirely infallible. By using our website, you acknowledge and accept that we cannot guarantee absolute security against all potential threats. Our company and our hosting provider shall not be held liable for any unauthorized access to, or loss of, your personal data due to circumstances beyond our reasonable control.
DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to give effect to the purposes we collected it for, but also for any other reason we believe that it is reasonably justified, incluing but not limited to, any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the nature of your personal data and the purposes for which we process your personal data and whether we can achieve those purposes through other means.
YOUR LEGAL RIGHTS
By virtue of the law, you have the following rights with respect to your personal data.
Right to access your personal data: you can obtain confirmation from us as to whether your personal data is processed and if so, access that personal data, or get a copy of it, whichever we are able to provide you with, and information about the processing of your personal data.
Right to rectify your personal data: you have the right to request from us to rectify any personal data we have about you that is not correct or complete any incomplete datan and to be informed about the rectification once effected.
Right to erase your personal data: you have the right to obtain from us erasure of your personal data where any of the grounds provided under the law apply, and to be informed about the erasure once effected.
Right to restrict the processing of your personal data: you have the right to request from us restriction of processing of your personal data, with the exception of storage, if any of the grounds provided under the law apply.
Right to transmit your personal data to another controller: you have the right to request from us your personal data in a machine-readable format in order to transfer them to another controller, provided that such personal data has been obtained on consent or for the performance of a contract and are processed by automated means.
Right to object to processing of your personal data: you have the right to object to the processing of your personal data at any time, however, please note that this may prevent us from performing any of the purposes stated in the table above and thus, hinder us from providing any goods or services.
Right to withdraw consent: where consent has been provided for the processing of your personal data, you have the right to withdraw it at any time, however, please note that this may prevent us from providing any goods or services.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is unreasonable, repetitive or unnecessary and disproportionately exceed the expenses of our business to provide you with such access.
In the event you wish to exercise any of the above rights, we may request further information from you in order to confirm your identity and ensure that the person who requests to exercise any of the above rights is you. This is a security measure to protect your personal rights.
We try to respond to all legitimate requests within one month, however, further time may be needed if a request to access your data is particularly complex. You will be kept posted at all times about the process of your request.
You have the right to make a complaint at any time to the Data Protection Commissioner (DPC) of the Republic of Cyprus. (ICO). We would, however, appreciate it if you contacted us first to give us the chance to deal with your concerns, before appealing to the DPC.
APPLICABLE LAW AND JURISDICTION
The laws and regulations of the Republic of Cyprus, and the relevant regulations of the European Union, as those may be amended from time to time, shall govern the present Privacy Policy and the Courts of the Republic of Cyprus shall have exclusive jurisdiction for adjudication of any disputes that may arise with respect to the present Privacy Policy.
AMENDMENTS TO THE PRESENT PRIVACY POLICY
The present Privacy Policy may be amended whenever deemed necessary. Where there are major amendments to the present Privacy Policy you may be prompted in the website to accept or decline the updated Privacy Policy. If you decline the updated Privacy Policy then we shall cease to process your personal data and erase them.
We strongly urge you to read the Privacy Policy of our company from time to time in order to be informed at all times about the protection of your personal data.
CONTACT US
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us by sending an email to info@hegemonicproject.com.
Your concerns are very important to us and endeavor to address all of your requests promptly.