Effective date: April 22, 2024

Business Name: A.A. UntitledPros (“UntitledPros”)

Business Registration Number: EE 59129

www.untitledpros.com (the “Site”) is owned and operated by UntitledPros. UntitledPros is the data controller and can be contacted at:

1. Email: info@untitledpros.com
2. Phone: +35796935400
3. WhatsApp
4. Address: Archiepiskopou Makariou III 38, Oroklini 7040, Larnaca, Cyprus

Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

1. The personal data we will collect;
2. Use of collected data;
3. Who has access to the data collected;
4. The rights of Site users; and
5. The Site’s cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.

General Data Protection Regulation (GDPR)
EU Regulations are directly applicable in Cyprus, without the need to implement local legislation. Cyprus, however, has incorporated the provisions of the Regulation in the local legislation with Law 125 (I)/2018. (Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data in 2018).

Kindly consider to incorporate references to the CY Law in cases of users in the Republic of Cyprus. For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the English Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

Consent
By using our Site users agree that they consent to the:

The conditions set out in this Privacy Policy.

When the legal basis for us processing your data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by: Users can withdraw their consent by contacting us via email at: info@untitledpros.com

Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal basis to collect and process the personal data of users in the EU:

Users have provided their consent to the processing of their data for one or more specific purposes (as per sub-paragraph (a) of paragraph 1 of Article 6 of the GDPR).

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data are collected in a Non-Automatic Way.

We may also collect the following data when you perform certain functions on our Site:

1. First and last name;
2. Email address;
3. Phone number;
4. Address; and
5. Payment information.

This data may be collected when customers make a purchase on our website and enter their details during the checkout process.

How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect when the user performs certain functions may be used for the following purposes:

1. For communication to facilitate the completion of the services we offer. (After completing the purchase, a professional will contact you to guide you through the necessary content requirements).
2. For online purchases: We use the data you provide to help you buy our services online. This involves processing transactions and giving you the information you need to get the services you’ve chosen. (The amount listed on our website for sales represents a 50% deposit. Upon the completion of your purchase, the remaining 50% payment is required. Please note that upon completing your purchase, you will receive a payment receipt directly to the email address provided during the transaction).
3. For potential future automatic annual payments if the customer opts for a Hosting or Support Package. (With every website purchase, we provide free hosting for the first year, allowing you to get started without any additional cost. Starting from the second year, there is an annual fee for hosting, ensuring continued access to our hosting services).
4. To receive updates and newsletters: With the user’s consent, the collected data may be used to send periodic emails containing business news, updates, promotions, or related service information. Users have the option to subscribe or unsubscribe from these communications at any time.

Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:

1. If the law requires it;
2. If it is required for any legal proceeding;
3. To prove or protect our legal rights; and
4. To buyers or potential buyers of this business in the event that we seek to sell the business.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data
User data will be stored until the purpose of the data collected has been achieved. You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data
For enhanced security measures, we employ robust browser encryption and store all data on servers located within secure facilities. Access to any data is restricted to authorized personnel. Our business adheres to stringent confidentiality agreements, and any violation of these agreements would lead to appropriate consequences.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore, we are unable to guarantee the security of user data beyond what is reasonably practical.

Your Rights as a User
Under the GDPR, you have the following rights:

1. Right to be informed;
2. Right of access;
3. Right to rectification;
4. Right to erasure;
5. Right to restrict processing;
6. Right to data portability; and
7. Right to object and automated individual decision-making.

Children
The GDPR gives the flexibility to Member States to provide for a lower age provided that such lower age is not below 13 yrs old.

We may collect personal information from individuals under the age of 16 through our online store. It is essential to note that any purchase of our service by individuals in this age group necessitates parental or guardian approval through a designated consent process. Please be aware that we are not responsible for obtaining this approval; it is the responsibility of the parent or guardian to provide consent for the collection of personal information during the purchase process.

If you have any reason to believe that consent in relation to a child under the age of 16 is not given by a parent or a guardian, please e-mail us at info@untitledpros.com. We will investigate any notification and, if appropriate, delete the personal information from our systems.

How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data, and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact us:

1. Email: info@untitledpros.com
2. Phone: +35796935400
3. WhatsApp
4. Address: Archiepiskopou Makariou III 38, Oroklini 7040, Larnaca, Cyprus

Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not track the users of our Site over time and across third party websites and therefore we do not respond to browser-initiated DNT signals.

Cookies Policy
A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

1. Necessary: Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
2. Functional: Functional cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.
3. Analytics: Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
4. Performance: Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
5. Advertisement: Advertisement cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns.

Modifications
This Privacy Policy may be amended from time to time to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office / Data Protection Commission.

Cloudflare Turnstile
We use Cloudflare Turnstile to protect our website forms from spam and automated abuse. Turnstile may process technical information required to verify whether a visitor is human. For more information, please review Cloudflare’s Turnstile Privacy Addendum.

Contact Information
If you have any questions, concerns, or complaints, you can contact our privacy officer, UntitledPros, at:

1. Email: info@untitledpros.com
2. Phone: +35796935400
3. WhatsApp
4. Address: Archiepiskopou Makariou III 38, Oroklini 7040, Larnaca, Cyprus

Business Name: A.A. UntitledPros (“UntitledPros”)

Business Registration Number: EE 59129