DIGITAL TREE MEDIA PRIVACY POLICY

Your data protection is important to us!

Please take a moment to read this Privacy Policy (hereinafter "the Policy") and learn how the company DIGITAL TREE MEDIA LTD, with registered office at 8 Michail Karaoli Street, Anemomilos Building, 3rd floor, Nicosia, 1095, Cyprus, as Data Controller Data collects, uses and generally processes your personal data when you visit or use its websites or social media pages.

Digital Tree Media Ltd and all its subsidiaries and/or affiliated companies hereinafter referred to as "we", "us" or "our", is committed to the protection of privacy and the secure processing of the personal data it holds, with an open and transparent manner and in full compliance with the General Regulation for the Protection of Personal Data of the European Union (Regulation 2016/679) (hereinafter "the Regulation") and with the legislation in force in Cyprus, which provides for the Protection of Natural Persons Against of the Processing of Personal Data and the Free Circulation of such Data Law of 2018 (Law 125 (I)/2018), which governs the collection and processing of Personal Data of Individuals.

Therefore, we have developed this Privacy Policy which governs the collection, use, disclosure, transfer and storage of personal data. Please read our privacy practices carefully to understand our policies regarding your data and how we will treat it. For any questions do not hesitate to contact us.

Our websites

Digital Tree Media Ltd offers a wide range of services creating a rich portfolio of online news and other media services:

www.kerkida.net: is the number one website in Cyprus that provides comprehensive coverage of all sports events through reports and audio-visual material.
The website www.offsite.com.cy is a news portal dedicated to providing comprehensive, objective, direct and in-depth information.
The website www.brief.com.cy is dedicated to providing informed and independent journalism to a specialized audience, providing the latest news of the local and global economy, with daily updates on politics, cryptocurrencies, energy issues and opinion blogs.
The website www.mylife.com.cy celebrates the life and style of the modern woman through a unique lens. Our topics range from fashion and cooking to health and beauty.
The website www.ffwd.com.cy is an English language online portal invented to shake up how audiences in Cyprus consume and read tech, business and policy news. FFWD covers not just everyday news but also thought through pieces that cover and answer true questions and conversations in today’s society in Cyprus.
The website www.avant-garde.com.cy offers an overview of global and local events, new faces, interesting events and beautiful places to explore.
The website https://digitaltv.com.cy is an online television that offers live and on-demand content focused on news coverage, general entertainment, educational and family programs in an original and easily consumable format, reflecting the pace of the modern digital world.

How we collect personal data

This Privacy Policy applies to the Data we collect:

Directly from you when you contact us
Directly from you when you subscribe to our newsletter and/or push updates
Through your use of our websites, such as through cookies
Through our Social Media pages
Directly from you when you enter corporate competitions through our websites and social networks
Through third parties in the normal performance of our company's operations in order to provide the service you requested

Our websites may sometimes contain links to third party websites and services, which are not controlled by us. These websites have their own privacy policies and Digital Tree Media Ltd is in no way responsible for the Privacy Policy of visitors/users following these websites.

What personal data we collect

We collect and use various types of data, including Data from which subjects can be identified ("Personal Data" means any Data relating to an identified or identifiable natural person ("data subject") a natural person who can identifiable is that which can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, and location data, an online identifier or to one or more factors relating to the physical, physiological, genetic, intellectual, economic, cultural or social identity of that natural person).

Such data may include your first and last name, email address, address and postal code, contact number, as well as other data related to cookies, online identifiers, demographic information and other (online) communication data etc. ., always regarding the relationship we have with you.

Purpose for which we use your personal data

In general, we may process your personal data for the following purposes:

Contacting you to respond to your requests, complaints and questions
To provide you with our newsletter in accordance with your subscription to our newsletter service
To send you updates in accordance with your consent
To improve our services and analyze the use of our websites through analytical and statistical data when you visit our websites, after anonymizing your data.
For targeted advertising after your express consent
To detect, prevent and address actual or potential fraud, illegal activity or intellectual property infringement
To enforce our terms and conditions and to comply with our legal obligations as they arise under applicable laws or our regulatory authorities;
For any other purpose with your consent.

Disclosure of your personal data

We do not share your Personal Data with third parties except as stated below:

Collaborators. We share Personal Data with our affiliates and partners to the extent that this is required for the purposes for which you provided the data or to the extent that you have given your consent.
Service Providers. To our authorized service providers (Data Processors) who perform certain services on our behalf, including services for the purposes of providing the services you have requested from us, customer administration and security. These service providers may have access to the Personal Data required to perform their functions but are not permitted to share or use this data for any other purposes. We have taken all reasonable steps to ensure that they comply with applicable data protection regulations, such as signing binding Data Protection Agreements.
Legal heirs. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, either as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which personal data held are among the transferred assets. In the event of such a sale or transfer, we will use reasonable efforts to ensure that the entity to which we transfer your personal data uses it in a manner consistent with this Privacy Policy.

We also disclose your Personal Data to other third parties, including official authorities, courts or other public bodies:

In response to a subpoena or similar investigative request, court order or other judicial or administrative order, or request for cooperation from law enforcement or another government agency; to establish or exercise our legal rights; to defend against legal claims; to comply with applicable law or to cooperate with law enforcement, governmental or regulatory agencies; or to enforce the terms and conditions of our Website or other agreements or policies. or as otherwise required by law (including in response to any governmental or regulatory request). In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
To the extent disclosure is necessary in connection with efforts to investigate, prevent, report or take other action related to illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, users us, our employees or others. to maintain and protect the security and integrity of the Website or our infrastructure.

We may disclose aggregated data about subjects and Data that does not identify any individual, without limitation. In particular, we may transfer non-Personal Data and process it outside your country of residence. We may combine Non-Personal Data we collect with additional Non-Personal Data collected from other sources. We may also share this aggregated data with third parties, including consultants, advertisers and investors, for the purpose of conducting general business analysis.

How we store your Personal Data

The Data we collect about you, including Personal Data, is stored and processed securely in Cyprus and/or in remote cases in Countries within the European Union.

Retention of Personal Data

The period for which we retain your Personal Data necessary for compliance and law enforcement purposes varies and depends on the nature of our legal obligations and claims in each case.

To the extent that we have collected your Personal Data for other purposes as stated in this Policy, we retain your Personal Data for as long as you have an active relationship with us, as required to provide you with our respective services and in accordance with the relevant laws of Cyprus Democracy. For more information regarding a specific retention period contact us at [email protected].

Legal basis for the Collection, Use and Disclosure of your Personal Data

There are different legal bases on which we rely for the collection, use and disclosure of your Personal Data, namely:

Consent: We rely on your consent to use (i) your Personal Data for marketing and advertising purposes, (ii) your Personal Data for other purposes where we ask for your consent and for which the purpose of processing is not related to the services we provide we offer you.
Performance of contract: The use of your Personal Data for the purposes of providing the services, customer management and functionality and security as described above is necessary for the performance of the services provided to you in accordance with our terms and conditions and in accordance with any other contract you have with us.
Compliance with legal obligation: We are granted the right to use your Personal Data to the extent necessary to comply with the legal obligation to which we are subject.
Protection of your vital interests: The processing of your Personal Data is necessary to protect your vital interests if you are vitally or legally incapable of giving your consent.
Protection of our legitimate interests: The processing of your Personal Data is necessary for the purposes of the legitimate interests pursued by us or by third parties, unless these interests are overridden by your interests or fundamental rights and freedoms that require the protection of personal data, in particular when the data subject is a child.

How we protect the Security of your Personal Data

We take appropriate technical and organizational security measures (including physical, electronic and procedural measures) to protect your Personal Data from unauthorized access, unlawful use, interference, modification or disclosure in accordance with the requirements of the Regulation. For example, only authorized employees are permitted to access Personal Data and may access it only for permitted business functions. In addition, we have trained our employees on how to handle, manage and process personal data, implemented upgraded technical measures and transformed our policies and procedures to comply with the General Data Protection Regulation.

Automated decision-making, including profiling

We reserve the right to use automated decision-making in the following circumstances: when deemed necessary to provide services to you, with your written, express consent and if appropriate measures have been taken to safeguard your rights.

Choices About How We Collect, Use and Disclose Your Personal Data

We strive to provide you with choices about the Personal Data you provide to us.

When you work with us, you may be given the option to receive emails, newsletters or promotional materials about our services, improvements, performance, special offers or containing special content distributions from us. If you consent and even later decide that you no longer wish to receive commercial or promotional emails or newsletters from us, you should take advantage of the unsubscribe mechanism set out in the applicable notice or submit your request to us by email. It may take up to thirty days for us to process an exemption request.

If you have provided Personal Data, you may terminate your relationship with us at any time in accordance with the provision of the agreement or commitment between us. If you choose to do so, your Personal Data will be deleted in accordance with our retention policy.

Subject to the provisions of the General Data Protection Regulation, you have the following rights in relation to your Personal Data: (Please note that these rights are not absolute and, in some cases, are subject to conditions as defined by law):

Right of access - You have the right to access your personal data, as well as the right to request a copy of your personal data held and processed by our company.
Right of Rectification - You have the right to request the rectification of any incomplete and/or inaccurate Personal Data we hold about you.
Right to Erasure - You have the right to request the erasure of personal data only if one of the following reasons applies:
1. The personal data are no longer necessary in relation to the purposes for which they were collected or processed.
2. If the processing is based on your consent and you have withdrawn this consent (on which the processing is based) in accordance with Articles 6.1.a and 9.2.a of the regulation and if no other legal basis applies, for processing.
3. If you object to processing in accordance with Article 21.1 of the regulation and there are no compelling and legitimate grounds for processing.
4. If the personal data has been processed unlawfully.
5. If the Personal Data must be deleted pursuant to a legal obligation under Union law to which our company is subject.
6. If the personal data has been collected in relation to the provision referred to in article 8.1 of the Regulation.
Right to Object - You have the right to object to the processing of your Personal Data at any time and for reasons related to a specific situation, unless there are compelling legal grounds for the processing that override your interests, rights and freedoms.
Right to restriction of processing - You retain the right to request the restriction of processing of your Personal Data so that we can no longer process that Data until the restriction is lifted (for example, the data has been rectified).
Right to Data Portability - You have the right to request the portability of your personal data, which you have provided to our company. This Data will be provided to you in a structured, widely used and machine-readable format and, in some cases, you may also have the right to ask us to send the Data to another organization, provided that such transfer is technically feasible.
Right to Object and Automated Individual Decision-Making (including profiling) - You have the right to request that we do not make any decisions about you based solely on automated processing, including profiling, only where legal or significant consequences for you .

If you have any questions about the type of personal data we hold about you or if you wish to exercise any right regarding your personal data, please send a written request to the email [email protected] or the postal address provided below of the Privacy Policy. We do, however, reserve the right to deny any requests for access or to enforce restrictions or other claims if required or permitted by law.

Use of our Websites by Children

Our websites are not directed at persons under the age of 16 (for Cypriot citizens it is under the age of 14). We do not knowingly collect personal information from children. If we become aware that a child under the specified age has provided us with personal information, we will take steps to delete that information. If you become aware that a child has provided us with personal information, please contact us at the contact information listed below.

Personal Data in Journalism

Digital Tree Media Ltd through its websites and social media pages may publish personal data as part of its journalistic purposes, according to the article. 85 of the GDPR, for the right to freedom of expression and information, including processing for journalistic purposes and for purposes of academic, artistic or literary expression.

Changes to our Privacy Policy

We may modify or revise our Privacy Policy from time to time. Although we may attempt to notify you when material changes are made to this Privacy Policy, you are expected to periodically check the most up-to-date version found on our website so that you are aware of any changes, as they are binding on you.

If we change anything in our privacy policy, the date of the change will be reflected in the "last modified date" below. You agree to periodically review this Privacy Policy and refresh the page when you do so. You agree as you note the date of the last revision to our Privacy Policy. By continuing to use the Site after a modified version of the Privacy Policy is made available by us in a way that you can easily see, you acknowledge that modification.

No Third Party Rights

This Privacy Policy does not create rights imposed by third parties or require the disclosure of any personal data relating to users of the Website.

No Error Free Performance

We do not guarantee error-free performance under this Privacy Policy. We will use reasonable efforts to comply with this Privacy Policy and will take immediate corrective action when we become aware of any failure to comply with our Privacy Policy. We will not be liable for any incidental, consequential or punitive damages related to this privacy policy.

Contact info

If you have any questions about this Privacy Policy or our data management practices, please contact us at [email protected].

You can also contact us at 8 Michael Karaoli, Windmill Building, 3rd floor, Nicosia, 1095, Cyprus, phone + 357-22396999

File a complaint

If you believe that your concerns regarding the use of your personal data or any of your data protection rights have not been addressed by us, you have the right to contact us at [email protected] and file a complaint. You also have the right to file a complaint with the Office of the Commissioner for Personal Data Protection at http://www.dataprotection.gov.cy.

Last modified date 6/14/2021