Our Privacy Policy covers Mastermind Group and its website, https://www.mastermind-cyprus.com.

Privacy Protection
Mastermind Group is committed to protecting your privacy. This policy establishes the management of any personal data relating to you and your use on this website. Protecting your privacy and your personal data is an important aspect of the way we create, organise and implement our activities.

The specific practices outlined in this privacy statement apply to the website. Other companies and/or organisations linked to the website may have different practices, which we may not guarantee. You are encouraged to review the privacy statements of other companies and/or organisations when visiting their websites.

Purpose Specifications and Data Collection
This Privacy Policy outlines the steps that MSM take to:

  • Keep your Personal Data confidential
  • Inform you about how and why we collect such data
  • Outline your rights and our contact information to exercise these rights
  • Raise questions or concerns arising out of this Privacy Policy

You can access and browse the website without disclosing any information about yourself. If you visit the website to read or download information, we collect and store only the following information that is automatically recognised: the date and time, the originating IP address, the domain name, the type of browser and operating system used (if provided by the browser), the URL of the referring page (if provided by the browser), the object requested and the completion status of the request.

Controllers and Processors of Personal Data
MSM with its registered office at 63 Christaki Kranou Street, 4042 Limassol, Cyprus, determines the purposes and means of Personal Data for collection and processing. The processing operations of Personal Data (automated and non-automated), are performed on behalf of MSM.

Why we collect Personal Data

  • Establish identity
  • Perform necessary identity and security verifications
  • Deliver products and services
  • Process transactions and conduct business
  • Deliver products and services
  • Improve products, services and service delivery
  • Provide you with information
  • Cooperate with law enforcement and legal authorities, where required, to comply with applicable laws and with court orders

MSM collect, use and may disclose personal information only as deemed appropriate.
Aggregated statistics and infirmation, where the identity of a specific individual cannot be identified, is not Personal Data.
We reserve the right to use aggregated information, which may include the preparation of aggregated user statistics and information summaries to improve efficiencies. Such aggregated information will not contain Personal Data.
The type of Personal Data we may collect
During the course of using our website, interacting or doing business with us, you may be asked to provide us with:

  • Geographical addresses
  • Demographic information
  • Email addresses
  • Telephone numbers and/or other contact information
  • Names
  • Shipping information
  • Billing information
  • Transaction history
  • Website usage preferences
  • Feedback regarding business, services and purblic relations
  • Source IP addresses
  • Time and dates of access to website servers
  • Language
  • Personal preferences
  • Browser types and configurations

How do we collect Personal Data?
MSM will only collect Personal Data that you have provided (voluntarily or agreed) to us. We will not collect any Personal Data without advising you why and how that Personal Data is being collected and how such Personal Data will be used or disclosed. MSM may collect Personal Data through:

  • Using our website
  • Using our services
  • In the course of communications with us (face-to-face, by email, by phone, mail or otherwise) and in the course of feedback with us regarding our business, services, website and any publications
  • Through the completion of manual or electronic forms
  • Website cookies – identifiers that can be sent from a website via your browser to be placed on your computer’s hard drive. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilising cookies may prevent you from using certain functions and features of our website. Information collected from the use of cookies is used to improve our services.
  • Website traffic information, monitored and analysed in order to determine which services or features may be of interest to visitors, so we may improve our services

Cookies and Other Technologies
As described above, we may collect anonymous information from visits to our site to help us provide better customer service. For example, we keep track of the domains from which people visit and we also measure visitor activity on the website, but we do so in ways that keep the information anonymous. We use the information that we collect to measure the number of visitors to the different areas of our site, and to help us make our site more useful to visitors. This includes analysing these logs periodically to measure the traffic through our servers, the number of pages visited and the level of demand for pages and topics of interest. The logs may be preserved indefinitely and used at any time and in any way to prevent security breaches and to ensure the integrity of the data on our servers.
This anonymous information is used and analysed only at an aggregate level to help us understand trends and patterns. None of this information is reviewed at an individual level. All our employees and processors who have access to personal data and are associated with the processing of that data are obliged to respect the confidentiality of data.

How we may disclose Personal Information
MSM does not sell any Personal Data it collects to third parties. We may share Personal Data with affiliates, subsidiaries, employees, contractors and agents in the course of providing you with our customer services.
We may disclose Personal Data if it’s required to do so:

  • To comply with any legal process served on us
  • Maintain, uphold or protect our rights or property
  • Protect and ensure the personal safety of public or of our clients
  • Protect against criminal activities
  • Detect, prevent, investigate allegations of, or address, misrepresentation or fraud

MSM reserves the right that in the event of bankruptcy filing, mergers with third parties, acquisition by third parties, sale of assets, or any other transfer of our relevant assets to a third party, that we shall be entitled to share the Personal Data provided by you to the third party.

Retention and Disposal
MSM keeps information only for so long as it is needed for the efficient and effective delivery or fulfilment of the software, products or services. We will either destroy or remove information when it is no longer needed.

Security and Storage
MSM endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities, so as to prevent any loss, misuse, unauthorised access, disclosure or modification of Personal Data. This also applies to our disposal or destruction of Personal Data.
We keep collected Personal Data about you strictly confidential. Only authorised and properly trained personnel have access to this data.
Personal information may be stored or processed in any jurisdiction in which we, our affiliates, suppliers, subsidiaries or agents maintain facilities. By supplying us with your data, you consent to any transfer of this information to other jurisdictions (including countries which have not been assessed for adequacy of privacy laws).
MSM use, and will continue to use, industry-standard technology to maintain the security of Personal Data and for our connections to the internet. However, we cannot and do not guarantee the privacy, security, authenticity or non-corruption of any information transmitted through the internet or any information stored in any third-party system connected to the internet.
We verify with any service providers, suppliers etc. with whom we share Personal Data, are committed to maintaining the privacy of Personal Data at standards that are at least as strict as our own privacy policy. It has been communicated to them to refrain from making any independent or unauthorised use of any Personal Data. MSM can however not guarantee the actions, conduct or standards of any such parties.
MSM shall not be responsible for any claims, damages, costs or losses whatsoever arising out of or in any way related to third-party connections to or through the use of the internet.
We do not ensure the protection of any Personal Data that you provide to a third-party website that may reference, be referenced or link to our website. Such data collected by such parties are not subject to, or governed by, this Privacy policy. MSM shall not be responsible for events beyond our direct control, and therefore will not be liable for any direct, indirect, incidental, consequential or punitive damages relating the use or release of Personal Data.

Data Subject Rights
You are entitled at any time to obtain confirmation of the existence of Personal data and to be informed of their contents and origin to verify their accuracy or request that such data be supplemented, updated or rectified.
We are committed to treating you with the greatest respect and consideration.  Should you want to advise us of any questions or concerns regarding this Privacy Policy, confirm the accuracy of applicable Personal Data, believe that the privacy of Personal Data has not been respected, or would like to update or delete incorrect Personal Data, please contact us on the dedicated email address: gdpr@mastermind-cyprus.com
MSM is committed to uphold this policy. We have procedures in place to educate and assist our employees and contractors in fulfilling their obligations under this policy.

By using and/or visiting this website, you signify your consent to this Privacy Policy.

Changes and Updates
This Privacy Policy may be revised periodically and this will be reflected in the ‘Date Last Modified’ section below. Please revisit this page to stay aware of any changes. Your continued use of the website constitutes your agreement to this Privacy Policy and any future versions.

Date Last Modified
May 02, 2018

Privacy Support
If you have any inquiries about our privacy statement, please contact:
Mastermind Group gdpr@mastermind-cyprus.com