Privacy Notice

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1. Introduction

The company ΠΟΛΙΤΗΣ ΤΩΡΑ ΛΙΜΙΤΕΔ (POLITIS TORA LIMITED), together with its affiliated entities (hereinafter referred to as the “Company”, “we”, “us”, or “our”), is committed to respecting your privacy and takes it seriously.

The Company is headquartered at 8 Vasileiou Voulgaroktonou Street, 1010 Nicosia, Cyprus, and is the owner of the websites https://politis.com.cy, https://parathyro.politis.com.cy and https://gipedo.politis.com.cy, together with its official application, available via the App Store and Google play(collectively referred to as the “Website”). The Company further maintains official accounts on social media platforms, including Instagram, Facebook, X, LinkedIn and YouTube, through which it communicates and engages with its audience (collectively, the “Digital Channels” ).

The Company inform its readers, visitors, users, members, and subscribers (collectively the “Users”) of the type and scope of personal data it collects and processes as a Data Controller, when Users visit and browse the Website.

The Company assures Users that any processing of personal data is carried out in their best interests, adhering to the principles of lawfulness, transparency, accuracy, availability, and integrity at all stages of processing, and in compliance with the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the Cyprus Law 125(I)/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of such Data, and the relevant guidelines and/or recommendations of the Office of the Commissioner for Personal Data Protection (collectively the “Legislation” ).

This Notice should be read together with our Cookie Policy and Terms of Use

2. Data Controller

The Data Controller of your personal data is ΠΟΛΙΤΗΣ ΤΩΡΑ ΛΙΜΙΤΕΔ, with registered office at:

  • Vasileiou Voulgaroktonou 8, 1010 Nicosia, Cyprus
  • Tel: +357 22 861861
  • Fax: +357 22 661583
  • Email: info@politis.com.cy

3. Collection and Use of Personal Data

When using the term “Personal Data” in this Notice, we mean data that relates to you and allows us to identify you, either directly or in combination with other data that we may hold. The Company collects and processes personal data of Users in the context of providing its services, in accordance with legislation. Data is collected in the following instances:

  • When Users register for services and/or subscription packages provided by the Company, including Politis Premium, Politis Newsletter, or other services and/or products offered through the Website
  • When Users utilise any of the Company’s products and/or services.
  • When Users visit the Website and/or interact with the Company’s promotional or advertising activities, including participation in giveaways, competitions, or other promotional campaigns organised by the Company.
  • When Users communicate with the Company through its digital channels, by email, by telephone, or through any other means of communication.

We use your information lawfully in accordance with:

  • Article 6 (1)(a) of the GDPR i.e. for purposes you have consented to
  • Article 6 (1)(b) of the GDPR i.e. as necessary to conclude or perform a contract with you
  • Article 6 (1)(c) of the GDPR i.e. to comply with obligations imposed by law (such as tax legislation)
  • Article 6 (1)(f) of the GDPR, i.e., as necessary for legitimate interests we pursue as a Company

Upon registration for Politis Premium, the following information is requested:

  • Full name
  • Telephone number
  • Email address
  • Residential address(optional)
  • Financial details, such as payment cards for subscribing to Politis Premium

Upon registration for Politis Newsletter, the following information is requested:

  • Full name
  • Email address

The above-mentioned personal data are processed for the following legitimate and specified purposes:

  • Personalisation of user experience and provision of tailored support through content aligned with User preferences.
  • Fulfilment of the Company’s contractual or pre-contractual obligations.
  • Delivery of communications concerning new services, offers, or operational changes to the Website, including newsletters consisting of articles and news published on the Website.
  • Compliance with the Company’s legal obligations.
  • Establishment, exercise, or defence of legal claims.
  • Journalistic purposes, pursuant to Article 85 of the GDPR and national legislation on press freedom.

In addition, certain data are automatically collected when visiting the Website, such as:

  • IP address
  • Operating system type and version
  • Browser type
  • Pages visited and connection/traffic data to and from the Website

Such automated collection serves the purposes of improving the Website’s technical and functional performance ensuring system security, and statistical analysis. We do not use automated decision-making or profiling in a way that produces legal or similarly significant effects on you.

We will not collect special categories of data from you such as personal data concerning your race, political opinions, religion, health or sexual orientation, unless you have chosen to provide that type of personal data to us. If you do, such data will be processed strictly in accordance with GDPR Article 9, with additional safeguards and only where legally permitted.

4. Data retention

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, along with applicable legal requirements.

Where processing is carried out to comply with legal obligations or for the establishment, exercise, or defence of legal claims, the relevant data are retained for the period stipulated by applicable law and/or for as long as necessary to fulfil such purposes, as appropriate to each case.

For your explicit consent to the use of your personal data for recurring processes and purposes (i.e. subscription to our Newsletters), your data will be used until you withdraw your consent. Such withdrawal shall not have retroactive effect and will apply only prospectively.

You may withdraw consent at any time by selecting the “unsubscribe” link located in the footer of each Newsletter email or by contacting us at dpo@politis.com.cy

5. Your Rights

Data subject rights are exercised within the limits provided by the legislation and may be subject to certain legal exceptions or limitations.

The Company has appointed a Data Protection Officer responsible for overseeing compliance with data protection laws and regulations. To exercise any of the rights outlined below, have any questions or comments with regard to this Privacy Notice, you may contact us by email at dpo@politis.com.cy or by post at Vasileiou Voulgaroktonou 8, 1010, Nicosia. P.O. Box 22894, 1524 Nicosia, Cyprus.

You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection via www.dataprotection.gov.cy, if you believe that the processing of your personal data violates the GDPR.

5.1 Right of Access

You have the right to access your personal data free of charge, except in cases where a reasonable fee may be imposed to cover administrative costs, such as where requests are manifestly unfounded, excessive or repetitive, or where additional copies of the same data are requested.

5.2 Right to Rectification

You have the right to request the rectification of your personal data if they are inaccurate or incomplete.

5.3 Right to Erasure

You have the right to request the erasure of your personal data when they are no longer necessary for the purposes for which they were collected or there is no legal basis for continuing their processing. This right is not absolute and may be limited where a legal obligation or other lawful basis exists for retaining the data.

5.4 Right to Restriction of Processing

In specific cases, you may request the restriction or suspension of processing. Where processing is restricted, your data will only be stored and not otherwise processed.

5.5 Right to Object

You may object, at any time and for reasons relating to your particular situation, to the processing of your personal data, unless the Company demonstrates compelling and legitimate grounds for such processing.

5.6 Right to Data Portability

You may request to receive the data you have provided in a structured, commonly used, and machine-readable format or request that it be transmitted to another controller.

5.7 Right to Withdraw Consent

You may withdraw your consent at any time, where processing is based on consent. The withdrawal shall not affect the lawfulness of processing carried out prior to such withdrawal.

6. Disclosure of Personal Data to Third Parties

The Company may transfer or disclose personal data to:

  • Third parties delegated and/or appointed by us for the performance of activities or part of the activities related to the provision of the services requested or to the navigation of the website (i.e., companies that provide IT services, management, and maintenance of the website)
  • Stripe, which acts as our payment service provider for all credit card and debit card payment transactions. Stripe processes your payment details on our behalf in accordance with its privacy policy
  • Mailchimp, which acts as our newsletters distribution platform. Mailchimp processes your full name and email address on our behalf solely for the purpose of delivering our newsletters, in accordance with its privacy policy
  • Amazon Web Services (AWS), acting as hosting and cloud services provider
  • Our affiliated companies or business partners, for internal management, billing, services, and products, and for the overall delivery of our services to you.
  • Agencies and authorities, if required by law. We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else (for example, in response to a valid and properly served legal process such as subpoena or warrant). If we have your contact details, we will take reasonable steps to attempt to notify you prior to disclosing your data unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with your use of our services (iii) is impracticable or unreasonable under the circumstances.
  • Sponsors and Partners, for the purposes of selecting and notifying winners when you participate in any of our competitions and giveaways. We may also share your data with entities offering any prize you have won in order for that entity to contact you about such a prize.
  • Service providers, consultants, potential transaction counterparties, or other third parties, in connection with the negotiation, evaluation, or completion of any transaction in which we are involved, including mergers, acquisitions, liquidations, or business transfers.
  • The extent this is necessary to fulfil any other purpose not mentioned above for which you provided personal information and, if applicable, your consent separately from this Privacy Notice.

We do not disclose, sell, rent, or otherwise share your Personal Data with third parties or unaffiliated entities for their own independent use, unless expressly provided for in this Notice or with your prior consent. We may share data that does not reasonably identify you, to the extent permitted by applicable law.

7. Third-party interactions

Our Website may include content, banners, or links directing you to third-party websites, platforms, or materials. Please note that this Notice does not apply to, and we are not responsible for, the privacy, security, or data processing practices of such third parties, including any tracking technologies they may use. Accessing or using such third-party content is at your own risk. We encourage you to review the relevant privacy policies, terms of use, and security practices of those entities before engaging with their content or services.

8. Data Security

We implement appropriate technical and organisational security measures to protect personal data from loss, unauthorised access, alteration, or misuse. These include:

  • Access control systems
  • Encryption and anonymisation where required
  • Secure storage and transfer protocols
  • Restricted access to authorised personnel
  • Staff training on data protection
  • Incident response mechanisms

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

Despite our efforts, we bring to your attention that no information system can be entirely secure, therefore, we cannot guarantee the absolute security of your information, nor can we be held responsible for the security of any information transmitted to us via networks beyond our control.

9. International Transfers of your Personal Data

Due to the global nature of the Internet and the services we provide, the collection and processing of your personal data in accordance with this Privacy Notice may involve the transfer of such data to countries in which we, our service providers, or our strategic partners are located. Where personal data is transferred to a country or territory outside the European Union (EU) or European Economic Area (EEA) whose laws may provide a different level of protection for personal data than that afforded under Cyprus Law 125(I)/2018 and the General Data Protection Regulation, we ensure that such transfers are carried out in compliance with the legislation. In particular, we implement appropriate safeguards, including entering into contractual arrangements such as the European Commission’s Standard Contractual Clauses (“SCCs”) or other mechanisms recognised under Chapter V of the GDPR, to ensure that your personal data is processed to a standard that is at least equivalent to that required under the legislation.

10. Minors

The Company does not knowingly process personal data relating to children or minors under the age of 14, unless such processing is lawful and only to the extent that consent is provided or authorised by the holder of parental responsibility for the child.

We will make reasonable efforts, taking into account available technology, to verify that such consent is indeed given or authorised by the holder of parental responsibility in such cases.

11. Changes to this Notice

The Company reserves the right to amend this Notice at any time without prior notice to Users. Any updates take effect upon publication on the Website. In the event of any material changes, we will notify you via our website or through any other digital channels made available. Users are advised to consult this Notice regularly before using our website or services to stay informed of any changes.