Dilution Ratio

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Privacy Policy

Welcome to the Dilution Ratio Ltd’s privacy policy.

Dilution Ratio Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Dilution Ratio Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service or take part in a competition.

We do not knowingly collect data relating to children (under 18 years old).

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Data Controller

The data controller responsible for your personal data is, unless otherwise specified, Dilution Ratio Limited (collectively referred to as “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy, our privacy practices, the date we hold on you, or you would like to exercise your legal rights, please do not hesitate to contact us:

Full name: Michalis Karanikolas, as director of Dilution Ratio Limited

Email address: info@dilutionratio.com

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. 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, plug-ins and applications. 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.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  •  Identity Data includes first name, last name, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes 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.
  • Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). 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.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
    ➢ apply for our products or services;
    ➢ subscribe to our service or publications;
    ➢ request marketing to be sent to you;
    ➢ enter a competition, promotion or survey; or
    ➢ give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies and other similar technologies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public available sources as set out below:
    Technical Data from the following parties:
    (a) analytics providers such as Google Analytics (Google LLC.) and Meta Platforms Inc. based outside Cyprus;
    (b) advertising networks such as Google AdSense (Google LLC.) based outside Cyprus; and
    (c) search information providers such as Google LLC. based outside Cyprus.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as JCC Smart based inside Cyprus, Paypal based outside Cyprus and Viva Wallet based outside Cyprus.
  • Identity and Contact Data from publicly available sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We collect your personal data so that we can:

  1. register you as a new customer;
  2. process and deliver your order including, manage payments, fees and charges, and collect and recover money owed to us;
  3. manage our relationship with you which will include, notifying you about changes to our terms or privacy policy, or asking you to leave a review or take a survey;
  4. enable you to partake in a prize draw, competition or complete a survey;
  5. administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  6. deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  7. use data analytics to improve our website, products/services, SPAM protection, marketing, customer relationships and experiences;
  8. make suggestions and recommendations to you about goods or services that may be of interest to you.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your personal 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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a good or service purchase, good or service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above.

  • External Third Parties:
    Service providers: this encompasses entities that facilitate the delivery of your purchases, including payment service providers, warehouses, order packers and delivery and courier companies.
    Brand Partners: in case these partners directly dispatch your orders, we will inform you during the ordering process.
    Professional service providers: we collaborate or may collaborate with professional service providers like marketing agencies, advertising partners, and website hosts who assist us in our business.
    Professional advisers: this includes our lawyers, bankers, auditors and insurers based in Cyprus who provide consultancy, banking, legal, insurance and accounting services.
    The tax department, regulators and other authorities based in Cyprus who require reporting of processing activities in certain circumstances.
    Credit reference agencies, law enforcement bodies and fraud prevention agencies for purposes of combating fraud.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Your personal data will not be retained for a longer period than permitted under applicable law.

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 unauthorised 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, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Further information on the processing of Personal Data Analytics

The services contained in this section enable us to monitor and analyze web traffic and can be used to keep track of user behavior.

  • Google Analytics (Google LLC)
    Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services.

    Google may use the data collected to contextualize and personalize the ads of its own advertising network.

    Personal Data collected: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant

Contacting the User

  • Contact form

    By filling in the contact form with your data (which you may also find using the link that will be forwarded to you via email) you authorize us to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data collected: email address; first name; last name; phone number.


SPAM protection

This type of service analyzes the traffic of our website, potentially containing users’ personal data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  • Google reCAPTCHA (Google LLC)

    Google reCAPTCHA is a SPAM protection service provided by Google.
    The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

    Personal Data collected: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy. Privacy Shield participant.
9. Further information about Automated Decision Making

Automated decision-making

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the user, is taken solely by technological means, without any human intervention. Our website may use your personal data to make decisions entirely or partially based on automated processes according to the purposes outlined in this policy. Our website adopts automated decision-making processes as far as necessary to enter into or perform a contract between you and us, or on the basis of your explicit consent, where such consent is required by the law.

Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.

The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of user’s failure to meet their obligation under a contract.

Consequences of automated decision-making processes for users and rights of users subjected to it

As a consequence, users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.

In particular, users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking us to reconsider it or take a new decision on a different basis;
  • request and obtain human intervention on such processing.

10. Your legal rights

We would like to make sure that you are fully aware of all your data protection rights. Every user is entitled to the following rights:

(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you believe that our Company is processing your data illegally, you have the right to lodge a complaint with the competent supervisory authority. In Cyprus, this is the Commissioner for the Protection of Personal Data: http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/All/2FBD2ACD407DEFE8C22582B9002E7019.

No fee usually required

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 clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 30 working days. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Additional information about Data collection and processing

 

Legal action

Your personal data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of our Website or in relation to our goods or services.

You declare to be aware that we may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this policy, our Website may provide you with additional and contextual information concerning particular goods or services or the collection and processing of personal data upon request.

System logs and maintenance

For operation and maintenance purposes, our website and any third-party services may collect files that record interaction with our website (System logs) use other personal data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of personal data may be requested from us at any time by contacting us.

How “Do Not Track” requests are handled

Our website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by giving notice to its users on this page and possibly within our Website. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the user’s consent (if any), we shall collect a new consent from the user, where required.