PRIVACY POLICY

INTRODUCTION
Welcome to the SELLEBRITIES privacy policy.

We respect your privacy and are committed to protecting your personal data.  This privacy policy will inform you as to how we collect, use and look after your personal data.  It further describes your privacy rights and the control you can exercise in relation to your personal data.

1.  IMPORTANT INFORMATION

CONTROLLER
A Data Controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.  This Privacy Policy is issued on behalf of SELLEBRITIES Ltd., who is the data controller responsible for this website and your personal data (collectively referred to as “SELLEBRITIES”, “We”, “Us” or “Our” in this Policy).  If you have questions in regard to this privacy policy, please contact us on the details outlined below:

Company Name:  SELLEBRITIES Ltd.
Email Address:  [email protected]
Postal Address:  Archimidous 11, ERA HOUSE, 3031 Limassol, Cyprus
Telephone Number: +357 25 871 684
Our Website:  www.sellebrities.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.  DATA WE PROCESS

Personal data, or personal information, means any information about an individual from which that person can be identified.

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 or similar identifier and title.
  • Contact Data includes billing address, delivery address, email address and telephone numbers (including mobile telephone number(s)), postal address.
  • Payment Details Data includes billing address, payment method, bank account number, account holder name, account security details, invoice records, payment records, SWIFT details, IBAN details, payment amount, payment date.
  • Transaction Data includes details about payments to and from you and other details of and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, 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 our website.
  • Profile Data includes your purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your consent to receive newsletters, updates or any other communication from us.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose.  Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

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.  In this case, we may have to cancel the services we provide to you, but we will notify you if this is the case at the time.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?

We regularly collect or receive personal data as part of our professional services and or activities.  We use different methods to collect data from and about you including:

  • Directly from you when you give us your identity, contact and financial data by filling in our forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you instruct us to provide services, subscribe to our service or publications, request marketing to be sent to you or provide us with feedback.
  • When you make information public which we may choose to collect.
  • When you or your organisation or business associates seek sales outsourcing advice and other services from us.
  • When you send us information via our website.
  • Via public records and 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 fulfil the contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests and your interests, providing fundamental rights to not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

5.  PURPOSES FOR WHICH YOUR PERSONAL DATA IS USED

We have set out below, a description of all the ways we intend to use your personal data, and the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.  Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

PURPOSE/ACTIVITYDATA CATEGORYLAWFUL BASIS FOR PROCESSING INCL. BASIS FOR LEGITIMATE INTEREST
To register you as a new cliento Identity
o Contact		o Fulfilment of a contract with you
To process and deliver on your instructions including:
o Manage payments, fees and charges
o Collect and recover money owed to us		o Identity
o Contact
o Financial
o Transaction
o Marketing and Communications		o Fulfilment of a contract with you
o Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
o Notification about changes to our terms or privacy policy
o Requesting you to leave a review or take a survey		o Identity
o Contact
o Profile
o Marketing and Communications		o Fulfilment of a contract with you
o Necessary to comply with a legal obligation
o Necessary for our legitimate interests (to maintain our records and analyse how clients use our services)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)o Identity
o Contact
o Technical		o Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and fraud prevention)
o Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the efficacy of the advertising employo Identity
o Contact
o Profile
o Usage
o Marketing and Communications
o Technical		Necessary for our legitimate interests (to analyse how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experienceso Technical
o Usage		Necessary for our legitimate interests (to define relevant clients for our services, to ensure our website is updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to youo Identity
o Contact
o Technical
o Usage
o Profile		Necessary for our legitimate interests (to develop services and grow our business)

6.  MARKETING & OPTING OUT

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  You can ask us to stop sending you marketing messages at any time by following the opt-out, unsubscribe links on any marketing message sent to you or by contacting us any time.  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to use for service provision, experience or other transactions.

7.  DISCLOSURE OF YOUR PERSONAL DATA

Except as described in this policy, SELLEBRITIES will not share, give or sell any personal information to any third-party.  We may disclose such information to respond to subpoenas, court orders or legal processes to establish and exercise our legal rights or defend against legal claims.  We may also share such information if we believe it is necessary to investigate, prevent or take action regarding illegal activities such as suspected fraud, potential threats to the physical safety of any person or as otherwise required by law.

8.  PERSONAL DATA ABOUT OTHERS

In some cases, you may provide personal data to us about other people (such as your customers, directors, officers, employees, shareholders or beneficial owners).  You must ensure that you are entitled to disclose that personal data to us and that, without taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Policy.  In particular, you must ensure that the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual.

9.  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, disclosed used or accessed in an unauthorised way.  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.

10.  DATA RETENTION

Personal data may be kept on our personal IT systems, those of our contractors on in paper files.  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, accounting or reporting requirements.  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.

11.  INFORMATION COLLECTED FROM THE WEBSITE VISITORS

SELLEBRITIES collects and processes personal data related to individual visitors of our website and fills in the role of the Controller for this specific set of information.  Personal data collected by third parties that remain legally and economically independent from SELLEBRITIES do not fall within the scope of this definition.  Please refer to our Cookie Policy for further information. During the course of your visit to our website, the following types of personal data is collected:

  • Due to the use of cookies on our website, SELLEBRITIES may obtain information about a website visitor’s computer and about a website visitor’s number of visits to and use of our website.  This includes information on the website visitor’s IP address (Internet Protocol), geographical location, internet access services provider, browser type, referral source, length of visit and number of page views.
  • In the course of using the contact form provided in the “Contact Us” section, SELLEBRITIES obtains personal information relating to an individual website visitor.
  • For the purpose of subscribing to our website services, email notifications and/or newsletters SELLEBRITIES may obtain personal information and data related to the individual website visitor.
  • Any other information that a website visitor chooses to send to us.
  • Finally, telephone calls may be recorded for training and monitoring purposes.

12.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  If you wish to exercise or discuss any of the rights set out above, please contact us as listed above in this Policy.  We may require proof of your identity prior to giving effect to those rights.

You have the right to:

  • Request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • 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 use.
  • 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.
  • 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.
  • 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:

    o If you want us to establish the data’s accuracy.
    o Where our use of the data is unlawful but you do not want us to erase it.
    o 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.
    o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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.
  • 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.
  • Right to lodge a complaint with the supervisory authority in Cyprus, the Office of the Commissioner of Personal Data (www.dataprotection.gov.cy).

13.  DIRECT MARKETING

We may use the information you give us for direct marketing from us only if you give us your consent.  You can opt-out of receiving direct marketing from us at any time by sending an email using the details set out at the beginning of this policy.

14.  CHILDREN

We do not knowingly collect information from children or other persons who are under 14 years old.  If you are under 14 years old, you may not submit any personal data to us.

15.  CHANGES TO THIS POLICY

This Privacy Policy is effective as of June 1st, 2023. and may be changed from time to time to reflect changing legal requirements or change in our processing practices.  If we change anything important about this policy, we will highlight those changes at the beginning of the policy.

16.  HOW TO CONTACT US

If you would like more information about the way we manage personal data that we hold about you please contact us as set out at the beginning of this policy.