Privacy Policy

Privacy Policy

Introduction

This privacy policy (“Policy”) describes how Bolsterup Contech Ltd (Company, or We/Our/Ours/Us) collects, uses, shares and stores personal data. This Policy applies to the site www.bolsterup.co, applications, products, and services and any other sites or applications, products and services that link to the site (collectively, Services). This policy applies to the personal data that relates to you as user of any part of the Services (You, Your).

By using the Services or by clicking a box marked “accept” or “agree”, you understand and agree that we will collect, process, and use your personal data as described in this Policy.

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.  

The Services are not intended for children and we do not knowingly collect data relating to children.  

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

In a nutshell, this Privacy Policy sets out:

  1. Important information and who we are
  2. What personal information we collect about you
  3. How we use your personal information and basis for such use
  4. How we obtain your personal information
  5. Who we share your personal information with 
  6. Cookies
  7. How long we keep your personal information 
  8. How we protect your personal information
  9. Which countries we transfer your personal information to
  10. Your rights regarding your personal information
  11. Our marketing policy
  12. Links to third party websites or apps
  13. Children
  14. Changes to this Policy
  15. Contact us

1 . Important information and who we are
Bolsterup Contech Ltd with registration number HE 434308 and registered office at Lord Byron 36, office 204, 1096 Nicosia, Cyprus is the controller and responsible for your personal data. In some cases, we may process your personal data based on an agreement with a third party. In those cases, that third party is a data controller and we are a data processor. In those cases, the terms of that agreement may govern how we process your personal data.  

If you have any questions about this Policy or how we process your personal data or our privacy practices, please contact us:

Email: support@bolsterup.co

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, the Cyprus regulator for data protection issues. We would appreciate you coming to us with your complaint in the first instance to give us a chance to resolve it.

2. What personal information we collect about you

We only collect the most relevant, proportionate for each purpose and strictly necessary personal information from you in the course of our business when you use the Services. 

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data that includes but is not limited to first name, last name, username or similar identifier, date of birth and gender  
  • Contact Data that includes but is not limited to billing address, delivery address, email address, telephone numbers
  • Financial Data that includes but is not limited to bank account and payment card details
  • Transaction Data that includes but is not limited to details about payments to and from you and other details of products services you have purchased from us
  • Technical Data that includes but is not limited to internet protocol 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 that includes but is not limited to username and password, purchases or orders, interests, preferences, feedback and survey responses
  • Usage Data that includes but is not limited to information about how you use our Services
  • Marketing and Communications Data that includes but is not limited to preferences in receiving marketing from us and our third parties and communication preferences

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our Services. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 information

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 we use your personal information and basis for such use

Purposes for which we will use your personal data

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

  • When we have your consent,  
  • 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.

The firm shall not carry out any automated decision-making activities, including profiling, using your personal information which produce legal effects concerning you or similarly significantly affect you.

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.

3.1 To register you as a new customer
  • Purpose / activity: To register you as a new customer
  • Type of data: (a) Identity, (b) Contact
  • Lawful basis for processing: Performance of a contract with you
3.2 To process and deliver your order including:
  • Purpose / Activity: (a) Manage payments, fees and charges, (b) Collect and recover money owed to us
  • Type of data: (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications
  • Lawful basis for processing: (a) Performance of a contract with you,(b) Necessary for our legitimate interests (to recover debts due to us)
3.3 To manage our relationship with you which will include:
  • Purpose / Activity: (a) Notifying you about changes to our terms or privacy policy, (b) Asking you to leave a review or take a survey
  • Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications
  • Lawful basis for processing: (a) Performance of a contract with you,(b) Necessary to comply with a legal obligation, (c)Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
3.4 To enable you to partake in a prize draw, competition or complete a survey
  • Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications
  • Lawful basis for processing: (a) Performance of a contract with you,(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
3.5 To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Type of data: (a) Identity, (b) Contact, (c) Technical
  • Lawful basis for processing: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (c) Necessary to comply with a legal obligation

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.  

In case we need to collect any Special Categories of Personal Data we will ensure to take all measures to comply with all applicable data protection laws.  

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.

4. How we obtain your personal information

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

  • Information you give us. This is information you consent to giving us about you by filling in forms on Services, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Services, sign up or make an account with us, subscribe to, and purchase subscriptions for, any of our Services, subscribe to our publications, apply for our products and services, share data via social media functions of the Services, request marketing to be sent to you, enter a competition, promotion or survey, give us feedback, and when you report a problem with our Services. If you contact us, we will keep a record of that correspondence.  
  • Information we collect about you via automated technologies or interaction. Each time you visit or use our website and Services, we will automatically collect personal data including Technical Data about your equipment, browsing actions and patterns, and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details. We may also receive technical information about you, such as your IP address, login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Technical Data from the following parties:  
  • analytics providers, such as Google Analytics.  
  • advertising networks, search information providers.
  • social media service accounts if we give you the option to use these service accounts to sign-up for our web app.  
  • Contact, Financial and Transaction Data from providers of payment services.  

5. Who we share your personal information with 

We may share personal information the following categories of third parties as necessary:

  • Service providers who provide IT, system administration services and customer screening services.
  • Our payment processors, Stripe, to allow them to carry out and process your payments for the purchase of our products/services/content.  Please make sure to review Stripe’s the payment processor’s Privacy Policy to determine how they use, disclose and protect the relevant payment data. In making any purchase connected to the Bolsterup Platform, you agree to be bound by our payment processor privacy policies.  Stripe’s Privacy Policy.  
  • Third parties to whom we outsource certain support services such as, without limitation, document processing and translation services, photocopying and document review, confidential waste disposal, IT systems and/or software and/or storage providers, IT Support service providers, document and information storage providers.
  • Professional advisers including lawyers, bankers, auditors, insurers and other professionals who provide consultancy, banking, legal, insurance, corporate, administration and accounting services.
  • Government or governmental agencies, regulatory authorities, courts and law enforcement agencies, registries.  We may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted.
  • Appropriate parties in the event of emergencies.
  • Advertising networks: to support and display ads on our Services, and other social media tools.
  • Third party service providers to assist us with client insight analytics, such as Google Analytics.
  • Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

Please note the following:

  • This list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services as effectively as we can.
  • We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
  • 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. Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Services, or any other relevant services sites and to remember your preferences. This helps us to provide you with a good experience when you use the Services and also allows us to improve the Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

7. How long we keep your personal information 

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 longer if we are required to do so based on our regulatory, compliance, or professional indemnity obligations or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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. We may remove your personal information based on our retention policies in compliance with our security standards without further notice or liability.

We will retain relevant personal information for five (5) years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation, or for longer if we are required to do so according to our legal, regulatory and/or compliance obligations or professional indemnity obligations. We may then destroy such files without further notice or liability. 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. How we protect your personal information

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with the applicable data protection laws including the EU General Data Protection Regulation.  We have also implemented appropriate information security policies, rules and technical measures to secure your personal information collected by us. Your personal information is saved in an encrypted form.  

All of our partners, employees, consultants, workers and data processors (i.e., those who process your personal information on our behalf), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information, keep it secure and protect it.  

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

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

9. Which countries we transfer your personal information to

In order to provide our services we may need to transfer your personal information to locations outside Cyprus.  This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA.  For any transfer of data outside the EEA, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws and the EU General Data Protection Regulation.

10. Your rights regarding your personal information

You have the following rights in relation to the personal information we hold about you. Please note that some of these rights will only apply in certain circumstances and some of them may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of confidentiality obligations.

  • Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and certain other information about it;
  • Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
  • Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims;
  • Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
  • Transfer: you may ask us to help you request the transfer certain of your personal data to another party;
  • Objection: where we are processing your personal data based on legitimate interests (or those of a third party) and you may challenge this.  However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
  • Consent: where we are processing personal data with consent, you can withdraw your consent.

If you want to exercise any of these rights, please contact us at support@bolsterup.co.

Again, please note that you also have a right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus, where you are habitually resident, or where an alleged infringement of Data Protection law has taken place.  

11. Our Marketing Policy   

We will only process your personal data for marketing purposes once we have your consent. You have the right to object where we are processing your personal information for direct marketing purposes. This means you can opt-out from receiving direct marketing from us at any time.

You can opt-out of receiving direct marketing from us at any time.  You can do this by clicking on the "unsubscribe" link included at the end of any marketing email we send to you, or by contacting us at support@bolsterup.co.

You have the right to ask us not to continue to process your personal data for marketing purposes.

12. Links to third party websites or apps

Our Services, email updates and other communications may, from time to time, contain links to and from the websites or apps of others. The personal data that you provide through these websites or apps is not in any case subject to this Privacy Policy and the treatment of your personal data by such websites is not our responsibility. 

You should consult the third parties’ Privacy Policy notices which will set out how your information is collected and processed when visiting those websites or apps, as we have no control over information that is submitted to, or collected by, these third parties.

13. Children

We do not knowingly collect information from children or other persons who are under 16 years old without the consent and acceptance by any of their parent and/or guardian. If you are under 16 years old, you may not submit any personal data to us without the consent and acceptance by any of your parent and/or guardian.  

14. Changes to this Policy

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

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.

15. Contact us

Notwithstanding any other specific provision in this Privacy Policy, you can contact us at support@bolsterup.co to:  

  • See what data we have about you,  
  • Change or correct any data we have about you,  
  • Request us to delete any data we have about you,  
  • Opt-out of receiving promotional communication and content from us.

Ask questions, make inquiries, complaints, or claims, or provide feedback.

Website Privacy Policy

Bolsterup Contech Ltd (Bolsterup, We/Our/Ours/Us) 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.

In a nutshell, this Privacy Policy sets out:

  1. important information and who we are
  2. what personal information we collect about you
  3. how we use your personal information and basis for such use
  4. how we obtain your personal information
  5. who we share your personal information with 
  6. cookies
  7. how long we keep your personal information 
  8. how we protect your personal information
  9. which countries we transfer your personal information to
  10. your rights regarding your personal information
  11. our marketing policy
  12. links to third party websites
  13. children
  14. changes to this Policy

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Bolsterup 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. When you use the Bolsterup Platform at [www.] our relevant Privacy Policy will apply as well as other potentially applicable privacy policies of other involved parties.  

This website is not intended for children and we do not knowingly collect data relating to children.

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.  

Who we are

Bolsterup Contech Ltd, with registration number HE 434308 and registered office at Lord Byron 36, Office 204, 1096 Nicosia, Cyprus is the controller and responsible for your personal data. In some cases, we may process your personal data based on an agreement with a third party. In those cases, that third party is a data controller and we are a data processor. In those cases, the terms of that agreement may govern how we process your personal data.  

If you have any questions about this Policy or how we process your personal data or our privacy practices, please contact us:

Email: support@bolsterup.co

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, the Cyprus regulator for data protection issues. We would appreciate you coming to us with your complaint in the first instance to give us a chance to resolve it.  

2. What personal information we collect about you

We only collect the most relevant, proportionate for each purpose and strictly necessary personal information from you in the course of our business when you use our website. 

The personal information that we collect, and process includes:

  • Identity Data that includes first name, last name, username or similar identifier, date of birth and gender  
  • Contact Data that includes billing address, delivery address, email address, telephone numbers
  • Technical Data that includes internet protocol 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
  • Usage Data that includes information about how you use our website
  • Marketing and Communications Data that includes preferences in receiving marketing from us and our third parties and communication preferences

3. How we use your personal information and basis for such use

Purposes for which we will use your personal data

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

  • When we have your consent,  
  • 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.
3.1 To manage our relationship with you which will include notifying you about changes to our terms or privacy policy
  • Purpose / activity: To manage our relationship with you which will include notifying you about changes to our terms or privacy policy
  • Lawful basis for processing: (a) Consent, (b) Consent may be withdrawn at any time by writing to support@bolsterup.co. , (c) Necessary to comply with a legal obligation
3.2 To enable you to complete a survey
  • Lawful basis for processing: (a) Consent. Consent may be withdrawn at any time by writing to support@bolsterup.co,(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
3.3 To administer and protect our business and this website
  • Purpose / Activity: To administer and protect our business and this website (including website provision, improvement, auditing and monitoring, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Lawful basis for processing: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud), (b) Necessary to comply with a legal obligation
3.4 To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Lawful basis for processing: (a) Consent. Consent may be withdrawn at any time by writing to support@bolsterup.co.  (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
3.5 To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Lawful basis for processing: (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
3.6 To send our newsletter to you regarding news and updates of our website and business
  • Lawful basis for processing: (a) Consent. Consent may be withdrawn at any time by writing to support@bolsterup.co, (b) Necessary for our legitimate interests (to develop our products/services and grow our business)
3.7 To provide information requested by you
  • Lawful basis for processing: In case you request any information from us, you offer and thus consent to our receipt and use of your personal data.
3.8 To fulfil and/or comply with legal obligations, legal compliance, regulatory and risk management obligations, including establishing exercising or defending legal claims
  • Lawful basis for processing: (a) Necessary for our legitimate interests (to comply with our obligations, carry out legal and regulatory risk assessment and management, and exercise or defend potential legal claims or any legal means), (b) Necessary to comply with a legal obligation.

The firm shall not carry out any automated decision-making activities, including profiling, using your personal information.  

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

4. How we obtain your personal information

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

  • Direct interactions. You may give us your basic information including your name and surname, contact information including your email address, social media account, where appropriate, and likes, posts, tweets and other interaction with our social media presence, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:  
  • subscribe to our service or publications;  
  • request marketing to be sent to you;
  • enter a promotion or survey;
  • send complaints or requests; or
  • give us feedback or contact us.  
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data, and generally technical information and online data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive technical information about you, such as your IP address, login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
  • Third parties or publicly available sources.
  • We will receive personal data about you from various third parties and public sources as set out below:  
  • Technical Data from the following parties:
  • analytics providers such as Google analytics;  
  • advertising networks ; and
  • search information providers.

5. Who we share your personal information with 

We may share personal information the following categories of third parties as necessary:

  • Service providers who provide IT, system administration services and customer screening services.
  • Third parties to whom we outsource certain support services such as, without limitation, document processing and translation services, photocopying and document review, confidential waste disposal, IT systems and/or software and/or storage providers, IT Support service providers, document and information storage providers.
  • Professional advisers including lawyers, bankers, auditors, insurers and other professionals who provide consultancy, banking, legal, insurance, corporate, administration and accounting services.
  • Government or governmental agencies, regulatory authorities, courts and law enforcement agencies, registries.  We may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted.
  • Appropriate parties in the event of emergencies.
  • Advertising networks: to support and display ads on our website, apps and other social media tools.
  • Third party service providers to assist us with client insight analytics, such as Google Analytics.
  • Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

Please note the following:

  • This list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services as effectively as we can.
  • We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
  • 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. Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Services, or any other relevant services sites and to remember your preferences. This helps us to provide you with a good experience when you use the Services and also allows us to improve the Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

7. How long we keep your personal information 

For visitors of our website, we will retain relevant personal information for five (5) years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation, or for longer if we are required to do so according to our regulatory and/or compliance obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.

8. How we protect your personal information

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with the applicable data protection laws and the EU General Data Protection Regulation.  We have also implemented appropriate information security policies, rules and technical measures to secure your personal information collected by us. Your personal information is saved in an encrypted form.  

All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf,), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information, keep it secure and protect it.  

9. Which countries we transfer your personal information to

In order to provide our services we may need to transfer your personal information to locations outside Cyprus.  This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA.  For any transfer of data outside the EEA, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws and the EU General Data Protection Regulation.

10. Your rights regarding your personal information

You have the following rights in relation to the personal information we hold about you. Please note that some of these rights will only apply in certain circumstances and some of them may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of confidentiality obligations.

  • Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and certain other information about it;
  • Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
  • Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims;
  • Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
  • Transfer: you may us to help you request the transfer certain of your personal data to another party;
  • Objection: where we are processing your personal data based on legitimate interests (or those of a third party) and you may challenge this.  However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
  • Consent: where we are processing personal data with consent, you can withdraw your consent.

If you want to exercise any of these rights, please contact us at []. Again, please note that you also have a right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus, where you are habitually resident, or where an alleged infringement of Data Protection law has taken place.

11. Our marketing policy

We will only process your personal data for marketing purposes once we have your consent. You have the right to object where we are processing your personal information for direct marketing purposes. This means you can opt-out from receiving direct marketing from us at any time.  

You can opt-out of receiving direct marketing from us at any time.  You can do this by clicking on the "unsubscribe" link included at the end of any marketing email we send to you, or by contacting us at support@bolsterup.co.

You have the right to ask us not to continue to process your personal data for marketing purposes.

12. Links to third party websites

Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others. The personal data that you provide through these websites is not in any case subject to this Privacy Policy and the treatment of your personal data by such websites is not our responsibility. 

You should consult the other websites' Privacy Policy notices which will set out how your information is collected and processed when visiting those websites, as we have no control over information that is submitted to, or collected by, these third parties.

13. Children

We do not knowingly collect information from children or other persons who are under 16 years old. If you are under 16 years old, you may not submit any personal data to us. 

14. Changes to this Policy

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

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.