General Information
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PRIVACY POLICIES
Who we are
Elite Blue Limited is a trade name and a division of Fameline Holding Group directed to the shipping with headquarters in Limassol Cyprus and operating under the registration number HE428679. We developed throughout the years’ long standing relations with our customers, suppliers, employees and collaborators, who have been of utmost importance to us by helping our Elite Blue Limited to build a successful presence in our territory. We do not knowingly attempt to solicit or receive information from children nor personal details and sensitive data of individuals that are not related to commercial matters.
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes Elite Blue Limited policies and practices regarding the collection and use of your personal data and clarifies your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies. Our Privacy Policy uses terms which are defined and have the same meaning as in the EU General Data Protection Regulation 2016/679/EU (GDPR).
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).
Data subject rights
The European Union’s General Data Protection Regulation provide certain rights for data subjects. This Privacy Policy is intended to provide you with general information about what personal data the Elite Blue Limited collects about you and how it is used. If you have any questions, please contact us at gdpr@fameline.com.cy
You may also request information about the purpose of the processing; the categories of personal data concerned; who else outside the Elite Blue Limited might have received the data from the Elite Blue Limited; what was the source of the information (if you didn’t provide it directly to the Elite Blue Limited); and how long it will be stored.
You have a right to: (i) access and confirm your information, (ii) you have the right to correct (rectify) the record of your personal data maintained by the Elite Blue Limited if it is inaccurate or not up to date, (iii) You may request that the Elite Blue Limited erase your data (right to be forgotten) however this right may be subject to certain exceptions according applicable laws; (iv) you can also ask us to stop processing (using) your data (right to withdraw consent) if you do not agree with our collecting/processing mechanisms or (v) you may also request that the Elite Blue Limited cease using your data for direct marketing purposes (right to restrict use of data); (vi)at your written request— we shall provide your personal data to you or transmit it directly to another controller (portability); and (vii) you have the right to object to our use of your personal data in certain circumstances (the right to object) and (viii) whenever you find necessary you have the right to lodge a complaint with the appropriate data protection authority (DPA) if you have concerns about how the Elite Blue Limited processes your personal data.
In Cyprus, the Supervisory Authority for personal data protection is the Office of the Commissioner for Personal Data Protection. You can contact the Commissioner's Office at:
Iasonos str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
Practical access to your personal data will be provided at no cost to you upon request made to the Elite Blue Limited at gdpr@fameline.com.cy, unless excessive requests are made in which case the Elite Blue Limited may at its discretion charge a reasonable administrative fee. If the request made by you cannot be provided within the legal time frame, the Elite Blue Limited will promptly provide you with a date when the information will be delivered. If for some reason access is denied, the Elite Blue Limited will without delay provide an explanation as to why access has been denied e.g. technical contingencies, non-availability of the GDPR designated person, etc.
How to exercise your rights
You can exercise your rights at any time by contacting our GDPR Designated Person see detail below. In order to process your request effectively, efficiently and securely, please include in your email: (i) A clear statement on which rights you are seeking to enforce; (ii) Full description of the information or type of information that you are writing about; and (iii) Details which will confirm your identity, such as a scan of your passport or ID card sent to us marked as Confidential, this ID confirmation will be encrypted together with your request and subject to the retention period described herein.
GDPR Designated Person
Elite Blue Limited appointed a designated person to be contact if you have any questions or concerns about the Elite Blue Limited personal data policies or practices. The Elite Blue Limited GDPR designated person is:
Constantinos Ellinas
Legal Director
1-3 Spatharikou Street
4004 Mesa Geitonia Limassol, Cyprus
gdpr@fameline.com.cy
+357 25889999
Why and how we collect and process (use) your personal data
We may collect your data electronically, visually or in hard copies depending on how we are interacting with you at the time of collection, however we do not sell personal information to anyone and only share it if/when necessary to the development of the business as mentioned below:
If you are our business collaborator: To ensure that we meet certain legal requirements such as KYC (know your customer) and AML (anti-money-laundering), we need to have certain details of our customers or details of individual contacts at customer’s organisation (such as their names, telephone numbers and e-mail addresses, the same type of information is collected from suppliers and website users; apart of the legal requirements, the information is also used to provide our suppliers, customers and website users with products and services, including the promotion of products, to facilitate contact between suppliers and customers, newsletter, direct mail offering the products and services of our companies and our principals (in case you opt to receive it), as well as informing about our events and business activities.
If you are our employee: The Elite Blue Limited only collect details required as part of your application process or employment. We may collect information such as your name, age, contact details, education details, employment history, emergency contacts, next of kin, immigration status, passport details (for traveling use only), bank account details, utility bills and other relevant information required by local laws for the purposes of your employment. Where appropriate, and in the limits accepted by local laws, we may also collect information of a more sensitive nature related to your health as part of our “Health & Safety at Work” measures. To enable employees to conduct our business, the Elite Blue Limited provides access to one another’s commercial contact information including name, position, telephone number, work address, work e-mail address, and photograph (in case you chose to provide one).
CCTV: When entering our premises, we collect the necessary personal data required for security and notification purposes. For security purposes, we also operate a Closed-Circuit Television system (CCTV). The CCTV cameras only operate in common areas of our premises and are positioned so as not to intrude on privacy. The footage is kept for no longer than a month and access is strictly regulated.
Live events
The Elite Blue Limited hosts many events throughout the year. These include in-person conferences. If you register for one of our events and you are a customer or supplier, we will access the information you provided to offer you with information and services associated with the event. If you are not yet a customer or supplier and you register for one of our events, we will collect your name and contact information (if you consented), which we will store in our secured database and use to provide you with information and services associated with the event and to inform you about upcoming events of our Elite Blue Limited.
If you are a presenter, panellist, exhibitor or a like at one of our events, we will collect information about you including your name, employer and contact information, and photograph. We may also make and store a recording of your voice and may in certain cases use it e.g. to include into our website, provided we have previously informed you and obtained your consent.You may require at any time to have the recordings, removed from the website by simply e-mailing our GDPR designated person at gdpr@fameline.com.cy
If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for events or you may contact the Elite Blue Limited directly at gdpr@fameline.com.cy. The Elite Blue Limited does not share your data with sponsors/co-sponsors and exhibitors.
In all our events be it private involving our staff, or open involving our guests, presenters, customers, principals, etc, we INFORM that we shall take photos and may film it, the images will be used only to illustrate and promote our events in our website, social medial and publications, if you do not want to have your picture/film taken you will be provided at entrance with a “sticker” informing to NOT PHOTOGRAPH you. Our media professionals will be instructed on the process.
Publications
The Elite Blue Limited also subscribes to news feeds and blogs produced by third parties which we often link from our website. This means you may find yourself on the Elite Blue Limited website or reading an email from the Elite Blue Limited publications team and we will offer you a link to another organization’s website. At these times please be aware you will be leaving the Elite Blue Limited website and the Elite Blue Limited is not responsible or liable for any content provided by these third-party websites or for the personal information they may happen to gather from you. We suggest you to always refer to the Terms of Use of such third parties before providing any information.
To receive the Elite Blue Limited newsletters by email, if you are still not in our mailing list, you will need to create a “profile” with us which involves providing the Elite Blue Limited with at least your first name and last name, an email address, and the country in which you live. The Elite Blue Limited does not share this information with any third party other than to store the information in our secured databases.
You may manage your profile by subscribing or unsubscribing at any time. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe. If you have any difficulties managing your email or other communication preferences with the Elite Blue Limited, please contact us at gdpr@fameline.com.cy
The Elite Blue Limited uses Google Analytics to track how often people gain access to or read our content. We use this information in the aggregate to understand what content our public find useful or interesting, so we can produce the most valuable content to meet your needs. For more information, please see our Terms of Use.
Your correspondence with the Elite Blue Limited
If you correspond with us by email, postal service, or other form of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry; to notify you of Elite Blue Limited conferences, publications, or other services; or to keep a record of your complaint, accommodation request, and the like. As always, if you wish to have the Elite Blue Limited to “erase” your personal information or otherwise refrain from communicating with you, please contact us at gdpr@fameline.com.cy
Note: if you ask the Elite Blue Limited not to contact you by email at a certain email address, the Elite Blue Limited will permanently delete that address from its mailing list in order to comply with your no-contact request.
Legal basis for processing your data
Our purposes and legal basis for processing your personal data may vary depending on our relationship with you, however we will never process your personal data, if our interests are suppressing your interests or fundamental rights. As explained above, In order to conduct business and fulfil our legal, regulatory, and contractual obligations, we need to perform legitimate and fundamental processing activities related to: (i) Establishing/maintaining commercial and employment contracts and the provisions of the contractual obligations, including contract review; (ii) invoicing, remittance and collection; (iii) non-promotional communication; (iv) Responding to enquiries, requests, and complaints (v) performance measurement related to the business; (vi) Business Continuity and Contingency Planning; (vii) Legal and regulatory obligations; (viii) Employment processing; (ix) Workforce planning (x)Training and certifications; (xi) Emergency communications; (xii) Interacting with other organisations, industry groups, and professional associations; (xiii) Internal ethics reporting and security.
The Elite Blue Limited also processes your data to provide you with news, products or services from our Elite Blue Limited that you have shown interest and consented to receive from us and in case of job seekers to have them on our database to be able to offer a job position when we may have availability (for more detail see job seekers). We use this information solely to refine our communication and relation with you and to better tailor our efforts to meet your needs and to communicate with you about news, products or services that the Elite Blue Limited offers that may assist you in your professional duties. It is of essence for our business to have an open communication channel with our collaborators.
Personal information we may receive from third parties
From time to time, the Elite Blue Limited may receive personal information about individuals from third parties. This may happen if your employer signs you up for our events, visits etc. Our third-party partners may also share your personal information with the Elite Blue Limited such events, news, visits etc. But this information shall not be disclosed or distributed to persons not committed with the Elite Blue Limited.
What happens if you don’t give us your data
You can consult our website without giving us your personal data. The information on our website is available for those who did not provide personal information. You can even enter only the minimal amount of information (name and contact information) to your “profile” if you wish, and you can edit your profile at any time. Some personal information is necessary so that the Elite Blue Limited can supply you with the products and/or services you have purchased or requested, and to authenticate you, so that we know it is you and not someone else making requests on your behalf. You may manage your Elite Blue Limited subscriptions and you may opt-out of receiving marketing or other sort of communication at any time by simply sending a message to the GDPR.
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 or we may not be able to perform the services as agreed. In case you fail to provide the required data, we may have to terminate that contract with you as a result, but we will notify you if this is the case at the time.
Job Seekers
At Elite Blue Limited, we are committed to taking every appropriate action to ensure the protection and responsible use of personal information shared by all candidates completing our online recruitment procedure applying for employment within our Company.
In accordance with the new EU General Data Protection Regulation (GDPR) we hereby inform you that your personal data submitted online through our website will be under the control of Elite Blue Limited, as the Controller of Processing. Elite Blue Limited holds the role of the System Administrator, and the recipients of your personal data will be the authorised people in the Human Resource department responsible for the processing and assessment of your application.
The purpose of the processing of your personal data is:
- to process, review, administer and assess your application for employment;
- to contact you during your candidacy for requesting additional information when needed, sending you emails and keeping you updated on the progress of your application;
- to assess your suitability for other current and future roles within the Company (for the period of 6 to 12 months that your application is kept in our system as per our retention policy)
Retention policy: Upon submitting your application, we will retain your personal information, application through our website for a period of 6 to 12 months, upon which we will securely dispose of all your personal information. If you do not agree to keep your application in our system, upon your request, your personal data will be deleted within [30] working days from the date we complete our in-house recruitment procedures for the specific vacancy applied.
If you wish to get in touch with us, please contact our data protection manager at c.ellinas@fameline.com.cy.
Use of Elite Blue Limited website
The Elite Blue Limited website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of the Elite Blue Limited website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyse trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. The Elite Blue Limited website also uses cookies and web beacons. It does not track users when they cross to third party websites, does not provide targeted advertising to them, and therefore does not respond to Do Not Track (DNT) signals.
Use of Cookies and web beacons
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purposes of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using the Elite Blue Limited website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
When and how we share information with others
The personal information the Elite Blue Limited collects from you is stored in one or more databases or clouds hosted by third parties located in the European Union or other countries where these service providers operate. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.
We do not reveal your personal data to third-parties for their independent use unless: (i) you request or authorize it; (ii) the information is provided to comply with applicable laws (for example, to comply with a search warrant, subpoena or court order, KYC, anti-money laundry regulations or tax and employment duties), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (iii) the information is provided to our agents, vendors, service providers, companies of the Elite Blue Limited, that perform functions on our behalf; (iv) to address emergencies or acts of God; or (v) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our customers, suppliers and website users and disclose the results of such aggregated (but NOT PERSONALLY IDENTIFIABLE) information to our partners, service providers, principals, advertisers and/or other third parties for marketing or promotional purposes.
The Elite Blue Limited website may direct you to social media pages as Facebook, LinkedIn, Twitter and others. If you choose to "like" or “share” information from the Elite Blue Limited website through these services, you should review the privacy policy of that service. Please note, if you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data.
Transferring personal data from the EU to other countries
The Elite Blue Limited would transfer your personal data outside the EU only if: (i) you gave your consent; (ii) necessary to perform a contract with you; or (iii) necessary to fulfil a compelling legitimate interest of the Elite Blue Limited in a manner that does not outweigh your rights and freedoms. The Elite Blue Limited endeavours to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with the Elite Blue Limited and the practices described in this Privacy Policy.
To comply with applicable data protection law, we will implement international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for Personal Data that may be transferred to countries outside the EEA where an adequate level of protection is not already guaranteed.
Security of your personal data
To help protect the privacy of data and personally identifiable information you transmit through use of this website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data only to those employees or third parties (processors, government, banks, auditors, etc) who need to know that information in order to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities, and we conduct internal audits to check our methods and procedures. The Elite Blue Limited also lessens the risk to your rights and freedoms by minimizing to the strictly necessary the collection and storage of sensitive information about you.
Data storage and retention
Your personal data is stored by the Elite Blue Limited on its servers, and on the servers of the cloud-based database management services the Elite Blue Limited engages, located in the European Union or any other place these service providers operate. The Elite Blue Limited retains data for the duration of the employees’, customers’, suppliers’, visitors’ business relationship with the Elite Blue Limited and in some cases the retention period will be subject to applicable laws and regulations. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for or to comply with legal requirements. For Job Seekers please see related section. For more information on where and how long your personal data is stored, as well as on your rights of erasure and portability, please contact the Elite Blue Limited GDPR designated person at gdpr@fameline.com.cy
Changes and updates to the Privacy Policy
This Privacy Policy and our Terms of Use is expected to change during the conduction of our business. We reserve the right to amend the Privacy Policy and Terms of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy and Terms of Use at this website. We may e-mail periodic reminders of our notices and terms and conditions but you should check our website frequently to see the current Privacy Policy and Terms of Use that is in effect and any changes that may have been made to it.
Your agreement with this Privacy Policy
By using this website, you agree to the terms and conditions contained in this Privacy Policy and Terms of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this website or any Elite Blue Limited benefits or services. You agree that any dispute over privacy or the terms contained in this Privacy Policy and Terms of Use, or any other agreement we have with you, will be governed by the laws of Cyprus. You also agree to arbitrate such disputes in Limassol, Cyprus where the Elite Blue Limited holds its headquarters and to abide by any limitation on damages contained in any agreement we may have with you.
Questions, concerns, requests or complaints
Please contact the Elite Blue Limited GDPR designated person at addresses provided above.