This Privacy Policy applies to the use of and describes how we collect, use, process, and disclose your information, including Personal Data, in conjunction with your access to and use of our website (https://www.fromsoda.com) (the “Website”) and/or any of our social media platforms from time to time (together with the Website, the “Platforms”).  

This Privacy Policy together with our Terms of Use (and any other documents referred to it) sets out the basis by which the Company, including, but not limited to, the Platforms, processes personal information that we collect from you or you provide to us directly, which may be considered to be Personal Data (as defined below).

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it before using our Platforms.

By using or visiting any part of our Platforms, you confirm that you have read, understood and accepted the Terms and Conditions of this Privacy Policy. Moreover, you agree that this Privacy Policy, including any amendments thereof will govern how we collect, store, use, share and in any other form process your Personal Data and your rights during our relationship and after its termination.

If you do not agree to accept and be bound by this Privacy Policy or any amendment thereto, then please discontinue the use of the Platforms.

The Company is the Data Controller (as defined under GDPR) and responsible for your Personal Data covered by this Privacy Policy.

Definitions

For the purposes of this Privacy Policy:

“Affiliate” means (a) in relation to a body corporate, any subsidiary undertaking or parent undertaking of that body corporate, and any subsidiary undertaking of any such parent undertaking for the time being; (b) any person directly or indirectly controlling, controlled by or under common control with any person or any of the foregoing persons; and (c) any person who acts in the capacity of agent, trustee, partner, attorney, nominee of, or otherwise has agreed to account (whether for money or otherwise) to, that person.

“Account” means a unique account created for you to access the services of our Platform.

“Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy) refers to Crafted Compass Ltd, a limited liability company incorporated under the laws of the Republic of Cyprus with registration number ΗΕ 469941 and registered office address Kypranoros 13, EVI BUILDING, 2nd floor, office 201, 1061, Nicosia, Cyprus.

“Cookie” means a small text file in the browser of your computer, as further defined in the Directive 2002/58/EC of the European Parliament and of the Council, as amended (the “Cookie Law”).

“IP address” means the Internet Protocol, a numerical label assigned to a device connected to a computer network that uses the Internet Protocol for communication.

“Personal Data” means any information that relates to an identified or identifiable individual as further defined in the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

“Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services provided by the Company on behalf of the Company, to perform services related to the Services or to assist the Company in analysing how the service is used.

“Service” (referred to as either “Service” or collectively our “Services”) means the services provided by the Company.

“You” (referred to as either “You” or the “User”) means the individual accessing or using the Platforms.

1. Amendment or Changes to the Policy

We reserve the right to amend or change this Privacy Policy at any time. Any such change shall be binding and effective immediately upon posting of the changes or our Website or otherwise notifying the users via any contact information available to the Company. It is your responsibility to regularly check the Website for any changes. If you oppose to the amendment of the Privacy Policy, you must stop using the Platforms immediately. Your continued use of any of the Platforms after any modifications constitutes your acceptance of the new Privacy Policy.

2. What Personal Data do we collect and process?

We collect and process the information (a) you may provide to us directly (b) that we may collect in the course of our business or in the course of our business with any third parties and (c) that we may collect from you through your use of our Platforms or when you subscribe with us. Depending on the circumstances, this information may include, but is not limited to:

1. Name and Surname;
2. Gender;
3. Date of birth;
4. Address;
5. Email address;
6. Phone number;
7. Payment information;
8. IP address;
9. Company name;
10. Business address;
11. Technical information including inter alia any user specific request, design preferences and project files;
12. The information you provide to us when you contact us through the “Contact Us” form; and
13. Any other information relating to you and your request(s) which you may provide to us or that we may collect.

3. Cookies and Tracking Technologies

Like most websites, our Website may place a “cookie” in the browser of your computer, assigning you a unique number to improve your experience while you navigate through the Website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the Website.

We also use third-party cookies that help us analyse and understand how you use this Website. These cookies will be stored in your browser only with your consent. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use effectively some portions of our Service.

4. Why do we collect and process Personal Data?

We use and process the information we collect from you:

1. To administer and manage your Account;
2. To provide, manage, and maintain our Services, ensuring that we can fulfil any of your requests efficiently;
3. To perform our obligations in accordance with any contract that we may have entered with you (or the entity you represent);
4. To process payments, manage orders and subscription(s), and ensure the smooth handling of your requests;
5. To communicate with you regarding your inquiries, orders, and updates related to our Services. This may include sending notifications, confirmations, and other relevant information;
6. To provide customer support and respond to your questions or concerns about our Services;
7. To comply with applicable laws, regulations;
8. To carry out certain profiling of you and your activity on the Website in order to personalise, measure, and improve the services we provide, enhance user experience, and develop new features based on user feedback and behaviour and/or for business administration purposes; and/or to protect or enforce our interests and rights. You can always opt out of receiving notifications from us by unsubscribing from any newsletters and any other marketing communications that you may have previously consented to; and
9. To protect our users and the integrity of the Company by monitoring fraudulent activities and ensuring data security.

By processing your Personal Data and any other information, we aim to provide a seamless and efficient experience while ensuring compliance with applicable laws and regulations.

5. Storage of your Personal Data

Once your Personal Data is collected, it is stored in a secure and updated system of cloud storage which allows for the supply of details of the data held.

The data is processed in a manner that ensures the appropriate security of Personal Data, including, without limitation, protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

We maintain a strict policy regarding confidentiality and security, and we require all our staff, advisors, Affiliates, third-party Service Providers and any other data processors to do the same.

6. Personal Data Retention

We retain the data we collect from you for so long as necessary to fulfil the purposes for which it was collected, as listed above. Accordingly, your Personal Data will be retained in accordance with the appropriate retention period for each category of data and in strict compliance with applicable law, including but not limited to, GDPR.

Those periods are based on the requirements of GDPR and applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and the Company’s business purposes. We may retain your Personal Data for a longer period if required by law or to comply with applicable legal obligations, such as tax or accounting requirements. Accordingly, if you have entered into a contract with us, we will retain your Personal Data as long as necessary to fulfil the terms of that contract.

In some cases, we may retain your Personal Data in an aggregated or anonymized form, which no longer identifies you, for analytical purposes and to improve our Service.

Once your Personal Data is no longer needed for the purposes for which it was collected, we will securely delete or anonymize it in accordance with applicable laws and regulations.

7. Disclosure of information

We shall not disclose or communicate or share your Personal Data to any third party unless we have your prior consent. Having said that, we reserve the right to disclose, communicate and share your Personal Data in the following instances:

1. To courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against us, (iii) to respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our Users to legal liability.
2. To our Affiliates and/or third-party Service Providers who help us provide services related to the Website, who may be located inside or outside of the European Economic Area (“EEA”). These Service Providers are contractually bound to protect and to use the Personal Data on our behalf only for the purposes for which it was disclosed and consistent with this Privacy Policy.  You can always contact us to receive the full list of our third-party Service Providers which process your data.
3. To the internal staff/recruitment team of the Company involved in the hiring process.
4. Aggregated information and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
5. For the purpose you have provided it.
6. In case we have an indication or believe that your use of the Platforms has violated or may potentially violate any law and/or regulation, or our Terms of Use, or any terms of Service and any other agreement between ourselves and yourself.
7. In the event that we sell or transfer all, or any portion of, our business or assets (including in the event of any reorganization, dissolution, spin-off, or liquidation) we reserve the right to transfer your Personal Data to the relevant acquirer, successor, purchaser or beneficiary, or any appropriate combination of them.
8. We may share Personal Data for a purpose to which you provide your prior express consent. Save as described above, we refrain from disclosing any information about your visits to the Website or other information which identifies you to any third parties unless we have your prior express consent.

8. User Rights

We want to be fully transparent and clear about the way in which we handle your Personal Data.

Accordingly, please note that you have the following rights under applicable laws and regulations:

1. access: you are entitled to request details of the Personal Data we hold about you and how we process it. If we do not hold and process any Personal Data relating to you, we will simply confirm to you that we do not.
2. rectification: you are entitled to obtain from us without undue delay the rectification of inaccurate or incomplete Personal Data we hold on to you. If you are entitled to rectification and if we have shared your Personal Data with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your Personal Data with so that you can contact them directly.
3. erasure: you are entitled to request the erasure of your Personal Data, and we will be obliged to do so without undue delay. However, we will not be required to satisfy your foregoing request where if, inter alia, processing of your Personal Data is required for our compliance with a legal obligation that we are subject to and/or for the establishment, exercise or defence of legal claims.
4. data portability: you entitled to ask us to provide your Personal Data in a structured, commonly used and machine-readable format and to transmit, where technically feasible, such information to another controller without hindrance, where (i) processing is based on your consent or on the performance of a contract with you; and (ii) such processing is carried out by automated means.
5. restriction of processing: you are entitled to ask us to restrict the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or you object to us. If you are entitled to restriction and if we have shared your Personal Data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal Data with so that you can contact them directly.
6. objection: if you believe your fundamental rights and freedoms outweigh our legitimate interests, you are entitled to object to any processing of your Personal Data which has our legitimate interests as its legal basis. Once you objected, we will have the opportunity to demonstrate that we have compelling legitimate interests to continue processing your Personal Data which override your rights and freedoms.
7. withdraw consent: If we rely on your consent to process your Personal Data, you are entitled to withdraw such consent at any time. However, you should be aware that if you choose to do so there may be potential consequences which we will tell you about at that time.
8. right to complaint: you are entitled to lodge a complaint with the local supervisory authority, which is the Office of the Data Protection Commissioner in case you are not satisfied with the manner we process your Personal Data.

We would like to note that certain of the above rights may, depending on the circumstances, be limited where we have an overriding interest or legal obligation to continue to process your Personal Data.

If you want to exercise any of your rights listed above, please visit our Website or email us at hello[at]fromsoda.com. You can also contact us by post at Kypranoros 13, EVI BUILDING, 2nd floor, Office 201, 1061, Nicosia, Cyprus. For your protection and the protection of all our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.

9. International Data Transfer

To facilitate our operations, we may transfer, store, process or share your information with Service Providers based outside Europe for the purposes described in this Privacy Policy. If we transfer your Personal Data outside of the EEA, within the group or to our business partners, we will take all reasonable steps to ensure that adequate measures are in place to keep your Personal Data as secure as it is within the EEA and in accordance with this Privacy Policy, by relying on the use of standard contractual clauses or binding corporate rules or any other acceptable method that ensures protection of your data to the standard required within the EEA.

10. Personal Data Security

Unfortunately, no data transmission can be entirely secured and guaranteed. Still, we make every effort to safeguard your Personal Data and privacy in general. Notwithstanding any measures we take to protect your Personal Data, we cannot guarantee that: (i) such security measures will prevent our computers from being accessed illegally, and (ii) the Personal Data on them being stolen, misused or altered.

You always remain solely responsible for the security of your computer, and we shall not have any responsibility whatsoever for destruction or inappropriate disclosure of your Personal Data. For your own protection, you are strongly encouraged to: (i) virus-check software when using our Platforms: (ii) avoid posting or providing to us via the Platforms, any document which you believe may contain a virus; and (i) virus check any document which you intend to post or provide to us via the Platforms.

We have put adequate procedures in place to be followed in the event that any Personal Data is destroyed, lost, altered or if there is unauthorised disclosure of (or access to) Personal Data as a result of a breach of security. Data breaches or leaks which may pose a risk to individuals will be notified to the Office of the Data Protection Commissioner within seventy-two (72) hours. A breach which is likely to result in a high risk to the rights and freedoms of individuals will also trigger an obligation to notify the holders of the Personal Data, in which case we shall inform you of such breach directly as soon as possible.

11. Third-Party Links

The Platforms may include links to other internet websites. Such websites are beyond the control of the Company, and we assume no responsibility for the content and privacy practices of any such websites. You acknowledge and agree that your linking to other websites, use of such websites, and use of any information, material, products and services offered and/or provided by such websites, is solely and exclusively at your own risk. Consequently, the information practices of third-party websites are not covered by this Privacy Policy.

12. Children’s Privacy

We only address adult persons with our online offer and we do not collect or retain any Personal Data relating to minors.

13. Copyright notice

Unless otherwise stated, the Company and/or its licensors own the intellectual property rights for all material on the Platforms. All intellectual property rights are reserved. You may view and/or print pages from the Platforms for your own personal use subject to restrictions set in these terms and conditions.

You are prohibited to:

1. Republish material from the Platforms;
2. Sell, rent or sub-license material from the Platforms;
3. Reproduce, duplicate or copy material from the Platforms; and
4. Redistribute content from the Platforms, unless content is specifically made for redistribution.

All trademarks, service marks, logos, trade names used and displayed on this Website are the property of the Company or other respective owners that have granted the Company the right and license to use such marks.

14. Contact Information

If you have questions about this Privacy Policy or our information handling practices, you can contact us by emailing us at hello[at]fromsoda.com or online through our Platforms by submitting the contact us request.

You can contact us by post at the following address:

Kypranoros 13, EVI BUILDING,

2nd floor, Office 201,

1061, Nicosia, Cyprus