Background
This privacy policy applies between you, the User of this Website, and Tupel, the owner and provider of this Website. Tupel takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. This privacy policy should be read alongside, and in addition to, our Terms and Conditions and Cookies Policy.
In this privacy policy, "Tupel" refers to the brand name of the Website operated by Tupel Investments Limited, a company incorporated in the Republic of Cyprus. "Tupel Investments Limited" and "Tupel" may be used interchangeably to refer to the same entity.
Definitions and Interpretation
Data: collectively all information that you submit to Tupel via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the EU GDPR and the Processing of Personal Data (Protection of Individuals) Law of 2018 (Cyprus);
GDPR: the General Data Protection Regulation (EU) 2016/679;
Tupel Investments Limited, "we" or "us": Tupel Investments Limited, a company incorporated in the Republic of Cyprus, with registered number ΗΕ 464587 whose registered office is at 13 Agiou Prokopiou St., 2406 Egkomi, Nicosia, Republic of Cyprus.
UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you: any third party that accesses the Website and is not either (i) employed by Tupel and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Tupel and accessing the Website in connection with the provision of such services;
Website: the website that you are currently using, tupel.com, and any subdomains of this site unless expressly excluded by their own terms and conditions.
In this privacy policy, unless the context requires a different interpretation: the singular includes the plural and vice versa; references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy; a reference to a person includes firms, companies, government entities, trusts and partnerships; "including" is understood to mean "including without limitation"; reference to any statutory provision includes any modification or amendment of it; the headings and subheadings do not form part of this privacy policy.
Scope of This Privacy Policy
This privacy policy applies only to the actions of Tupel and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites. For purposes of the applicable Data Protection Laws, including Cypriot and EU legislation, Tupel is the "data controller", responsible for determining the lawful basis for processing and ensuring compliance with data protection laws. This means that Tupel determines the purposes for which, and the manner in which, your Data is processed.
Data Collected
We may collect the following Data, which includes personal Data, from you: name; date of birth; job title; profession; contact information such as postal address, email address, and telephone number; device type; financial information such as credit or debit card numbers or bank account information; IP address (automatically collected); web browser type and version (automatically collected); operating system (automatically collected); in each case, in accordance with this privacy policy.
How We Collect Data
We collect Data in the following ways: Data you provide to us and Data collected automatically.
Data That Is Given to Us
Tupel will collect your Data in a number of ways, for example: when you contact us through the Website, by telephone, post, email or through any other means; when you register with us and set up an account to receive our products/services; when you use our services; in each case, in accordance with this privacy policy.
Data That Is Collected Automatically
To the extent that you access the Website, we will collect your Data automatically, for example: we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content. We will collect your Data automatically via cookies, in line with the cookie settings on your browser and in compliance with Cypriot and EU data protection laws. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
Our Use of Data
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons: internal record keeping; improving our services; monitoring security and usage; marketing purposes; conducting surveys; research and analysis; in each case, in accordance with this privacy policy. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your Rights" below). When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Who We Share Data With
We may share your Data with any of our group companies or their affiliates, in accordance with this privacy policy and Cypriot data protection laws.
Keeping Data Secure
We will use technical and organisational measures to safeguard your Data, for example: access to your account is controlled by a password and a username that is unique to you, we store your Data on secure servers, payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both)) in your browser when we use this technology. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: hello@tupel.com.
Data Retention
Unless a longer retention period is required or permitted by law or necessary for legitimate business, contractual, or legal obligations, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your Rights
You have the following rights in relation to your Data. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive". Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete. Right to erase - the right to request that we delete or remove your Data from our systems. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it. Right to data portability - the right to request that we move, copy or transfer your Data. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: hello@tupel.com.
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For Cyprus, this is the Office of the Commissioner for Personal Data Protection. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to Other Websites
This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. Please be aware that following links to third-party sites may result in data collection governed by those sites' privacy policies. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
Changes of Business Ownership and Control
Tupel may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Tupel. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us. We may also disclose Data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Cookies
This Website may place and access certain Cookies on your computer. Tupel uses Cookies to improve your experience of using the Website and to improve our range of services. Tupel has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times. All Cookies used by this Website are used in accordance with current EU and Cyprus Cookie Laws and in compliance with the EU ePrivacy Directive. By using the Website, you agree to our placement of cookies. You can also choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer. If you choose to disable Cookies, some features of the Website may not function optimally, which may affect your user experience.
General
You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected. If any court or competent authority finds any provision (or part-provision) of this privacy policy to be invalid, illegal, or unenforceable, that part will be deemed deleted to the extent required, without affecting the remaining provisions. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy. This Privacy Policy will be governed by and interpreted according to the law of the Republic of Cyprus. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Cypriot courts.
Changes to This Privacy Policy
Tupel reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website, and we will endeavor to notify you of significant changes where applicable on the Website. You are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Tupel by email at hello@tupel.com.