Privacy policy.

1 Who we are

The Services are provided by the company below, which you can reach at any of these addresses.

2 Personal data we collect

The personal data we may collect and process falls into three groups.

What you give us directly

• your full name;
• your email address;
• your phone number;
• details of your company or organisation;
• billing or payment details;
• messages and enquiries you send us;
• any documents or other materials you choose to send us via the Services.

Technical and usage data

• your IP address;
• the type and version of your browser;
• your operating system;
• identifiers belonging to your device;
• data on how you interact with the website;
• the pages you visit;
• details of your session;
• the URLs that referred you to us;
• data gathered through cookies and analytics.

Data we receive from third parties

We may obtain information about you from:

• providers of analytics services;
• companies that process payments;
• services that handle authentication;
• sources open to the public;
• our business partners;
• specialists in fraud prevention and security.

3 Why we use personal data

Our reasons for using personal data are legitimate operational and business ones. They include:

• delivering the Services and keeping them running;
• answering your questions and support requests;
• staying in touch with the people who use the Services;
• making the website work better and more pleasant to use;
• keeping watch over security and stopping fraud or abuse;
• meeting our legal and regulatory obligations;
• handling transactions and payments;
• keeping internal records and running day-to-day administration;
• enforcing the Terms of Use and our legal rights.

Where the law allows it, we may also draw on personal data for:

• optimising performance and running analytics;
• developing and testing our services;
• sending marketing and promotional messages.

4 Legal bases for processing

Under the GDPR and the European data protection laws that apply, each processing activity we carry out rests on at least one of these legal grounds:

• consent you have given us;
• the need to perform a contract;
• our duty to comply with legal obligations;
• the legitimate interests of A.B. GOVERLA LTD;
• guarding against fraud, abuse and threats to security.

Where we rely on your consent, you can withdraw it whenever you wish. Withdrawing it does not make any processing carried out beforehand unlawful.

5 Who we share personal data with

We do not sell anyone’s personal data.

We may pass personal data to trusted third parties when that is reasonably needed for legal, business, security or operational reasons. The recipients can include:

• providers of hosting and infrastructure;
• analytics services;
• payment processors;
• providers of communication tools and customer support;
• our lawyers, accountants and other professional advisers;
• fraud-prevention and cybersecurity specialists;
• regulators, courts, law-enforcement authorities or government bodies, where legally required.

We expect every third-party service provider to keep appropriate confidentiality and security safeguards in place.

6 International transfers

Personal data about you may be processed in, or transferred to, countries beyond the European Economic Area (the “EEA”). When such a transfer takes place, we put appropriate safeguards in place as the GDPR requires. They include:

• adequacy decisions that the European Commission has adopted;
• Standard Contractual Clauses (SCCs);
• further contractual, technical and organisational safeguards.

7 How long we keep data

We hold on to personal data no longer than is reasonably needed to:

• deliver the Services;
• meet our legal obligations;
• settle disputes;
• enforce our agreements;
• keep legitimate business records;
• safeguard security and prevent fraud.

How long we keep it can differ according to:

• what kind of information it is;
• the requirements set by law and regulation;
• what our operations require.

Once we no longer need personal data, we securely delete it, anonymise it or otherwise dispose of it.

8 Security

We use appropriate technical and organisational measures intended to shield personal data from:

• unauthorised access;
• accidental loss;
• destruction;
• alteration;
• disclosure;
• misuse.

The measures we rely on may include:

• encryption of data;
• infrastructure built to be secure;
• controls on who can access what;
• systems that monitor activity;
• internal procedures that protect confidentiality.

That said, no system that runs over the internet, and no way of transmitting data across it, can be guaranteed as completely secure.

9 Cookies and similar technologies

We rely on cookies and comparable technologies to:

• run the Services and keep them secure;
• remember your preferences;
• analyse how the Services are used;
• improve how well the Services function and perform.

Our Cookie Policy explains in more detail how we use cookies.

10 Your rights

Depending on the law that applies, you may hold these rights over your personal data:

• the right to access it;
• the right to have it rectified;
• the right to have it erased (often called the “right to be forgotten”);
• the right to restrict how it is processed;
• the right to object to its processing;
• the right to data portability;
• the right to withdraw your consent;
• the right to complain to a supervisory authority.

To exercise any of these rights, write to us at privacy@elisiotraffic.com. Before acting on certain requests, we may ask you to verify your identity.

11 Marketing communications

Where applicable law allows, we may send you informational, service-related or marketing messages. You can stop receiving marketing messages whenever you like by:

• following the unsubscribe instructions;
• changing your account preferences, where that option exists;
• getting in touch with us directly.

Even after you opt out, we may still send operational messages, or messages the law requires, where they are necessary.

12 Third-party websites

The Services may include links to websites or services run by third parties. We are not responsible for:

• how those third parties handle privacy;
• the content of external websites;
• the security measures third parties use.

You should read the relevant policies of any external service for yourself.

13 Children’s privacy

The Services are not meant for anyone younger than 18, and we never knowingly gather personal data from children. Should we learn that a child’s personal data has been collected without an appropriate legal basis or parental authorisation where that is required, we will take reasonable measures to erase it.

14 Changes to this policy

From time to time we may revise this Privacy Policy to take account of:

• developments in law or regulation;
• changes in how we operate;
• improvements to security;
• changes to the Services.

Any update will appear on this page alongside a new “Last updated” date. If you keep using the Services after an update is published, you acknowledge the revised Privacy Policy.

15 Contacting us

You can reach us by post or email.

16 Where to complain

If you consider that the processing of your personal data has been unlawful, you may complain to the competent supervisory authority. Users based in Cyprus can turn to:

Office of the Commissioner for Personal Data Protection https://www.dataprotection.gov.cy/ (opens in a new tab)