Introduction
In this Privacy Policy, “users”, “you”, “your” and “yours” refers to the individual accessing the Sites and, where applicable, to the company or legal entity on whose behalf the individual is viewing this Privacy Policy.At Gadelia Services Ltd, we recognize that you, our users place a high value on the privacy of your personal information, and we want you to understand the kinds of information collected on the various websites operated by us, including program information and registration sites, www.repaid.com.cy, and the websites constituting the Repaid platform (collectively, the “Sites”), and how your personal, corporate and other information may be used and shared as you use the supply chain finance and other services (the “Services”) available on the Sites. All of this is described in this Privacy Policy, along with various ways in which the Sites treat your personal information. This Privacy Policy includes the Terms of Use, which is incorporated herein. By clicking your acceptance, you agree to both this Privacy Policy and the Terms of Use.
About this privacy policy
This privacy policy explains how we collect, use, and share your personal data when you use the services provided on our site and our app.Personal data is any information about you by which you can be identified. This can include information such as:
- your name, date of birth, email address, postal address, phone number, mobile number;
- information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and
- information relating to your personal circumstances and how you use our sites, apps and services.
Who we are and how to contact us
The data controller for our site and app is Gadelia Services Ltd, Sikinou 3A, 1048 Nicosia, Cyprus. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “How to contact us” section below.The categories of personal data that we collect, where we collect it from, and how we use it
We collect personal data when you sign up for our service and when you browse our site or use our app. This information is used to provide our officers how you use our site and app.The personal data we collect when you register for an account
When you register for an account on our site and app we collect:- your name;
- your mobile phone numbers
- your email address; and
- your bank account details to which payments will be made.
- your IP address - a numerical code to identify your device and which can provide information about the country, region or city where you are based;
- your browsing history of the content you have visited on our sites, including information on how you were referred to our sites via another website; and
- details of your devices, for example, the unique device ID, unique advertising ID and browsers used to access our content.
How we collect personal data
We collect personal data when you subscribe to our service.Why we use your personal data
We use personal data collected through our sites and apps for a number of purposes, including the following:- To provide the services you sign up for. We also use the personal data for related internal administrative purposes - such as our accounting and records - and to make you aware of any changes to our services.
- To send marketing communications when we have your permission, or when permitted by law.
- To personalize our services recognizing you when you sign in.
- For statistical purposes such as analysing the performance of our sites and apps and to understand how visitors use them.
- To respond to your queries and to resolve complaints.
- For security and fraud prevention, and to ensure that our sites and apps are safe and secure and used in line with our terms of use.
- To comply with applicable laws and regulations.
Access permissions that we ask from users of the Repaid app
When you use the Repaid app, we ask for the following permissions to access particular functions of your mobile device:- For the Android version, we ask for permission to access the storage on your mobile device, so that you can store content.
- For the iOS version, we ask for permission to save pictures to your photo library
Legal grounds for using your personal data
We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. The legal ground may be one of the following:- Consent: For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any time. In the case of marketing emails you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email.
- Our legitimate interests: Where it is necessary for us to understand our subscribers, promote our services and operate our sits and apps efficiently.
- Performance of a contract with you
- Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
Security of your personal data
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.Who we share your personal data with or sell your personal data to
We do not share your personal data with other people or organisations that are not directly linked to us except under the following circumstances:- We may share your data with other organisations that provide services on our behalf such as dealing with online payments and other forms of payment processing, i.e., credit card transactions and preventing fraud.
- We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
- We may reveal your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our privacy policy. Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards. We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.
How long we keep your personal data
We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data.How we may contact you
Service communications
From time to time we may send you service emailsMarketing communications and editorial newsletters
We may send you materials we think may interest you, such as new offers and updates. Depending on your marketing preferences, this may be by email, phone or SMSResponding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.Cookies and similar technology
When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technology. A cookie is a small file that can be placed on your device that allows us to recognise and remember you. Your rights under the General Data Protection Regulation with regard to the personal data that we hold about you If you live in the EEA, pursuant to the General Data Protection Regulation you can contact us with regard to the following rights in relation to your personal data:- If you would like to have a copy of the personal data we hold on you or if you think that we hold incorrect personal data about you, please write to the Data Protection Officer at Gadelia Services Ltd Sikinou 3A, 1048 Nicosia, Cyprus. We will deal with requests for copies of your personal data or for correction of your personal data within one month. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
- Where you have provided us with consent to use your personal data, you can withdraw this at any time.
- Where applicable, you may also have a right to receive a machine-readable copy of your personal data.
- You also have the right to ask us to delete your personal data or restrict how it is used, consistent with the GDPR. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request. Where applicable, you have the right to object to processing of your personal data for certain purposes.
Contact us for information about how we use your personal data
If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at Gadelia Services Ltd, 1048 Nicosia, Cyprus.Complaints will be dealt with by the Data Protection Manager and will be responded to within 30 days.