What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The entity responsible for data processing, is F.L.K FRONT LINE KART , ΕΕ 57831 of P.O. Box 20424, Aglantzia 2152, Nicosia, Cyprus (“Front Line Kart”, “we”, “us”, or “our”) acting as the data controller in accordance with Cyprus’ Law No. 125(I)/2018 as amended (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”).
If you have any questions about this policy or our data protection practices, you can reach us via email using email@example.com, call +357 99 820 445 or write to us at the above address.
What are the legal bases of processing?
We only process your Personal Data if we have to have at least one of the reasons:
Data we collect automatically
Even if you do not log in or register on our website, but simply browse our website, data is collected and stored and processed by us. Specifically, this requires the IP address of your computer, Date and time of access, Name and URL of the accessed file, Browser used, Number of bytes transferred, Status of the page retrieval, Session ID, Referrer URL. The legal basis for this processing is our legitimate interest.
We host our website using the services of A2 Hosting. In this sense, A2 Hosting processes all data and communication data including IP addresses, that are provided to us through our website. This means that all data submitted to our website are transferred to Squarespace. The legal basis for processing is our legitimate interest.
Content Management System
We use the Content Management System (CMS) of WordPress by Automattic Inc, to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to our website is transferred to WordPress. The legal basis for this processing is our legitimate interest.
We integrate Google Fonts by Google LLC, and Font Awesome of Fonticons Inc. To enable the display of fonts, a connection to Google’s and Font Awesome’s server is established when our website is accessed. This enables Google and Fonticons to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.
Google Tag Manager
We use Google Tag Manager by Google LLC which allows website tags to be managed via an interface. The Google Tag Manager only implements tags. No cookies are set, and no Personal Data is collected. Google Tag Manager triggers other tags that may collect data but does not itself access this data. The legal basis for using Google Tag Manager is our legitimate interest.
To comply with our obligations we use the cookie consent tool “GDPR Cookie Consent” from Mozilor Limited trading as WebToffee to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via WebToffee: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; e) Time of your visit to the website. The basis for processing is our legitimate interest and your consent.
Links to other websites
Data we collect directly
If you contact us, we store and process the following data from you: Name, e-mail address, telephone number as well as other Personal Data that you provide when contacting us. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted, provided there is no legal obligation to retain it. The legal bases for processing are contract and our legitimate interest.
Create an Account
It is also possible for you to register for an account. For this purpose, you are asked to provide your full name, date of birth and your student code. Further, you can choose a password together with your email address, both of which will enable you to log in more easily without having to enter your data again when you access our course portal. We will hold your data as long as you have your account with us and you have the option to delete your account with us at any time. The legal basis for processing is the provision or initiation of a contractual service and your consent.
It is also possible for you to register for a member account. For this purpose, you will need to provide us with the following: Username, First Name, Last Name, E-mail Address, Password, Phone Number, Country of Residence, Date of Birth, Sector, Division, Your job title or position, Professional Registration Number, your professional ID card. Providing those will enable you to enter into a contract with us and to benefit from our services. We will hold your data for further orders as long as you maintain your registration. You have the right to access, correct or delete your registration data at any time. The legal basis for the data processing is your consent and the legal basis for the storage is contract.
Partners enter into a service contract with us. Front Line Kart exclusively processes personal data provided by the partner himself/herself or an employee authorized to represent him/her and necessary for the contractual performance of services by Front Line Kart. The Partner is responsible for ensuring that the active consent of the persons concerned has been obtained for all personal data provided by him/her, such as names and e-mail addresses of contact persons or company photos on which employees can be seen. The legal basis for the data processing is your consent and the legal basis for the storage is contract.
When using our Services
The protection of your data is particularly important to me in the performance of my services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain personal data, in order to fulfill our contractual obligations to you or to carry out pre-contractual measures. This processing of personal data will always be carried out in accordance with the DPA and the GDPR.
To ensure that you receive your discounts, we pass on the necessary data to the selected business partner so they can process your discount. In this case and provided that you consent to the sharing by using your Front Line Kart, we transmit your Front Line Kart Profile to the selected business partner.
In this way, we can ensure that your membership is verified and that the selected business partner is aware of your Front Line Kart Membership. With the information exchange, you can influence the delivery of your Front Line Kart benefits by the selected business partner but also disclose Personal Data and your location.
This in turn however may also reveal data that centers on your personal interests and may possibly reveal sensitive information. Accordingly, the processing of Personal Data and your location is limited to the strict needs of allowing you to claim your discount and is solely based on your consent.
We and the selected business partner involved in the process, are particularly vigilant not to collect Personal Data except if doing so is absolutely necessary for the purpose of processing. The legal basis is the fulfillment of our contractual obligations. For sharing your Front Line Kart Profile or location with the selected business partner, the legal basis is your consent.
If you make a purchase your payment will be processed via the payment provider Stripe Inc. Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
If you have consented to receive our newsletter, we will use your email address to send you information about us, our services, promotions, and news using the services of Mailchimp by Intuit Inc on our behalf. You can revoke your consent to receive the newsletter or to the creation of personalized user profiles at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data.
Analytics and market research
We are present on social media (currently Instagram and Facebook (Meta Platforms, Inc). If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.
Principles of processing Personal Data
Storage and Retention
As far as necessary, we process and store your Personal Data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.
In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods. The retention and documentation periods specified there are two to six years.
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Do Not Sell
We do not sell your Personal Data.
Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services including the selected business partner and, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
In the course of my website operation, we process data. We usually do not transfer Personal Data to countries outside Cyprus and the EEA. However, if we do, we will make sure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses for a high level of data protection.
Your Rights and Privileges
You can exercise the following rights:
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The Commissioner for the Protection of Personal Data (the “Commissioner”) 1 Iasonos Street, 2nd Floor, 1082 Nicosia, Cyprus and their website can be found at www.dataprotection.gov.cy. We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner or any other supervisory authority.
Does this policy change?
Who should I contact for more information?