Last updated: 07/11/2024
I. Introduction
This Privacy Notice explains how our company (collectively “we” “us” or “our”) will collect, compile and disclose information about those who use of or contact us via the Website or other communication channels (collectively “you” or “your”). We put great efforts in making sure that we secure your personally identifiable information and use it properly. This Privacy Notice explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.
Please read this Privacy Notice (“Privacy Notice”, “Notice”) in full before using the Website. If you do not agree to this Notice, please do not provide us with your data.
II. Scope of application
This Privacy Notice applies to data processing activities carried out as part of:
- Site management xanada.investments (“Website”).
- Requests sent by you through the participation forms posted on the Website.
- Sending the Xanada your company’s documents or other essential information necessary for application.
III. What do we mean by “Personal Data” and “Processing of your Personal Data”?
For us, “Personal data” or “Personal information” means information relating to persons who:
- can be identified, or who are identifiable, directly from the information in question; or
- who can be indirectly identified from that information in combination with other information.
“Processing” covers “any operation” performed on personal data such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
IV. Who we are, and what is our role with respect to your Personal Data?
In this Privacy Notice, any reference to “Xanada”, “we”, “us” and “our” means: XANADA INVESTMENT LTD, limited liability company incorporated under laws of Cyprus.
Registration number: ΗΕ 461071.
Address: Anastasiou Sioukri, 1, THEMIS COURT, Floor 4, Flat/Office 402, 3105, Limassol, Cyprus.
Email: Projects@xanada.investments.
If you have any questions about this Privacy Notice, please contact us via the above-mentioned contact details.
With respect to personal data collected when you access and use the Website or communication channels via Social Media (as Twitter, LinkedIn or Facebook), we may act as a data controller, joint data controller, or a data processor depending on applicable circumstances as described below.
Data controller means an entity or individual that determines the purposes and means of processing personal data. In other words, the data controller is responsible for deciding why and how personal data is collected, stored, used, and disclosed. The Data controller is also obligated to ensure that the processing of personal data complies with the principles and requirements of the applicable legislation, including obtaining the necessary consent from data subjects and protecting their rights in relation to their personal data.
Joint data controller refers to two or more entities or organizations that jointly determine the purposes and means of processing personal data. In this scenario, they share the responsibility for complying with data protection laws and ensuring the protection of individuals' rights whose personal data is being processed. According to the applicable data protection legislation, which includes the General Data Protection Regulation, also known as the GDPR (“Applicable Legislation”), we may be regarded as joint controllers, for example, in the following case: with respect to your Social Media Data (what is this data outlined below) — when you contact us via Social Media, we are deemed a data controller with respect to (i) the data you provide us with and (ii) the statistical data provided by the respective Social Media. However, with respect to any other processing of your data, the respective Social Media acts as an independent data controller.
Data processor mean an entity or organization that processes personal data on behalf of a Data controller. The Data processor's role is to process Personal data according to the instructions provided by the Data controller. They may include various tasks such as collecting, storing, organizing, analyzing, and deleting Personal data.
V. What are Our principles?
We are committed to maintaining the highest standards of data protection and privacy when processing your Personal data. Our data processing practices are guided by the following principles:
Principles | Description |
Lawfulness, Fairness, and Transparency | We process your Personal data lawfully, with a clear and legitimate purpose. We ensure that you are informed about the processing activities through this Privacy Notice and any other relevant communications. |
Purpose Limitation | Your Personal data is collected for specified, explicit, and legitimate purposes and will not be further processed in a manner incompatible with those purposes. We do not use your data for purposes that are unrelated to the original intent of collection without obtaining your consent, unless required or permitted by law. |
Data Minimization | We only collect and process Personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is being processed. We do not retain your data longer than required to fulfill the specified purposes, unless retention is necessary for legal or regulatory compliance. |
Accuracy | We strive to keep your Personal data accurate, complete, and up-to-date. You have the right to request the correction of any inaccurate or incomplete information. |
Integrity and Confidentiality | We implement appropriate technical and organizational measures to ensure the security and confidentiality of your Personal data, protecting it from unauthorized access, disclosure, alteration, or destruction. |
Accountability | We take responsibility for our data processing practices and comply with applicable data protection laws and regulations. We maintain records of our processing activities and conduct periodic assessments to ensure compliance. |
Lawful Bases for Processing | We process your personal data based on one or more lawful bases, such as your consent, the performance of a contract, compliance with legal obligations, legitimate interests, or other lawful grounds provided by the Applicable legislation. |
Data Subject Rights | We respect your rights as a data subject and provide mechanisms for you to exercise those rights. |
International Data Transfers Security | If we transfer your Personal data to countries outside the European Economic Area (EEA), we will ensure that adequate safeguards are in place to protect your data, as required by applicable data protection laws. |
VI. What Personal Data do we collect?
The categories of personal data we collect depend on how you interact with us, use the Website, and the requirements of the Applicable Legislation.
We collect and process the following types of personal data as outlined below.
Category of Data | Examples | Description or Comments |
Analytical and Statistical Data | internet protocol (IP) address | When you access and use the Website, certain data may be collected automatically via Google Analytics. More information regarding Google Analytics is available here. After collecting the personal data, Google creates reports about the use of the Platform, which contain the aggregated information where we do not see any data pertaining to a particular person. In other words, we cannot identify you from the other users. Besides, we gather the information by means of placing cookies. Cookies are a feature of the software that allows web servers to recognise the device used to access the Website. A cookie is a small text file that the Website saves on your device when you visit thereof. They allow the Website to remember your actions and preferences over a period of time. |
the type of device used | ||
the browser used | ||
the device operating system | ||
information regarding your use of the Website, for instance, when you clicked a certain button or made some input. | ||
Contact Data | name/nickname | This data are collected through contact form on the website. You decide at your own discretion what data to provide to us. |
email address | ||
any other data requested by us or data that you choose to provide us with | ||
Subscription Data | email address | If you contact us via contact form on the website, we may use indicated email for our marketing and newsletter purposes. |
Social Media Data | nicknames, names, and/or photos | You may contact us via Social Media as Twitter, LinkedIn or Facebook. In general, Social Media makes available the respective statistical information to us in an anonymized form. It is impossible for us to make any conclusions about individual users and access to individual user profiles relying solely on such information. Certain categories of personal data and processing details vary depending on the Social Media, therefore, please refer to the Privacy policies of the respective Social Media as listed below. |
messages, comments, and other communications | ||
information provided to us by the respective Social Media as outlined below | ||
other data that you choose to provide us with | ||
Feedback Data | name | If you are satisfied with the services, or for other reasons decide to tell others your impression of us, you can send us feedback and we will publish it on our Website. |
position | ||
photo |
VII. How do we use Personal Data?
Category of Data | Description | Lawful Basis for Processing |
Analytical and Statistical Data | To provide a better user experience by improving functionality, usability, user flow and interface of the Website. | Our legitimate interest to improve the Website functionality and user experience, detect fraud and respond to requests from authorities. |
Contact Data | To respond to your inquiry. | Our legitimate interest to respond to your inquiry. |
Subscription Data | To provide you with marketing and newsletter emails concerning our investment services, compliance guidance, as well as general updates. | Your consent. You may revoke your consent and unsubscribe from receiving marketing and newsletter emails from us at any time by (i) contacting us; or (ii) clicking the unsubscribe button available at the bottom of each marketing and newsletter email. In such a case, we will delete your email address from the respective marketing database. |
Social Media Data | To communicate with the visitors, participants, or subscribers | Our legitimate interest to achieve the purposes outlined herein. To take steps at your request prior to entering into a contract and further to perform such a contract, if and to the extent you wish to enter into a contractual relationship with us. |
To handle requests from visitors via the communication channels. | ||
To obtain statistical information about the reach of the communication channels. | ||
To conduct customer surveys, marketing campaigns, market analyses, or other promotions and events. | ||
Feedback Data | To provide Website users with the experience and impressions of others from cooperation with us. | Our legitimate interest to achieve the purposes outlined herein. |
VIII. How long do we retain Personal Data?
Category of Data | Period of retention | Explanation |
Analytical and Statistical Data | Up to two (2) years. You may find specific timelines here. | Specific timelines are set by Google in its settings. |
Contact Data | 2 years after the last communication, unless otherwise provided by the relevant legislation | |
Subscription Data | As long as you remain a subscriber. | We process such data only until you opt out from receiving our marketing and newsletter emails. |
Social Media Data | No retention period for statistical and analytical information. The personal data you provided us with is stored as long as it is not deleted by you or respective Social Media. Information on our communication will be deleted by us after 2 years from the last communication. | We do not establish any retention period for statistical and analytical information, because such information does not allow us to identify any particular individual. We may not be able to erase the personal data you provided us within the communication channels, therefore, such data is processed until either you or respective Social Media deletes it. |
Feedback Data | As long as your feedback remains on our Website. | We process such data only until you opt out by informing us via contact details stipulated in the "Contact Us" section. |
IX. Do we share your Personal Data with Third parties?
We do not share your Personal information with other companies for direct marketing purposes.
Each section on Personal data processing operations details the external recipients responsible for accessing and processing the relevant data. The data may be shared with technical service providers selected for their experience and reliability, who act on our behalf and in accordance with our instructions (IT subcontractor, our server hosting providers, etc.).
We authorize these providers to use your Personal information only to the extent necessary to perform services on our behalf or to comply with legal requirements, and we are committed to ensuring that your personal information is protected at all times. Information about these companies and their privacy policies:
Google Ireland Ltd. Address: Gordon House, Barrow Street, Dublin 4, Ireland and its affiliates including Google LLC, 1600, Amphitheatre Parkway, Mountain View, CA, 94043, USA. You can learn more about how Google processes personal data here. We share your information with Google for the purposes of marketing and analytics. Unfortunately, the US is not recognized by the EU as a country that provides a sufficient level of personal data protection, which is why, for our EU customers, we have concluded a DPA (Data Processing Agreement) with Google to ensure that your data is always safe.
With respect to the personal data collected via Google solutions, Google acts as our data processor. However, Google may use this personal data for any of its own purposes, such as profiling and cross-platform tracking. In this case, Google acts as an independent data controller. You can learn more about Google tools here.
Hosting Ukraine LTD. Our site is hosted by Hosting Ukraine LTD. The data that you leave in the web forms of the site is available to this company. Address: Ukraine, 03067, Kyiv, str. Mashynobudivna, bldg. 35-A. Unfortunately, Ukraine is not recognized by the EU as a country that provides a sufficient level of protection of personal data, which is why, for our clients from the EU, we have concluded a DPA (Data Processing Agreement) with a Hosting Ukraine LTD, so that your data is always safe.
X. What rights do you have in relation to Personal Data?
According to Applicable Legislation you may have the rights in relation to the personal information we hold about you as outlined below. In order to exercise your rights as a data subject, we may request some additional information from you to verify your identity.
Rights | Description |
Right of access | You have the right to request access to the personal data we hold about you. Upon receipt of such a request, we will provide you with information about the purposes of the processing, the categories of personal data being processed, any recipients of the data, and the data retention period. |
Right to rectification | If you believe that the personal data we have about you is inaccurate or incomplete, you have the right to request that we rectify or update it promptly. |
Right to erasure (Right to be Forgotten) | You can request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent, and there are no legitimate grounds for continuing the processing. |
Right to restrict processing | You have the right to request the restriction of processing your personal data under specific circumstances, for example, if you contest the accuracy of the data or if the processing is unlawful, and you oppose erasure. |
Right to data portability | You may request to receive a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another data controller, where technically feasible. |
Right to object | You have the right to object to the processing of your personal data based on our legitimate interests. We will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms. |
Right to withdraw consent | If you have provided consent for the processing of your personal data, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. |
Right to file a complaint | If you believe that your rights under the Applicable legislation have been violated or that we have not properly addressed your concerns regarding the processing of your personal data, you have the right to file a complaint with the relevant supervisory authority. The supervisory authority is the data protection authority in your country or region responsible for overseeing compliance with data protection laws. You can find the contact details of your supervisory authority on their official website or through other relevant sources. The supervisory authority in Cyprus: Office of the Commissioner for Personal Data Protection Website: https://www.dataprotection.gov.cy Address: Kypranoros 15, 1061 Nicosia Postal address: P.O. 23378, 1682 Nicosia Phones: +357 22818456 E-mail: commissioner@dataprotection.gov.cy. |
To exercise any of these rights, or if you have questions or concerns about how we handle your personal data, please contact us using the information provided in the IV section of this Privacy Notice. We will respond to your requests and inquiries without undue delay and in accordance with the requirements of the Applicable legislation. Please note that there may be instances where we cannot fulfill your request due to legal requirements or exemptions provided by the Applicable legislation.
XI. Could this Privacy Notice be modified?
We reserve the right to review this Privacy Notice from time to time of which you will be promptly updated. If we decide to change our Privacy Notice, we will post those changes on this page, and/or update the Privacy Notice. If we make any changes to this document, we will change the “Last Updated” date above. If you want to make sure that you are up-to-date with the latest changes, we advise you to frequently visit this page.
XII. Contact Us
Kind reminder, if you have any questions about this Privacy Notice, please contact us via the following contact details:
Registration number: ΗΕ 461071.
Address: Anastasiou Sioukri, 1, THEMIS COURT, Floor 4, Flat/Office 402, 3105, Limassol, Cyprus.
Email: Projects@xanada.investments.
