Website Privacy Policy

By accessing and/or using any of Rich Media Gallery you agree that you are bound by the website privacy policy.  Any unauthorized use of Rich Media Gallery products, designs, and services, including but not limited to, entry into Rich Media Gallery’s systems, misuse of any information posted on or to the Sites, or otherwise engaging in any activity relating to the Sites products, designs, and services that are contrary to applicable laws is strictly prohibited.

Rich Media Gallery’s reserves the right to change the website privacy policy at any time by publishing the modified version and you agree to be bound by the modified website privacy policy.

  1. Website operation

We process your personal data in order to be able to provide you with the best possible information about our Group and to make your visit on our website as insightful and productive as possible. In general, personal information you submit to us is used either to respond to requests that you make, assist us in serving you better, or/ and marketize our services, products, business activities and industry news or our company’s news. We use your personal information in the following ways:

  • Operate, maintain, and improve our site(s), products, and services;
  • Respond to comments and questions and provide customer service;
  • Link or combine user information with other personal information we get from third parties, to help understand your needs and provide you with better service;
  • Develop, improve, and deliver marketing and advertising for the Group;
  • Provide and deliver products and services you request;
  • Identify you as a user in our system.

Personal data means any information capable of identifying an individual. It does not include anonymized data. We do not collect any Sensitive Data that refers to details about your race or ethnicity, religious or philosophical beliefs, private life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting, printed form or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping and for the establishment, pursuance, or defense of legal claims.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, address, company name, job title, sector, discipline, delivery address, email address, phone number and contact details. We process this data to supply the goods and/or services you have interested in and to keep records of such transactions. Our lawful ground 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 or communication.
  • User Data that includes data about how you use our website and any online services and products together with any data that you provide us through our website or through other online services and applications. We process this data to operate our website and ensure relevant content is provided to you, to establish security to our website, to maintain backups of our website and/or databases and to enable publication and administration of our website with other online services and business.
  • Technical Data that includes data about your use of our website and online services such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking systems. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Moreover, the Technical Data is important to enable us to properly administer our website and to grow our business and to decide our marketing strategy.
  • Marketing Data includes data about your preferences in receiving marketing material from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, campaigns, newsletters, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.
  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Social Media or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to assess the information and the products we marketize and our offers. If you don’t provide us with the requested data, we may have to cancel a product or service you have requested but if we do, we will notify you at the time.

  1. Processed data

When assessing and therefore collecting data we first establish that the processing is necessary. This means the processing must be a targeted, appropriate way of achieving the stated business purpose relying on the respected lawful bases. Our commitment requires us to document this process and show that we have considered which lawful basis best applies to each processing purpose, and fully justify these decisions. We also ensure that users, customers and subscribers whose data is being processed by us are informed of the lawful basis for processing their data, as well as the intended purpose. This is done via a privacy notice whether we have collected the data directly from the user, or from another source that we request its consent to establish communication and business offers.

2.1. Automatically collected data

In order to be able to display the most suitable information for you, we process the following data:

  • Address of the page you have visited on our website;
  • Address of the website you have visited immediately before our website (the so-called “Referrer”);
  • Date and time of your visit;
  • Features of your terminal, particularly the operating system, the browser used and the window size of your browser;
  • IP address of your terminal on the Internet;
  • Identification numbers that we store on your terminal. These identification numbers help us recognize your terminal on the website. Technically speaking, these identification numbers are stored in the so-called cookies;
  • Device identifiers consisting of individual features of your terminal. These device identifiers also help us recognize your terminal on the website.

The data processing related to the website’s services and products takes place at the premises of the Group. Appointed members of the staff are responsible for the actual treatment of your data taking all the necessary steps to ensure the confidentiality and security of shared data, in compliance with the provisions of the laws of the Republic of Cyprus and the European Union.

2.2. Data provided

Additionally, we process your personal data when, due to your interest in our Group, you contact us via mail, our website or otherwise and/or when you conclude agreements with us for the purchase of our products.

2.3 Comments

We may receive testimonials and comments from users who have had positive experiences with our services and products. We may publish such content. When we publish this content, we may identify our users by their first and last name. We obtain the user’s consent prior to posting this information along with the testimonial.

  1. Data processing purposes

Moreover, you can at any stage cancel the user account and/or to request to erase your details and contacts from the email newsletter by sending a written email. Once we have received notification that you have revoked your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

3.2 Disclosure of Your Personal information

We disclose your personal information as described below and as described elsewhere in this Privacy Policy.

Third Parties Designated by You: When you use the services, the personal information you provide will be shared with the third parties that you authorize to receive such information.

Third-Party Service Providers: We may share your personal information with third-party service providers to provide you with the products and services that we offer you through our services; conduct quality assurance testing; to provide technical support; market the services; and/or to provide other services to us.

Information We Share: We may disclose aggregated information about our users and information that does not identify any individual without restriction. In addition, we may disclose personal information that we collect or you provide:

  • To fulfil the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, or with your consent;
  • To third parties designated by you;
  • With our subsidiaries and affiliates;
  • To third parties to process and accept payments;
  • With contractors, service providers and other third parties we use to support our business;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users is among the assets transferred.

Other Disclosures: Regardless of any choices you make regarding your Personal Information may disclose Personal Information if it believes in good faith that such disclosure is necessary: (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on our company; (iii) to protect or defend the rights or property of our website or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our other internal policies and procedures.

3.3. E-mail newsletters & further e-mail campaigns

We offer you choices regarding the collection, use and sharing of your personal information. We may periodically send you emails that directly promote the use of our services and products. When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to this Policy.

We provide all our website users and/or clients and interested parties with an e-mail newsletter and/or further e-mail campaigns. In order to subscribe, the user can register for the web offer with his/her e-mail address. Subsequently, the user receives an activation link at the provided e-mail address, a link that the user must click on, in order to complete the subscription. This way, the user consents to the receipt of an e-mail newsletter and/or further e-mail campaigns (double-opt-in procedure).

The consent to receive the e-mail newsletter and/or further e-mail campaigns can be revoked at any time, without giving reasons. The easiest way to do this is to click on the “Unsubscribe” link, which can be found in every e-mail or by sending an email to erase and delete his/her contact details.

3.4. Entering into agreements

Insofar as we enter into agreements with our clients and service providers, for service provision purposes, we process the personal data of the persons authorized to sign the agreements and of the clients’ and service providers’ contact persons.

  1. Applicant data

Applicants are given the possibility to apply for advertised jobs via our website, email, third party websites or Linkedin. In this respect, we process the applicants’ personal data (first and last name, e-mail address, phone number, curriculum vitae (CV), cover letter, salary expectations, availability, previous employer, possibly certificates, recommendations, etc.) exclusively in order to decide on the establishment of an employment relationship, and, if so, in order to perform and terminate such a relationship.

We erase the applicant’s data within one year the latest as no employment relationship is justified. This does not apply if the applicant has consented that we store the data for a longer period and in order to receive other job offers during this period. The applicant can revoke such consent at any time, by sending an e-mail to [email protected]  In this case, the data are immediately erased and deleted.

  1. Data transfer

Your personal data will only be transferred to third parties by us if this is necessary to fulfil the contract, if we or the third party have a legitimate interest in the transfer or if you have consented to the transfer to a third party.

In addition, personal data may be transferred to third parties after signing a relevant agreement that the third parties comply with this policy and we will ensure that the recipient has an adequate level of data protection and the users have consented into that.

  1. Tracking tools for website analysis

6.1. General information

We want to design our web pages as optimal as possible. Therefore, we use tracking tools in order to technically and commercially improve our web structure allowing us to measure the usage of our web offers and identify the frequency and the interest on our pages, the information requested, the offers that are interested in the users in order to assist us to prepare statistics about the attractivity, the marketability, the marketing channels and the interests of the users to our website and pages.

6.2. Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). We use via Google such information in order to assess the use of the website by new and regular users, to prepare reports on the website activity and to provide the users with further services related to the website and internet usage. We try to constantly improve the use of our website and our marketability by the figures of the reports without involving any personal data that can identify the user apart from its IP.

6.3. Remarketing

We analyse our users’ interaction with our website, focusing on the offers that the users have shown interest in to be able to display targeted advertisements for them on other websites that the users visit subsequently. In doing so, Google saves cookies in the browsers of the users who visit certain Google services or websites within the Google display network. This cookie records the user’s visits. This number serves the clear identification of a web browser on a certain computer and not the identification of a person, and thus no personal data are stored. The user may prevent the cookie by means of a setting in his/her browser software.

6.4. Google Tag Manager

For transparency reasons, we point out that we use the Google Tag Manager. The Google Tag Manager does not collect any personal data. The Tag Manager facilitates the integration and management of our tags. Tags are small code elements that serve, among other things, the measurement of traffic and visitor behaviour, the determination of the effect of online advertising and social media, the remarketing and setting up of target groups and the testing and optimization of websites.

6.5 Cookies

They are small pieces of information (text files) that a website sends to your computer’s hard drive while you are viewing the website. We can store some cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission. To that end, this site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. We and some third parties may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our services and to marketize the services or other products. Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. If you decide at any time that you no longer wish to accept cookies from our Services and products for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the services or all functionality of the services. If you have any questions about how to disable or modify cookies, please contact us at info@newdeal.digital

  1. Third-Party Websites

Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and are not responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

  1. Training

All employees of the Group dealing with the GDPR and data processing will receive adequate training on provisions of data protection law specific for their role. Further training will be given as requested or if there is a move in role or responsibilities.

  1. Use of external service providers

For the operation of our website, we entrust external service providers with the processing of data (e.g. for the storage of data in data centres). If necessary, such service providers process personal data, as well. We select and monitor the service providers carefully.

  1. Storage period

We keep personal data only as long as this is necessary for the fulfilment of the purposes herein and/or for the retention periods stipulated by law. The data that you provide is therefore erased not later than the expiry of the possible commercial and fiscal retention periods and in any case, will not be longer than 6 years.

  1. Your rights

You have the following rights regarding your personal data:

  • Right to access personal data
  • Right to object
  • Right to rectification or erasure
  • Right to restriction of processing
  • Right to data portability

Please use the information under Contact to assert your rights. Please make sure that we can uniquely identify you. You can also object to the processing of your personal data for advertising purposes at any time (“Advertising Objection”). Please note that for organisational reasons there may be an overlap between your revocation and the use of your data within the framework of an ongoing campaign.

  1. Copyright

All Rich Media Gallery and Products, Designs, and Services are Copyright © Adap Digital Group of Companies. All rights reserved. 

  1. Trademarks

Rich Media Gallery registered logos and trademarks of Rich Media Gallery of Companies.  All pages, including splash screens, page headers, and custom graphics on Rich Media Gallery and Services are protected as trade dress under applicable law.  Rich Media Gallery and Services may also contain other trademarks, service marks, or trade names, which may be owned by Rich Media Gallery or a third party. You may not use any of the trademarks, service marks, or trade names contained on Rich Media Gallery Sites, Products, Designs, and Services, or copy or imitate the design or any element of the design that may be protected as trade dress under international, European and national laws, without the prior written consent of the owner.

  1. Cookies

We use cookies, and other technologies (collectively, “cookies”) to recognize your browser or device, learn more about your interests, and provide you with essential features, products and services and for additional purposes. When you visit this site, cookies will be placed on your machine for tracking visitor activity anonymously and remembering user preferences.

I set a cookie to remember that you don’t want to see the banner that warns you about cookies on this site. If you click the “Accept & Close” button, you will not see this banner on future visits. Approved third parties may also set cookies when you interact with Rich Media Gallery services. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies.

*Note: cookies are browser-specific. If you visit using a different browser or on another machine, you may see the banner again.

Cookie

Who owns the data?

Is this a 1st party or 3rd party cookie?

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Google

3rd Party

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Google

3rd Party

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Google

3rd Party

cookieconsent_status

User

1st Party

PHPSESSID

User

1st Party

CONSENT

Google

3rd Party

1P_JAR

Google

3rd Party

NID

Google Maps

3rd Party

PHPSESSID

User

1st Party

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Facebook

3rd Party

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facebook

3rd Party

  1. Disclaimer, Limitation of Liability and indemnity

YOUR ACCESS TO, AND USE OF, Rich Media Gallery DIGITAL SERVICESIS AT YOUR OWN RISK INCLUDING, BUT NOT LIMITED TO, ALL CONTENT, FUNCTIONS, APPLICATIONS, AND SERVICES, ARE PROVIDED “AS IS” TO THE FULLEST EXTENT PERMISSIBLE BY APPLICABLE LAW, AND NEWDEAL DIGITAL EXPRESSLY DISCLAIMS ALL STATUTORY OR IMPLIED REPRESENTATIONS, WARRANTIES, OR TERMS AND CONDITIONS.  NEWDEAL DIGITAL DOES NOT WARRANT OR REPRESENT THAT ANY CONTENT OR MATERIAL THAT YOU MAY ACCESS AT OR THROUGH A NEWDEAL DIGITAL SITE IS CURRENT, ACCURATE OR COMPLETE.  YOU AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR ANY AND ALL COSTS ASSOCIATED WITH ANY SERVICING OR REPAIRS OF ANY EQUIPMENT YOU USE, INCLUDING YOUR COMPUTER AND THAT NEWDEAL DIGITAL WILL NOT IN ANY WAY HELD LIABLE TO YOU FOR DAMAGES OF ANY KIND, INCLUDING, BUT NOT LIMITED TO, DAMAGES THAT ARE COMPENSATORY, DIRECT, INDIRECT OR CONSEQUENTIAL, LOSS OF PROFIT, INCOME OR DATA, DAMAGE TO PROPERTY OR CLAIMS BY ANY OTHER PERSONS OR ENTITIES, THAT RELATE TO YOUR ACCESS TO AND/OR USE OF THE SITES.  YOU ALSO AGREE TO WAIVE ANY AND ALL CLAIMS OF ANY KIND OR NATURE THAT YOU MAY HAVE AGAINST NEWDEAL DIGITAL, ITS OFFICERS, EMPLOYEES, AFFILIATES OR LICENSEES, WITH RESPECT TO YOUR USE OF THIS SITE OR ANY OF THE INFORMATION OR MATERIALS AVAILABLE AT THE SITE.  FINALLY, YOU AGREE TO DEFEND, INDEMNIFY AND HOLD HARMLESS, NEWDEAL DIGITALITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, DISTRIBUTORS AND ITS AFFILIATES FROM AND AGAINST ANY AND ALL THIRD-PARTY CLAIMS, DEMANDS, LIABILITIES, COSTS, OR EXPENSES, INCLUDING REASONABLE ATTORNEY’S FEES, RESULTING FROM OR RELATED TO YOUR ACCESS TO AND/OR USE OF THE SITE OR SERVICE, OR YOUR BREACH OF ANY OF THE AGREEMENTS, REPRESENTATIONS OR WARRANTIES YOU HAVE MADE TO OR WITH NEWDEAL DIGITAL.

  1. Governing Law

All matters relating to your access to or use of the Rich Media Gallery hall be governed by the statutes and laws of the Republic of Cyprus.

  1. Contact

Rich Media Gallery

Stadiou 73, Larnaca, Cyprus 6020

i[email protected]

Laws and provisions

1)    Article 6(1)(f) GDPR (Legitimate interests, based on our interest to offer you the best possible attractive website).

2)    The legal basis for such data processing is Article 88 GDPR.

3)    The legal basis for such data processing is Article 6(1)(b) GDPR (Performance of a contract) and Article 6(1)(f) GDPR (Legitimate interests, based on our interest to provide our customers and service providers with relevant information).

4)    The legal basis for this is your consent within the meaning of Article 6(1)(a) GDPR, as well as Article 6(1)(f) GDPR (Legitimate interests, based on our interest to adapt the website to our users’ interests and needs, to the best possible extent).

5)    Ο περί Προστασίας των Φυσικών Προσώπων Έναντι της Επεξεργασίας των Δεδομένων Προσωπικού Χαρακτήρα και της Ελεύθερης Κυκλοφορίας των Δεδομένων αυτών Νόμος 125 (Ι) του 2018, σε εφαρμογή των διατάξεων του Κανονισμού (ΕΕ) 2016/679 του Ευρωπαϊκού Κοινοβουλίου και του Συμβουλίου της 27ης Απριλίου 2016 για την προστασία των φυσικών προσώπων έναντι της επεξεργασίας των δεδομένων προσωπικού χαρακτήρα και για την ελεύθερη κυκλοφορία των δεδομένων αυτών και για την κατάργηση της οδηγίας 95/46/ΕΚ (Γενικός Κανονισμός για την Προστασία Δεδομένων) άλλως GDPR.