1 Introduction

Xyrichis Transport Services is committed to maintaining the accuracy, confidentiality and security of your personal information. These Privacy and Cookies Policies describe the personal information that Xyrichis Transport Services collects from or about you when you visit this website and how we use and to whom we disclose that information. The effective date of these Privacy and Cookies Policies is January 20, 2020.

2 Application

Xyrichis Transport Services has adopted a series of Privacy and Cookies Policies in order to address the specific privacy concerns of certain groupings of individuals and specific regulations covered under the European Union General Data Protection Regulation (GDPR) (EU) 2016/679.

3 Compliance Policy

It is Xyrichis Transport Services’ policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes, the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. These Privacy and Cookies Policies were developed to guide the activities of Xyrichis Transport Services. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions.

These Privacy and Cookies Policies have a limited scope and application and the rights and obligations contained in these Privacy and Cookies Policies may not be available to all individuals or in all jurisdictions. If you are unsure if or how these Privacy and Cookies Policies apply to you, please contact us at info@xyrichis.com.

4 Definitions

4.1 Personal Data

Personal data is any information relating to an identified or identifiable natural person.  An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (including IP address) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

4.2 Usage Data

Usage Data is data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

4.3 Cookies

Cookies are small pieces of data stored on a User’s device.

This website uses cookies to distinguish you from other users of our website. This helps us provide a good experience when you browse this website and also allows us to improve the functionality of the website. By continuing to browse this site, you agree to our use of cookies.

4.3.1 What is a cookie

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

4.3.2 What cookies we use

• Strictly necessary cookies.These are cookies that are required for the operation of our website.
• Analytical/performance cookies.They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve the way this website functions, i.e. ensuring that visitors will find easily what they are looking for.
• Functionality cookies.These are used to recognize you when you return to this website. This enables us to personalize our content and remember your preferences (i.e. your choice of language).
• Targeting cookies.These cookies record your visit to this website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. To this end, we may share this information with third parties.

Please note that third parties (web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies and targeting cookies.

You can manage the cookies settings in your browser. You can find more information about disabling cookies or managing your browser’s cookie settings below:

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
• Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of this site.

If you require more information about our cookies policy, please contact us at info@xyrichis.com.

4.4 Data Controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

Under these Privacy and Cookies Policies, we are a Data Controller of your data.

4.5 Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

4.6 Data Subject

Data Subject is any living individual who is the subject of Personal Data.

4.7 User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

5 What Data We Collect?

5.1 Personal Data

While using our Service, we may ask you to provide us with personally identifiable information that may include, but is not limited to:

• Email address
• First name and last name
• Cookies and Usage Data

We may use your Personal Data to contact you.

5.2 Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, your mobile operating system, unique device identifiers and other diagnostic data, which are collected in order to optimize our infrastructure and Service.

5.3 Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

5.4 Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our service and hold certain information.

6 How will this Data be Used?

Xyrichis Transport Services uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues

7 How Long is your Data Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, Xyrichis Transport Services endeavours to retain your personal information only for as long as it believes is necessary to fulfil the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting, tax or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.

Xyrichis Transport Services will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

8 Transfer of Data

We may share your personal information with other parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in Cyprus, and in some cases, other countries.  Personal data is only transferred by us to another country if this is required or permitted under the applicable privacy legislation, in particular only in as far as a reasonable level of data protection is assured in the recipient country.

Your consent to these Privacy and Cookies Policies, followed by your submission of such information, represents your agreement to that transfer.

9 Disclosure of Data

9.1 Disclosure for Law Enforcement

Under certain circumstances, Xyrichis Transport Services may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

9.2 Legal Requirements

Xyrichis Transport Services may disclose your Personal Data in the good faith belief that such action is necessary:

• as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavour to not disclose more personal information than is required under the circumstances;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• to protect the rights and property of Xyrichis Transport Services;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the personal information is publicly available; or
• with your consent where such consent is required by law.

10 How is Your Personal Data Protected?

Xyrichis Transport Services endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal data in question. These safeguards are designed to protect your personal data from loss and unauthorized access, copying, use, modification or disclosure.

11 Your Rights

Under the GDPR and/or Privacy Shield regulations, you have a number of rights with regard to your personal data.

1. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability.
2. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
3. You have the right to ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.
4. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer at info@xyrichis.com.
5. Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
6. You have the right to lodge a complaint to the relevant authorities if you believe that we have not complied with the requirements of the GDPR.

12 Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
• For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

13 Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy and Cookies Policies of every website you visit.

We have no control over and assume no responsibility for the content, privacy and cookies policies or practices of any third-party sites or services.

14 Children’s Privacy

Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

15 Changes to this Website’s Privacy and Cookies Policies

We may update our Privacy and Cookies Policies from time to time. We will notify you of any changes by posting the new Privacy and Cookies Policies on this page.

You are advised to review the Privacy and Cookies Policies periodically for any changes. Changes to the Privacy and Cookies Policies are effective at the time they are posted on this page.

16 Privacy Officer

We have appointed a Privacy Officer to oversee compliance with these Privacy and Cookies Policies and to respond to any questions you may have as to how your data is processed. The contact information for our Privacy Officer is info@xyrichis.com.