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Privacy Policy

How we collect, use, and protect your personal information.

Last updated: · CONSILIORA NEXUS CONSULTING LTD

1. Introduction

CONSILIORA NEXUS CONSULTING LTD ("Company", "we", "us", or "our"), a company registered in the Republic of Cyprus under registration number HE468919, with registered address at Franklinou Rousvelt, 170, 2nd floor, Omonoia, 3048, Limassol, Cyprus, is the data controller responsible for the personal data processed in accordance with this Privacy Policy.

This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website consiliora.org (the "Site") or engage with our digital marketing and mobile app promotion services.

This Privacy Policy is issued in accordance with Regulation (EU) 2016/679 (the "GDPR"), the Cyprus Law 125(I)/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data, and other applicable data protection laws.

2. Scope of This Policy

This Privacy Policy applies to the processing of personal data by CONSILIORA NEXUS CONSULTING LTD in connection with (i) the Site consiliora.org, (ii) our B2B business communications with clients, partners, and prospects, and (iii) our internal operations.

Client applications and separate products. We operate separate products and services — including mobile applications distributed via third-party app stores — that have their own dedicated privacy policies. If you are a user of any such product, the privacy policy published on the dedicated website of that product governs the processing of your personal data in connection with it, not this Policy. This Policy does not apply to the data of end users of such products.

3. Information We Collect

3.1 Information You Provide

We collect personal data that you voluntarily provide when you:

  • Fill out our contact form (name, email address, company name, message content)
  • Send us an email or otherwise communicate with us directly
  • Request information about our services or enter into a business relationship with us
  • Provide business contact details in the course of commercial negotiations or engagements

3.2 Information Collected Automatically

We do not run any analytics, tracking, or behavioural measurement tools on the Site. However, as with any website, our hosting infrastructure automatically processes limited technical information in standard server access logs for security, diagnostics, and abuse prevention purposes. These logs may include:

  • IP address of the visitor
  • Browser type and version (user-agent string)
  • Operating system and device type
  • Date and time of the request
  • URL requested and HTTP response status
  • Referring source, where provided by the browser

This information is not used to track individual users across sessions, to build profiles, or for marketing purposes.

3.3 Cookies and Similar Technologies

The Site does not use analytics, advertising, or tracking cookies. We do not use Google Analytics, Google Tag Manager, Meta/Facebook Pixel, or any similar tracking, profiling, or advertising technologies, and we do not display any advertising. We do not build user profiles, and we do not track you across sites or applications.

Where the Site sets any cookies at all, they are limited to strictly necessary technical cookies required for the Site to function (for example, session or security cookies, where applicable). Under Article 5(3) of the ePrivacy Directive and corresponding Cyprus law, strictly necessary cookies do not require your consent.

Please note that certain pages of the Site load web fonts and images from third-party content delivery networks (such as Google Fonts and Unsplash). When your browser requests these resources, your IP address is transmitted to the relevant provider for the sole purpose of delivering the content. These providers do not receive any tracking identifiers or cookies from us, and we do not use them to profile you. If you prefer not to load third-party resources, you can use browser extensions that block external content.

You can control, block, or delete cookies at any time through your browser settings. Doing so may affect the basic functionality of the Site.

4. Purposes of Processing and Legal Bases

We process personal data only for specific, legitimate purposes and only on the basis of a valid legal ground under Article 6 of the GDPR:

  • Responding to your inquiries and providing information about our services — legal basis: our legitimate interest (Art. 6(1)(f)) in responding to business communications, or taking steps at your request prior to entering into a contract (Art. 6(1)(b)).
  • Performing a contract with you or your organization — legal basis: contractual necessity (Art. 6(1)(b)).
  • Sending business communications and updates about our services — legal basis: your consent (Art. 6(1)(a)), which you may withdraw at any time, or legitimate interest (Art. 6(1)(f)) for existing clients, subject to an opt-out.
  • Operating, securing and improving the Site — legal basis: our legitimate interest (Art. 6(1)(f)) in running a secure and functional online presence.
  • Complying with accounting, tax and other legal obligations — legal basis: legal obligation (Art. 6(1)(c)).
  • Establishing, exercising or defending legal claims — legal basis: our legitimate interest (Art. 6(1)(f)) or legal obligation (Art. 6(1)(c)).

We do not carry out automated decision-making, including profiling with legal or similarly significant effects, on the basis of the personal data collected through this Site.

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data. We may share personal data only with:

  • Service providers (data processors): third parties acting on our documented instructions under written data processing agreements, including hosting providers, email and communication tools, and professional advisors (legal, tax, accounting). These providers are contractually required to process data only for our purposes and to maintain confidentiality and security.
  • Business partners: where strictly necessary to deliver services under a commercial agreement with you or your organization.
  • Competent authorities: where required by applicable law, court order, or a legally binding request from a public authority.
  • Acquirers or successors: in connection with a merger, acquisition, reorganization, or sale of all or part of our business or assets, with appropriate confidentiality safeguards.

6. International Data Transfers

Some of our service providers may be located outside the European Economic Area ("EEA"), including in countries that have not been recognized by the European Commission as providing an adequate level of data protection.

Where such transfers take place, we rely on appropriate safeguards in accordance with Article 46 of the GDPR, including (i) transfers to countries covered by a European Commission adequacy decision, (ii) Standard Contractual Clauses approved by the European Commission, together with supplementary technical and organizational measures where needed, or (iii) another lawful transfer mechanism permitted by the GDPR.

You may request a copy of the safeguards applied to a particular transfer by contacting us at the address below.

7. Data Retention

We retain personal data only for as long as is necessary for the purposes for which it was collected, and in accordance with the following general retention criteria:

  • Contact form and general inquiries: up to 12 months from the last meaningful contact, unless the exchange results in a business relationship.
  • Client relationship data: for the duration of the contractual relationship and for up to 6 years thereafter, for the purpose of defending against legal claims and complying with accounting obligations.
  • Accounting and tax records: for the period required by applicable Cyprus tax and accounting law (typically 6 years).
  • Server and security logs: up to 14 months, after which they are deleted or anonymized.
  • Marketing communications: until you withdraw consent or object to processing, plus a short suppression-list retention period to ensure your preferences are respected.

When retention periods expire, personal data is securely deleted or anonymized.

8. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include access controls, encryption in transit, least-privilege principles for employee access, and regular review of our security practices. No method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

9. Your Rights

Subject to the conditions and limitations set out in the GDPR and other applicable laws, you have the following rights with respect to your personal data:

  • Right of access — to obtain confirmation of whether we process your personal data and a copy of that data.
  • Right to rectification — to correct inaccurate or incomplete data.
  • Right to erasure ("right to be forgotten") — to request deletion of your personal data in certain circumstances.
  • Right to restriction — to restrict processing in certain circumstances.
  • Right to data portability — to receive your personal data in a structured, commonly used, machine-readable format, or to have it transmitted to another controller, where technically feasible.
  • Right to object — to processing based on our legitimate interests, including for direct marketing purposes.
  • Right to withdraw consent — where processing is based on consent, at any time and without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at support@consiliora.org. We will respond to your request within one month, as required by the GDPR. We may extend this period by a further two months where necessary, taking into account the complexity and number of requests, and will inform you of any such extension.

10. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the GDPR or other applicable data protection law, you have the right to lodge a complaint with a supervisory authority. The competent supervisory authority for our establishment is:

Office of the Commissioner for Personal Data Protection of the Republic of Cyprus
Iasonos 1, 1082 Nicosia, Cyprus
Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus
Email: commissioner@dataprotection.gov.cy
Website: www.dataprotection.gov.cy

You may also lodge a complaint with the supervisory authority of the EU Member State where you are habitually resident, where you work, or where the alleged infringement took place.

11. Third-Party Links

The Site may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children's Privacy

Our services are directed to businesses and are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child without the consent of a parent or guardian, we will take steps to delete it promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The "Last updated" date at the top of this page indicates when it was last revised. Where changes are material, we will take reasonable steps to bring them to your attention (for example, through a prominent notice on the Site or, where appropriate, by email). Your continued use of the Site after such changes indicates your acceptance of the revised Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, or if you wish to exercise any of your rights, please contact us:

CONSILIORA NEXUS CONSULTING LTD
Registration #HE468919
Franklinou Rousvelt, 170, 2nd floor
Omonoia, 3048, Limassol, Cyprus
Privacy contact email: support@consiliora.org