We are committed to protecting your privacy. In this Privacy Policy, we set out how we collect your personal data, how we use it, and what rights and choices you have in relation to the personal data we hold and process.
This Privacy Policy is separate and in addition to client confidentiality obligations we may owe you. Please refer to the terms and conditions applicable to your engagement for further details.
Who decides why and how we process your personal data?
M.P. Theodorou (Salt Industry) & Sia Ltd determines why and how we process your personal data.
What personal data might we collect?
We collect different types of personal data when you express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us. This may include:
Contact information: Information such as your name, job title, postal address, home address where you provide this to us, business address, telephone number, mobile number, fax number and email address.
Payment data: Data necessary for us to process payments and implement fraud prevention measures, including credit/debit card numbers, security code numbers and other such relevant billing details.
Business details: Business information which we necessarily process as part of our instructions or projects we are involved in or otherwise provided by you voluntarily.
Preferences: Information about your preferences, where it is relevant to the services we provide.
Sensitive personal information: We do not process sensitive personal information.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
How will we use your personal data?
We will use your personal data for the following purposes (Permitted Purposes):
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see section ‘What are your privacy rights?’ below.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
Where you have expressly given us your consent, we may process your personal data also for the following purposes:
- For customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events; or
- To collect information about your preferences to create a user profile to personalise and foster the quality of our communication and interaction with you.
Depending on for which of the above Permitted Purposes we use your personal data, we may process your personal data on one or more of the following legal grounds:
- Because processing is necessary for the performance of a client instruction or other contract with you or your organisation or a Third Party Entity;
- To comply with our legal obligations (eg to keep pension records or records for tax purposes); or
- Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms.
We may also process your data based on your consent where you have expressly given that to us.
How will we share your personal data?
We may share your personal data in the following circumstances:
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
- Data Analytics Services
- Communication & Collaboration Tools
- Sales & Marketing Tools
- Ad Networks
- Finance & Accounting Tools
- Data Storage Service Providers
- Cloud Computing Services
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Can you refuse to share your personal data with us?
In general, we receive your personal data where you provide this on a voluntary basis, and there will typically be no detrimental effect for you if you wish not to provide this or otherwise withhold your consent for it to be processed. However, there are certain cases where we will unfortunately be unable to act without receiving such data, for example where we need to carry out legally required compliance screening or require such data to process your instructions or orders, or otherwise to provide you with our online services or communications.
Where it is not possible for us to provide you with what you request without the relevant personal data, we will let you know accordingly.
How do we keep your personal data safe?
We take appropriate technical and organisational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data. We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files.
Personal data we receive from you about other people
Where you provide us with the personal data of other people, such as your employees, directors of your companies, or other persons you may have dealings with, you must ensure that you are entitled to disclose that personal data to us and furthermore that, without being required to take further steps, we can collect, use and disclose that data in the manner described in this policy. More specifically, you must ensure that the individual whose personal data you are sharing with us is aware of the matters discussed in this Privacy Policy, as these are relevant to that individual, including our identity, how to get in touch with us, the purposes for which we collect data, our disclosure practices, and the rights of the individual in relation to our holding of the data.
Transfers of personal data abroad
M.P. Theodorou (Salt Industry) & Sia Ltd is active across the world. This means that we may transfer your personal data abroad if required to do so for the Permitted Purposes. In certain cases, this may include transferring data to countries which do not offer the same level of protection as the laws of your country (such as for example the data protection legislation of the EU/EEA).
When making such transfers, we will ensure that they are subject to appropriate safeguards in accordance with the General Data Protection Regulation (Regulation 2016/679) or other relevant data protection legislation. This may include entering into the EU Commission’s Standard Contractual Clauses.
All entities and offices within M.P. Theodorou (Salt Industry) & Sia Ltd will ensure an adequate level of protection for your personal data at all times.
How long do we keep your personal data?
We delete your personal data once it is no longer reasonably necessary for us to keep it for the Permitted Purposes, or, where we have relied on your consent to keep your personal data, once you withdraw your consent for us to do so, and we are not otherwise legally permitted or required to keep the data.
What rights do you have?
Subject to certain conditions under applicable legislation, you have the right to:
- Obtain information regarding the processing of your personal data;
- Request a copy of the personal data which we hold about you;
- Have any inaccurate data we hold about you corrected;
- Object or restrict our use of your personal data;
- Ask that we not subject you to automated decision-making that uses your personal data;
- Object to us using your personal data for direct marketing purposes;
- Submit a complaint if you have concerns about the way in which we are handling your data.
To do any of the above, please contact us at info@theodorousalt.com. To enable us to process your request, we may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification. This is to ensure that we appropriately protect the personal data we hold from unauthorised access requests and comply with our security obligations.
We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive, and for any additional copies of the data you may request.
In relation to complaints, we will promptly respond to your requests and complaints. In the event that you are unhappy with our response, you may submit a complaint to the relevant privacy regulator. We can provide you with the details of the relevant regulator upon request.
Correcting and updating your personal data
Where any personal data you have provided us with has changed, or where you believe the personal data we hold is inaccurate, please let us know at info@theodorousalt.com. In addition, please note that if you hold an office or are interested in or have certain relationships with a Third-Party Entity to which we provide services, you and/or the Third Party Entity may have a contractual or legal obligation to notify us of any change within a prescribed time period. We cannot be responsible for any loss that may arise due to us having any inaccurate, incomplete, inauthentic or otherwise deficient personal data which you or a Third Party Entity have provided to us. Please also let us know if you wish to withdraw any request.
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Get in touch
We would be happy to hear your views about our website and this Privacy Policy. Please let us know any questions, comments or clarifications you may have at info@theodorousalt.com.
Changes to our Privacy Policy
This Privacy Policy was last updated on 13/01/2023. We have the right to update the contents of this Privacy Policy from time to time to reflect any changes in the way in which we process your personal data or to reflect legal requirements as these may change. In case of updates, we will post the revised Privacy Policy on our website. Changes will take effect as soon as the revised version is made available on our websites.
