Privacy Policy

Last updated: 23 May 2018

 

Action Digital LTD is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy notice.
This Privacy Notice includes all the relevant information regarding the processing of your personal data and makes you aware of how and why your personal data will be used and how long it will usually be retained for.

Action may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

Who we are
Action Digital LTD, having its registered address at Action Global Communications LTD at Kondilaki 6 Street, 1090, Nicosia, Cyprus , herein after referred as “Action” or “We” or “us” is a data controller within the meaning of the General Data Protection Regulation (“GDPR”) who collects, holds and process your personal data in accordance with the GDPR legal obligations. This means that we are responsible for deciding how we hold and use personal information about you.
We’ve appointed a Data Protection Officer which can be contacted at [email protected].

What we collect
We may collect the following information:

  • First, Last Name
  • CV
  • Contact information including email address and telephone number
  • other information relevant to customer surveys and/or offers

How we collect personal information
We collect personal information directly when you provide it to us or automatically as you navigate through the website, through submitting the contact form/subscribing to our newsletter and sending your CV Application.

We may also collect personal information from telephone calls and/or other correspondence with you.
We may receive personal information about you from other sources. In particular:
Third party sources and/or partners, in regards to a service you have subscribed with those partners.

What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Internal record keeping.
  • We may use the information to improve our products and services.
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
  • Responding to your queries and helping
  • To Fulfil a contract
  • For purposes which is required by law
  • For recruitment purposes
  • For the purposes of responding to request by government, a court of law, or law enforcement authorities conducting an investigation.

Which is the legal basis of processing your personal information
We will only use your personal data only when we have a legal basis to do so. Most commonly, we will collect, use and process your personal data in the following circumstances:

  • Where we need to perform the contract we have entered into with you;
  • Where you provided us with your consent;
  • Where we need to comply with a legal obligation ;
  • Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests. Example of legitimate interests are managing our relations with third parties such as clients, vendors and business partners, provision of our services to clients and preservation of security, confidentiality and integrity of our systems
  • We may also use your personal data where we need to protect your interests (or someone else’s interests).;

How we might share your personal information
In order for us to deliver our services, we may transfer your personal data to third parties such as (but not limited to):

  • Subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular:
  • Website hosting provider which are located in the EU
  • Website developers which are located in the EU
  • Marketing and Analytics services which are located in US
  • Internally through our international network and offices.
  • Business partners and affiliates internal business purposes or to provide you with a service that you have requested.
  • Our Professional advisors
  • Regulators or government authorities in connection with our compliance procedure
  • A third party to respond to requests relating to criminal investigations or alleged suspected activity
  • A rights holder in relation to an allegation of intellectual property infringement or any other infringement
  • Other recipients where we are authorised by law to do.

Where we transfer and/or store your personal information
We are based in Cyprus so your data will be processed in Cyprus and the EU. Some of the recipients we have described above and to whom we disclose your personal information, are based outside Cyprus and the EU in places like the GCC, CIS, and North Africa. We only transfer personal data outside the European Economic Arear in compliance with the GDPR and especially when there is an adequacy decision of the Commission or in the absence of such decision we use Standard Contractual Clauses or other appropriate safeguards such as binding corporate rules to ensure that the transfer will be in compliance with the requirements of the GDPR. In order to protect your information, we take care where possible to work with subcontractors, service providers, business partners, affiliates and professional advisers who we believe maintain an acceptable standard of data protection and security compliance.

Security
We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Marketing Choices regarding your personal data
Where we have your consent to do so (e.g. if you have subscribed to our newsletter or have consented that you’d like to hear about our offers, courses, services, news and educational blogs), we send you marketing communications by email about courses and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future at any time by clicking the ‘unsubscribe’ link in the footer of any such email communication you receive from us, or by contacting us at [email protected]. In doing so you exercise your right to withdraw your consent without affecting the lawfulness of the processing based on consent before withdrawal.

Cookies and Web Analytics
For more information on how we use cookies see our Cookie Policy

When you visit our website, there is certain information that is recorded which is generally anonymous information and does not reveal your identity. If you are logged into your account, some of this information could be associated with your account. We are talking about the following kinds of details:

  • Your IP address.
  • The domain name you requested.
  • The name of your internet service provider (ISP) is sometimes captured depending on the configuration of your ISP connection.
  • The date and time of your visit to the website.
  • The length of your session.
  • The pages which you have accessed.
  • The number of times you access our website within any month.
  • The file URL you look at and information relating to it.
  • The website which referred you to our website.
  • The operating system which your computer uses.

Occasionally, we will use third party advertising companies to serve ads based on prior visits to our website. For example, if you visit our website, you may later see an ad for our courses and services when you visit a different website. Read more about your options in our Cookie Policy
We are using Google Analytics for tracking of our website traffic and the user data retention period is 26 months.
You also have choices about cookies, as described in our Cookie Policy . By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies you may not be able to access all or parts of our website.

How long we keep your personal information
We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations (e.g. for Cyprus corporation tax purposes, records should be kept 6 years from the end of the accounting period). If you no longer want us to use your personal information or to provide you with any services, you can request that we erase your personal information and close your account. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Your rights
According to GDPR you have certain rights with respect to your personal data. Action is committed to facilitate the exercise of your rights and below we present to you your rights and how you can exercise them.

You have the right to:

  • request access and rectification of your personal data;
  • to request us to erase your personal data under certain circumstance;
  • request restriction of the processing activity under certain circumstances;
  • object to the processing activity under certain circumstances;
  • data portability.

You can exercise your rights by contacting us either via email to [email protected] outlining your request or by calling us on (+ 357) 22 818884.

Children under the age of 18
The Website is not aimed at children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, please do not use our services or provide any information to us through the Website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 , please contact us at [email protected].

Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Complaints
If you have any questions about our Privacy Policy or the way in which we have been managing your personal information or you wish to exercise any of your legal rights as these deriving by the GDPR, please contact us by email at [email protected].
In any event, you have the right to lodge a complaint with the supervisory authority in Cyprus which is Office of the Commissioner for Personal Data Protection

When we need to update this policy
We may need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

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Cookie Policy

This is the Cookie Policy for Action Digital, accessible from actionprgroup.com

What Are Cookies
As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

For more general information on cookies see the Wikipedia article on HTTP Cookies.

How We Use Cookies
We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

  • Email newsletters related cookies
  • This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
  • Surveys related cookies
  • From time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.
  • Forms related cookies
  • When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

Third Party Cookies
In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

  • This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
  • For more information on Google Analytics cookies, see the official Google Analytics page.
  • From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
  • As we sell products it’s important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price.
  • We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; {List the social networks whose features you have integrated with your site?:12}, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

However if you are still looking for more information then you can contact us through one of our preferred contact methods:
Email: [email protected]

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