Privacy Policy

We’ve updated our website’s privacy notice to comply with the General Data Protection Regulation (GDPR), UK GDPR, and the Data Protection Act 2018. While our methods of collecting and using your personal data haven’t changed, we’ve clarified what data we collect, how we collect it, what we do with it, and your rights regarding your personal data. If you have any questions about the updated privacy notice, please contact us.

Introduction

Graystone S.a.r.l respects your privacy and is committed to protecting your personal data. This notice explains how we handle your personal data when you visit our website at https://cybertiro.com (the “Site”) and informs you of your privacy rights and how the law protects you.

1. Important Information and Who We Are

Purpose of This Privacy Notice

This notice provides information on how Graystone S.a.r.l collects and processes your personal data through your use of the Site, including any data you provide. The Site is not intended for children, and we do not knowingly collect data from children. Please read this notice alongside any other privacy notices or fair processing notices we may provide on specific occasions when collecting or processing personal data.

Controller

Graystone S.a.r.l is the data controller and responsible for your personal data. Our company is registered in England and Wales under company number 35597463 (VAT LU35597463), with a registered office at 44. Rue de I’ Industrier, L- 8069 Bertrange, Luxembourg. We are part of Graystone S.a.r.l.

You can contact us:

• By post: The UK Compliance Team, Graystone S.a.r.l, 44. Rue de I’ Industrier, L- 8069 Bertrange, Luxembourg
• By phone: +4598009284 (Calls cost no more than calls to geographical numbers and are included in your package’s inclusive minutes)
• By email: [email protected]

We have appointed a Data Protection Officer (DPO) responsible for overseeing questions about this privacy notice. Contact the DPO:

• By post: Data Protection Officer, Graystone S.a.r.l, 44. Rue de I’ Industrier, L- 8069 Bertrange, Luxembourg
• By email: [email protected]

Changes to the Privacy Notice and Your Duty to Inform Us of Changes

We may update this privacy notice periodically. Please check this page occasionally to stay informed of any changes. If there are significant updates, we may notify you via a message on the Site’s landing page. Ensure your personal data is accurate and current; inform us of any changes during your relationship with us.

Third-Party Links

The Site may include links to third-party websites. Clicking on these links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit.

2. The Data We Collect About You

Types of Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymized data.

We process personal data collected from you according to this privacy notice. For subscribers of Cybertiro or their administrators or employees, we process personal data according to the Privacy Notice in the terms and conditions applicable to the subscription, including use of the secure customer area (“Subscribers’ Area”).

We may use information we hold about you for:

• Processing and managing your Cybertiro subscription
• Collecting payments
• Providing information about our products, promotions, and special offers if you have consented

Data Collection Methods

We collect data through:

• Direct Interactions: You provide personal data (e.g., contact details) by filling out forms on the Site or corresponding with us by phone, email, or otherwise.
• Automated Technologies: As you interact with the Site, we automatically collect technical data (e.g., IP address, device type, screen resolution, operating system) and information about your visit (e.g., pages visited, links clicked).

Failure to Provide Personal Data

If you fail to provide required personal data, we may not be able to perform the contract for your subscription or respond to your queries.

3. How We Use Your Personal Data

We use your data for the following purposes:

• Subscription Management: To process and manage your Cybertiro subscription and provide access to the Subscribers’ Area.
• Communication: To communicate with you regarding your subscription and other matters.
• Internal Record Keeping: For our legitimate interests and to comply with legal obligations.
• Product and Service Improvement: To develop our business and inform our marketing strategy.
• Statistical Analysis: To study business trends and develop marketing strategies.
• Fraud Prevention: To comply with legal obligations.
• Debt Collection: To recover debts due to us.
• Marketing: To contact you about products, services, and events that may interest you, if you have consented.

For more details, see our Cookie Policy.

4. Disclosures of Your Personal Data

We may share your personal data with:

• Service Providers: Authorized service providers and third-party suppliers performing services on our behalf.
• Company Group: Other companies within the Graystone S.a.r.l Group for management and analysis.
• Other Organisations: In response to legal requirements, to establish or exercise our legal rights, to defend legal claims, or to prevent illegal activities or fraud.
• Prospective Buyers: In the event of a business sale or reorganization.

We ensure that all third parties respect the security of your personal information and treat it according to the law.

5. International Transfers

We may transfer your personal data outside the European Economic Area (EEA) and ensure adequate safeguards are in place to protect your data. Contact our DPO for more information on the specific mechanisms used for such transfers.

6. Data Security

We have implemented security measures to prevent your personal data from being accidentally lost, used, or accessed unlawfully. We limit access to your personal data to those who need it for business purposes and are subject to confidentiality. In case of a data breach, we will notify you and any applicable regulator as required by law.

7. Data Retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this notice or as required by law. For subscription data, see the Privacy Notice in your Cybertiro Terms.

8. Your Legal Rights

You have rights under certain circumstances, including:

• Access: Request a copy of your personal data.
• Correction: Request correction of incomplete or inaccurate data.
• Erasure: Request deletion of your data under specific conditions.
• Objection: Object to processing based on legitimate interests.
• Restriction: Request suspension of processing.
• Transfer: Request transfer of your data to another party.

To exercise these rights, contact us:

• By post: Data Protection Officer, Graystone S.a.r.l, 44. Rue de I’ Industrier, L- 8069 Bertrange, Luxembourg
• By email: [email protected]

You won’t be charged for these requests unless they are unfounded or excessive. We may need to verify your identity to process your request and will respond within one month. You also have the right to complain to the Information Commissioner’s Office (ICO), but we appreciate the chance to address your concerns first.

For more details, please visit www.ico.org.uk.