Privacy policy

Privacy Policy

A. Overview

On May 25, 2018, new European data protection law known as the General Data Protection Regulation (“GDPR”) came into effect. The GDPR defines a specific framework and set of rules to protect individuals within the European Economic Area (EEA) with regard to the processing of their personal data.

Any natural or legal person, be it an individual, a company or an organization, that collects, stores, manipulates or otherwise processes personal data (hereinafter collectively referred to as “processing”) is affected and must take appropriate technical and organizational measures undertake such processing to comply with the provisions of the GDPR. The GDPR therefore affects any natural or legal person or entity that carries out the processing, whether located inside or outside the European Union, as long as these natural or legal persons process personal data for persons located in the European Union .

This Privacy Policy has been prepared by Mission-Freedom (Cyprus) Ltd (hereafter referred to as „M-F LTD“) with the aim of helping our customers, employees, suppliers, partners and any other interested party to understand the measures taken by we have taken and are performing as part of our own GDPR compliance program and practices. When we mention M-F LTD „we“, „us“ or „our“ in this Privacy Policy, we are referring to Mission Freedom (Cyprus) Ltd, which is the relevant legal entity responsible for processing your data.

B. AAM as data controller or data processor

In the context of the GDPR, M-F LTD is a data controller (e.g. in relation to its own employees and external contractors and partners) and a data processor in relation to accessing and processing personal data of our customers‘ borrowers. M-F LTD undertakes to conduct all processing of personal data in a transparent and fair manner, based on processes that are inherently private and using appropriate technical and organizational measures in support of security and privacy objectives. This obligation applies throughout the processing life cycle of personal data, including during collection, transmission, use and storage.

M-F LTD also undertakes to take all reasonable steps to ensure that the processing of personal data is based on a valid legal basis. Where M-F LTD is the data processor, this obligation generally means that in all cases we rely on the data controller to provide a valid legal basis 1 for the processing we carry out in that capacity. We also rely on the relevant data controllers to notify us in a timely manner if the status of these legal bases changes.

In certain other cases, the processing we carry out – in particular where we are the data controller – is required by law. Alternatively, the processing of personal data may be carried out to perform a contract between MF LTD and the individuals involved; or may be based on data subject consent. In certain cases, the processing of personal data may be based on our legitimate interests, in particular those arising from our professional duties and responsibilities and/or other legal framework to which our work is subject.

C. On what basis do we justify the processing of your personal data

According to Article 6 of the GDPR, the processing of personal data is lawful if at least one of the processing bases described below applies:

the existence of proven consent of the data subject (i.e. natural living person) whose personal data is being processed

Processing is necessary for entering into a contract to which the data subject is party, or in order to take steps at the request of the data subject, before or after the entry into force of a contract

The processing is necessary for compliance with a legal obligation on the part of the data controller or data processor

The processing is necessary for the purposes of the legitimate interests of the data controller or data processor, unless such interest outweighs the interests or fundamental rights and freedoms of the data subject that require the protection of personal data, in particular when

the person concerned the data is a child

the processing is necessary to protect the vital interests of the data subject or another natural person

the processing is necessary for the fulfillment of an obligation that is in the public interest or in the exercise of official authority vested in the Company.

Based on the foregoing, M-F LTD seeks to ensure that any type of processing of personal data that we carry out is based on one or more of the legal bases set out above. With very limited exceptions, the legal bases applicable to our operations and the resulting processing of personal data that we carry out are those described in the first four bullet points above.

D. How do we collect personal data?

In the vast majority of cases, we receive the personal data from our customers, e.g. B. Banks or other financial institutions on whose behalf we provide debt collection and related services and/or property owners who, for the purpose of the bid for and/or sale of said properties, are and/or are duly represented by and /or has duly authorized AAM under the terms of a Power of Attorney granted for the above purpose. In other cases, we receive personal data directly from the data subject (ie the “data subject”). Typically, such personal information is requested when we establish a relationship with the data subject, or in some cases at a later point in time after we have started interacting with the data subject. There are a variety of ways in which we receive personal information, including electronic records (e.g., received from a bank), paper-based forms, electronic self-service facilities (e.g., on a website), or through email communications or physical exchanges of contact information (e.g. a business card).

We may also collect Personal Information in an automated manner when data subjects interact with resources we provide (website logs, email delivery tools, mobile applications, access control systems, time and attendance applications, CCTV systems, etc.). Our processes may also result in improvements to the personal information we process about data subjects as a result of the interactions and/or transactions between data subjects and MF LTD.

Finally, in a comparatively limited number of cases, we receive personal data from data subjects from sources other than our customers. Key examples include references from previous employers during an application process, legitimate third-party databases during Know Your Customer (KYC) checks that we may conduct, and other lawful services of a similar nature. Where the data subject is a representative of one of the borrowers of a loan that falls under our debt collection services, we may receive their personal data directly from their employer/client or from other colleagues of the data subject.

E. Why we process personal data

Below we describe the main ways in which we use personal data and the legal bases of processing on which we rely for such processing. We have also identified what our legitimate interests are, where appropriate.

In general, we use the Personal Data we collect to help AAM better understand each data subject in each case and to enable us to achieve the objectives of our Services while respecting the data subjects‘ privacy rights. In this regard, we use personal data to:

Deliver our services through interactions with data subjects in the most appropriate manner relevant and necessary to the objectives of our services

Providing customer service to data subjects, e.g. B. Responding to inquiries and carrying out any action or request agreed between us

personalize our services, such as B. administering, managing and selling real estate assets, and to provide users with a personalized experience on our websites and other electronic assets

Offer website content that includes articles that returning visitors might like and to track their likes and choices

Contacting data subjects about accounts we may maintain in relation to them and notifying them of important changes 

to inform genes that affect them

Manage surveys and questionnaires

Verifying and verifying the identity of individuals who interact with us and preventing, mitigating or detecting and investigating criminal, fraudulent or illegal activity and

Process purchases and payments and provide assistance where necessary.

Please note that your personal data may be processed for more than one lawful purpose. If you require further information about the specific legal basis we are relying on to process your personal data, please send us your specific request to dpo@cy.altamiraam.com.

F. How long we keep your personal information

Personal data may be retained by us in physical and/or electronic form and processed in accordance with the principles of purpose limitation; data minimization; data accuracy; integrity and confidentiality; and Retention Limitation.

In relation to storage in particular, the technical and organizational measures operated by M-F LTD are designed in such a way that personal data is only kept for as long as is necessary to fulfill our legal, contractual, professional and/or regulatory obligations, and – if longer – in accordance with the provisions of the specific legal basis of processing related to each category of data subjects.

After the applicable retention periods have expired, defined operational processes or routines result in personal data being deleted or destroyed in electronic and physical form in a controlled manner. In certain circumstances, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes. In this case, we can use this data indefinitely without further notice to you.

G. Sharing of Personal Information

Your personal information may be accessed within M-F LTD or disclosed internally on a need-to-know basis based on user access rights management processes.

Your personal data may also be accessed and/or accessed by third parties, including suppliers and consultants, as described below. When this happens, we take specific measures and steps to protect this shared information, as set out in the “M-F LTD SUBPROCESSORS” section of this Privacy Policy. In summary, such measures and steps include requiring all such third parties to respect the security of your personal information and to treat it in accordance with applicable laws and the GDPR. We do not permit our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specific purposes and in accordance with our instructions. The types of third parties that may typically be involved in the processing of your personal data include:

Service providers to M-F LTD acting as data sub-processors based in the EEA, providing IT, system administration services, payment providers to facilitate financial transactions, fulfillment providers, marketing and communication service providers to personalize your experience and to communicate with you.

M-F LTD professional advisors including EEA based lawyers, bankers, auditors and insurers providing consultancy, banking, legal, insurance or accounting services.

Tax and customs authorities, regulators, law enforcement agencies and other authorities acting as processors or joint controllers located in the EEA, who have the right to request reporting of processing activities in certain circumstances and otherwise to defend legal claims.

Market researchers, fraud prevention agencies and data analysis providers.

In relation to HR data in particular, these may be shared with payroll and provident fund providers; accountants & auditors; recruitment agencies; call center providers; and HCM consultant.

In addition, there are circumstances where we may need to share your personal information with third parties in order to administer our business and deliver our services. In this context, we may disclose your personal data:

to third parties to whom we may sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other companies. If such a change occurs in our company, k

the new owners may use your personal information in the same manner as described in this Privacy Policy

to a third party if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, or in order to enforce or apply our legal rights. In this case we may share your personal data with our supervisory authorities and law enforcement authorities in the EEA or with our legal advisers and

if it is necessary to protect the rights, property or safety of M-F LTD, in which case we may share your personal data with our legal counsel and other professional services companies.

We may also share your personal information with national authorities and governmental bodies where legislation allows or compels us to do so.

H. Categories of personal data processed

As part of our operational business processes and routines and depending on the specific relationship and/or existing commercial or other engagement, we may process personal data for one or more categories of data subjects as tabulated below (not a definitive or exhaustive list).

 

business relationship

Type of personal data processed

Legal basis

a.

Corporate Borrowers and/or Guarantors

The information set out below relates to business relationships between M-F LTD and corporate borrowers and/or guarantors which involve, entail or require processing of personal data of directors, officers and employees of employees or legal representatives of corporate borrowers and/or guarantors of the relationship and other natural persons responsible for managing or conducting business between the two parties.

Full name

gender

age and birthday

Identify and position/role information

Location information (physical address and electronic location data)

Business email address and phone numbers

Identification numbers such as ID cards, passports, driver’s licenses, catchy words that support authentication processes (electronic or physical).

Mobile phone numbers (business or personal)

Negotiation power and binding of the borrower to final decisions, financial inquiries, execution of financial transactions, etc.

Verification data (only in certain cases)

contract

b.

Personal Borrowers and/or Guarantors

In connection with the processing of personal data of personal borrowers and/or guarantors, in particular in connection with M-F LTD debt restructuring services, the following personal data are processed:

Full name

gender

age and birthday

Employment information such as occupation, professional or other qualifications, employer, title and position

Mobile, business and home phone numbers

Location information (physical address and electronic location data), place of residence, delivery, work

Electronic identifiers such as IP addresses, usernames, emojis

Identification numbers such as ID cards, passports, driver’s licenses, catchy words that support authentication processes (electronic or physical).

Economic (like value of assets or guarantees or salary, income margins)

Physiological and/or health or medical information, such as B. Physical disabilities (which are special categories under the GDPR and for which specific measures are taken to create a valid legal basis for processing)

Nationality data (which are special categories under the GDPR and for which specific measures are taken to create a valid legal basis for processing).

contract

c.

applicant

Resume Information

contact details

Previous Employment Records

referee

Clear police/criminal records

Work Permit Information

Skills & professional and academic achievements (e.g. languages, academic degrees

Medical information (only for certain vacancies / jobs)

approval

Legitimate interest (for application information that the applicant voluntarily transmits to us, unsolicited by M-F LTD

i.e.

Employees, contractors & workers

„Basic Information“ [full name, ID, social security number, address, marital status, children, age, gender, personal emails]

“Recruitment Dates” [academic credentials, experience, previous employers, references]

Evaluation and performance information [salary, appraisals, promotions, disciplinary records, complaints and resulting

ongoing investigations, appeals against personnel decisions]

Professional data [languages, specialist knowledge, driving licence]

Operational data [sales, travel locations, training records, absences, timesheets/arrival and departure times, passports and IDs to support business travel arrangements]

Financial data [payroll, wage-related, life insurance data, marital status, bank details]

contract

e.

Former employees, contractors and workers

In the case of former employees, contractors or workers, the types of personal data listed under (b) above will be processed with the following differences:

Financial data is retained for tax and regulatory purposes for a period of 14 years after termination or resignation

All other data will be retained for 10 years after departure or termination for archival and/or reference purposes

labor and social security law

employment/employment contracts

f.

relatives and relatives

Full name, mobile phone details, relationship to employee, contractor or worker (next of family)

Full name, gender, age and date of birth

employment/employment contracts

G.

Board Members and Directors

Manager – as described under „Employee“ above; and also regulatory data such as registration with a relevant regulatory authority, your regulated status and any regulatory references

Non-Executive – full name, mobile phone details, personal email address, resume information, other full or part-time employment/service positions, financial information such as bank account details, regulatory information such as registration with a relevant regulator, your regulated status and any regulatory references

legislation

Legitimate Interest

H.

suppliers and subcontractors

The information set out below relates to business relationships between M-F LTD and its suppliers (e.g. collection agencies and/or estate agents) which involve, entail or require the processing of personal data of directors, officers and employees of MF LTD’s suppliers . Employees involved in the relationship and other individuals responsible for managing or conducting business between the two parties.

Identify and position/role information

Location information (physical address and electronic location data)

Business email address and phone numbers

Mobile phone numbers (business or personal)

Authority to place orders, make financial inquiries, conduct financial transactions, etc.

Verification data (only in certain cases)

contract

Legitimate Interest

I.

Buyers of real estate

As part of its services, M-F LTD is responsible for operating and managing processes through which real estate assets are offered for sale to interested buyers and for completing such sales through various means. As part of these processes, M-F LTD carries out the following processing of personal data:

Full name

gender

age and birthday

Employment information such as occupation, professional or other qualifications, employer, title and position

Mobile, business and home phone numbers

Location information (physical address and electronic location data), place of residence, delivery, work

Electronic identifiers such as IP addresses, usernames, emojis

Identification numbers such as ID cards, passports, driver’s licenses, catchy words that support authentication processes (electronic or physical).

Economic (like value of assets or guarantees or salary, income margins)

Physiological and/or health or medical information, such as B. Physical disabilities (which are special categories under the GDPR and for which specific measures are taken to create a valid legal basis for processing)

Nationality data (which are special categories under the GDPR and for which specific measures are taken to create a valid legal basis for processing).

 

j.

visitors and guests on site

Full name

employer

Person(s) to visit.

signature

Passport number used and access logs

Camera/CCTV footage

Legitimate Interest

k.

event attendee

Full name

employer

Job Position and Title

work/office location

Work and mobile phone numbers

E-mail address (professional and/or private)

photos and images

approval

l.

general public

Full name, email, phone numbers, employer, title (for cases where you initiate electronic communication and/or correspondence with us)

photos and images

from you from CCTV cameras that we operate

License Plate

Legitimate Interest

m.

website user

Full name

gender

E-mail address (business or private)

Mobile and business phone numbers

Location information (physical address and electronic location data)

Electronic identifiers such as IP addresses, usernames, emojis

approval

Contract (if this information is collected for the purpose of entering into a contract with you)

.

I. Technical and organizational measures to protect personal data

The GDPR imposes obligations on data controllers and data processors, which in several cases depend on the consistent implementation of relevant measures and controls in their own operations and those of their data processors. It is our policy to process personal data with due regard for the security, privacy and protection of the data we receive, store and process. This privacy statement explains the types of such technical and organizational measures that we take to increase the level of protection of the personal data we process. These measures also serve to maximize control over data protection under the GDPR and aim to provide a level of security appropriate to the risks involved.
It is important to note that the nature of our business model dictates that M-F LTD invariably uses its customers‘ (i.e. the banks) systems and technology. In any case, the relevant technical and organizational measures described below are managed and operated and are under the full control and responsibility of these customers. For this purpose, M-F LTD relies on the adequacy of the design of the related mechanisms and controls, as well as on their operational effectiveness, for any processing of personal data carried out partially or totally through the use of such systems and technologies, since they concern the day-to-day operations of M-F LTD Operation.

As part of our overall data protection framework, M-F LTD has appointed a Data Protection Officer (DPO) in line with GDPR requirements. Our DPO can be contacted at info@mission-freedom.eu.

All of our employees, including service agents and/or account managers and account managers, regularly attend GDPR-specific awareness sessions to keep their understanding of the GDPR up to date and how it may affect our various operations affecting the personal data we process. to maintain.

We support the implementation of instructions lawfully given to us by third-party companies (such as banks and other customers of ours) in relation to data subjects for whom such third-party companies are data controllers exercising their rights under the GDPR, as long as the instructions override our own legal, professional or official obligations. In such cases, we will endeavor to inform the third party of the options available to them.

We strive to ensure that third parties supporting M-F LTD operations or systems or otherwise involved in our processing operations of personal data have and implement the necessary technical and organizational measures to protect the security and confidentiality of personal data.

Our Incident Response Management and Breach Notification Procedures are designed to include escalation of identified incidents to our Data Protection Officer, who has the authority and experience to involve related senior management when such incidents involve personal data of one or more of M-F LTD’s affected companies and / or affect people .

Our internal policies state that cross-border data transfers of personal data that we have access to and/or that we process during a client engagement are not permitted. Where such cross-border data transfers are or become necessary, we will endeavor to ensure that a valid legal basis for such transfers under the GDPR is evident.

Our recruitment and ongoing staff training and development, as well as the assessment and disciplinary processes we implement, are designed to promote and maintain a high standard of professional ethics and competence at all levels of M-F LTD, consistent with industry standards and our profession and legal responsibilities .

In addition, M-F LTD operates several additional technical and organizational measures to protect the privacy of personal data that we collect, s

save and process. These measures include logical access controls and user rights management aimed at minimizing access to personal (and other M-F LTD) information and data to authorized M-F LTD personnel only. We also use user access credentials management with enforced frequent changes, password complexity and maximum/minimum lengths, restrictions on reusing the same passwords, etc., complemented by a structured process to regularly review and confirm continued business needs for such personal data.

In addition, M-F LTD uses purpose-specific technologies and tools (such as firewalls, intrusion prevention, mail security gateways, data leakage prevention (DLP) sandboxing technologies, etc.), all designed to monitor and manage the security of its electronic perimeter. M-F LTD also has an active and continuous security, server and endpoint device patch management program to address newly released threats and benefits from using endpoint malware protection on laptop, server and desktop devices Level. Finally, we also use technologies that encrypt data in motion and at rest to avoid privacy risks in the event of hardware theft or loss.

A significant part of our business involves third parties (legal or natural persons) involved and/or providing assistance in many aspects, including without exception the processing of personal data. The relevant technical and organizational measures that we use and operate with the aim of improving and protecting privacy are described in the next section.

J. Sub-processors of M-F LTD

Like almost all organizations, M-F LTD uses third parties as part of its business processes and routines. These third parties include legal and/or natural persons who provide services and/or products related to technology, debt collection, human resources management, marketing, facility management, accounting, legal and other areas that may affect the processing of personal data (including Processing as specified in this Privacy Policy).

When necessary in connection with such processing of personal data, our selection process and criteria for working with third parties (suppliers, vendors or other consultants) include considering and evaluating the level of GDPR readiness and compliance of those third parties. In this regard, we seek to ensure that third parties supporting M-F LTD operations or systems, or otherwise involved in our personal data processing operations, have and implement the necessary technical and organizational measures to protect the security and confidentiality of personal data . Therefore, wherever relevant, our contracts with third parties contain specific provisions aimed at:

Identify the third party’s respective role as data processor or sub-processor for M-F LTD

Definition of the GDPR-related obligations of the third party to M-F LTD, including:

• Enforcement of M-F LTD’s data retention periods (which themselves reflect those of our customers as explained in this Privacy Policy)
• Integration of third-party Incident Response Management process with M-F LTD
• Determine permitted access and connectivity methods for remote support (if relevant and required)
• Definition of the processes through which M-F LTD shall issue relevant instructions to the third party in relation to the expected and required processing of personal data (if applicable).
• Specification of technical protection methods and treatment of third party replicas of the software system, where relevant (e.g. for quality assurance and/or development purposes), including encryption and/or pseudonymisation of personal data
• Prohibit the third party from conducting cross-border data transfers except with the express prior written consent of AAM (which itself is subject to, consistent with, and required to comply with, contractual and other obligations of M-F LTD to data subjects).

Grant to M-F LTD the right to perform periodic audits (including surprise audits) against the execution of GDPR related processes that the third party supports and/or operates on behalf of M-F LTD. In this context, M-F LTD also tries to review pro

esse to implement with the third-party sub-processors to jointly regularly monitor the effectiveness of the execution of data protection processes and routines so that such processes become and remain “private by design”, where applicable.

Persons whose data is processed have rights defined under the GDPR. In particular, the GDPR requires data controllers and data processors to implement the necessary processes and mechanisms to support the exercise by data subjects of the following rights, the precise definitions of which have the meaning assigned to them by the GDPR:

Right to information about the processing of personal data carried out and the reason for this processing

Right to information about the personal data processed about you

Right to rectification, which enables individuals to request that their data be rectified or supplemented

Right to object to a certain type of processing in certain circumstances

Right to object to automated processing or profiling where automated processing leads to decisions which, in the data subject’s opinion, do not adequately reflect the specifics of the case at hand

Right to withdraw consent, which enables a data subject, in certain circumstances, to provide and withdraw previously given consent for a specific type of processing

Right to data portability, which enables the transfer of personal data being processed by one data controller to the data subject or directly to another data controller in an electronic, machine-readable format

Right to erasure (“right to be forgotten”), which entitles a data subject to request the erasure of their personal data in certain circumstances.

You do not have to pay a fee to access your personal information (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. In extreme cases, we may even refuse to comply with your request in such circumstances.

K. Your rights

Persons whose data is processed have rights defined under the GDPR. In particular, the GDPR requires data controllers and data processors to implement the necessary processes and mechanisms to support the exercise by data subjects of the following rights, the precise definitions of which have the meaning assigned to them by the GDPR:

Right to information about the processing of personal data carried out and the reason for this processing

Right to information about the personal data processed about you

Right to rectification, which enables individuals to request that their data be rectified or supplemented

Right to object to a certain type of processing in certain circumstances

Right to object to automated processing or profiling where automated processing leads to decisions which, in the data subject’s opinion, do not adequately reflect the specifics of the case at hand

Right to withdraw consent, which enables a data subject, in certain circumstances, to provide and withdraw previously given consent for a specific type of processing

Right to data portability, which enables the transfer of personal data being processed by one data controller to the data subject or directly to another data controller in an electronic, machine-readable format

Right to erasure (“right to be forgotten”), which entitles a data subject to request the erasure of their personal data in certain circumstances.

You do not have to pay a fee to access your personal information (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. In extreme cases, we may even refuse to comply with your request in such circumstances.

L. Inquiries and Complaints

M-F LTD undertakes to acknowledge, investigate and respond to all inquiries and complaints it receives from an individual who considers that they are affected by the processing of their data by M-F LTD. To submit any such request or complaint, please contact us at dpo@cy.altamiraam.com and we will endeavor to respond to your request as quickly as possible within the 30 day window required by the GDPR.

if you

If, despite our responses and actions taken to address your concerns, you are not satisfied, you have the right to raise the matter with the Cyprus Data Protection Commissioner, whose offices are at 1 Jason Street, 2nd Floor, Nicosia 1082. The Office of the Data Protection Commissioner can be reached on +357 22818456 and her email address is Commissioner@dataprotection.gov.cy.

M. Other important information

This Privacy Policy does not alter in any way except the obligations and responsibilities of M-F LTD or its customers, employees, suppliers or partners expressly defined herein, all of which are governed by the respective contracts (if any) and related agreements between M-F LTD and M-F LTD of each of these customers, employees, suppliers or partners.

N. Cookie Policy

1. What are cookies?

The Mission-Freedom (Cyprus) Ltd website uses cookies and other files with similar functionality (hereinafter the „Cookies“).
Cookies are small data files that are sent to the user’s computer, mobile phone or other access device when you visit a website and that allow you to obtain information about your browsing or a code that uniquely identifies the user be able.

2. Types of cookies and their purpose

Browsing this website uses session cookies and persistent cookies, which in turn may be your own or third-party cookies.
Session cookies are cookies designed to collect and store data while the user accesses a website. They are usually used to store information related only to the provision of the service requested by the user on a single occasion.

Persistent cookies are a type of cookies in which the data is stored in the end device and can be accessed and processed for a period of time set by the person responsible for the cookie, which can range from a few minutes to several years.

OWN COOKIES: Those created or managed by the person responsible for the Mission-Freedom (Cyprus) Ltd website use persistent proprietary cookies for analytical purposes. The information collected is used to measure activity on the website, to create user navigation profiles and to introduce improvements based on the analysis of the data used by the users of the service.

THIRD PARTY COOKIES: These are managed by advertising service providers, social networks and analytics unrelated to Mission-Freedom (Cyprus) Ltd. have to do.
Below are more details on third parties who can configure and access cookies (not exempt from information and consent) . Equipment and the purposes for which the stored information is used:

Below are more details on third parties who can configure and access cookies (not exempt from information and consent) on their devices and the purposes for which the information stored is used:

3. Disabling or removing cookies

Most web browsers allow you to manage user preferences regarding the use of cookies at any time. The user can set their browser to refuse cookies or delete certain cookies at their own discretion.

For the configuration of cookies, the user can access:

Google Chrome : Tools » Settings » Show advanced options » Content settings » Cookies » Block data from third-party websites and cookies.

Mozilla Firefox: Tools » Options » Privacy » History » Use custom configuration for history (uncheck all boxes).

Microsoft Edge : More (…) » Settings » Clear browsing data » Choose what to clear (check the box next to each type of data to clear).

Internet Explorer: Tools » Internet Options » Privacy » Internet Zone Settings (upload the navigation bar to block all cookies).

Safari: Edit » Preferences » Privacy » Block Cookies (select „Always“).

Opera : Menu » Settings » Privacy and security » Cookies section (select Block third-party cookies and site data).

The user can revoke their consent to the use of cookies in their browser through the above-mentioned notices or by installing a refusal system (“opt-out”) in their web browser. Some third-party providers facilitate this opt-out through the following links:

Sharethis opt-out: https://www.sharethis.com/legal/privacy/#sthash.lzSwStYB.dpbs

Deactivation of Doubleclick: https://www.google.com/ads/preferences/ht

ml/opt-out.html

Opt-out of Youtube : https://www.google.com/settings/ads?hl=es&sig=ACi0TCg66O2u8SrGfhxrWbHumebpQPEQXbsqYB_nK30txDbdrtsOon2mmXUNCAxqvklAkfpCtCh65 BMWV9cTtnayw9r00joLsijkFY_LrT-GkjnrTpo049eIN_9XHDCNqA0i1kZ6Rc9YZP4YBXPbeqX2LlE_iuolhMJuMWtFlhmlAvmm1LNSOjfq-9uWPcfCkM_C-rjnEciM

The user must keep in mind that some functions of the content of this website are only available if the installation of cookies is allowed in your browser. If you decide not to accept or block certain cookies (depending on their purpose), this may affect the normal functioning of the site, in whole or in part, or prevent access to some of its services.

4. Updates and Changes in the Cookie Policy

Mission-Freedom (Cyprus) Ltd may amend this Cookies Policy based on new legal or regulatory requirements or to align this policy with the instructions of the Cyprus Data Protection Commissioner.

If significant changes are made to this Cookie Policy, the user will be informed either by an informative notice on our website or by email for registered users.

If you would like more information about how we use cookies, you can contact us at: contact@mission-freedom.eu.

Glossary and useful definitions

expression

definition

1. Personal Data

Personal information, also referred to as „personal information“ (or „PII“), is any information relating to an identified or identifiable living natural person (the „data subject“).

2. Legal Basis for Processing

The basis on which the processing of personal data may be based can be one of the following:

the data subject’s consent to the processing of their personal data

Processing is necessary for entering into a contract to which the data subject is party, or in order to take steps at the request of the data subject, before or after the entry into force of a contract
The processing is necessary for compliance with a legal obligation on the part of the data controller or data processor
The processing is necessary for the legitimate interests of the data controller, unless that interest outweighs the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child

the processing is necessary to protect the vital interests of the data subject or another natural person

the processing is necessary for the fulfillment of an obligation that is in the public interest or in the exercise of official authority vested in the Company.

3. Legitimate Interest

Our legitimate interests in conducting and administering our business, to enable us to provide you with the best services and/or products and a safe and private experience. When deciding to process personal data on the legal basis of legitimate interest, we want to make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we do so.

As a general rule, we do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law to do so).

4.Data Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, decides on the purposes and means of the processing of personal data.

5. Data Processor

A natural or legal person, public authority, agency or other body that processes personal data on behalf of a data controller.

6. Data Protection Officer

A data protection officer (or “DPO”) is a security leadership role required by the GDPR. The DPO is responsible for (a) overseeing data protection strategy and implementation within an organization; (b) ensuring compliance with GDPR requirements; (c) advising the data controller or data processor and its employees in relation to the processing of personal data; and (d) collaborating with data protection authorities and regulators on all privacy and data protection matters.

7. Cross-Border Data Transfers

Transfer of personal data outside the European Economic Area in physical and/or electronic form.

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