Privacy policy

This website is operated by WINTERSBERG BUSINESS LIMITED (registration number HE423686), 1 Constantinou Skokou, Capital Chambers, 5th floor, 1061 Agios Antonios, Nicosia, Cyprus. We are the controller of the personal data described in this policy.

For any question about this policy or your personal data, call us on +357 25 345 300 or write to us at the address above.

This website has no registration, online forms or user accounts. We process personal data in the following cases:

• When you contact us by phone or post — your name, the contact details you give us and the content of your enquiry.
• When you do business with us — the identification, contact and payment details of counterparties and their representatives that are needed to prepare and perform an agreement and to meet legal requirements.
• When you visit the website — technical data such as your IP address and browser type may be recorded in server logs by our hosting provider for security purposes.

• To answer your enquiry — our legitimate interest in responding to people who contact us, or steps taken at your request before entering into a contract.
• To enter into and perform agreements — performance of a contract.
• To meet accounting, tax, anti-money-laundering and other statutory requirements — compliance with our legal obligations.
• To keep the website secure and to establish or defend legal claims — our legitimate interests.

This website does not use analytics, advertising or other non-essential cookies. If that changes, we will ask for your consent first.

The “Open in Google Maps” link opens Google’s own website, where Google’s privacy policy applies.

We do not sell personal data. We share it only where necessary with:

• service providers that support our work, such as hosting and IT providers, who act on our instructions;
• professional advisers such as lawyers, accountants and auditors;
• banks and public authorities, where the law requires us to do so.

We aim to keep personal data within the European Economic Area. If a service provider processes data outside it, we rely on the safeguards required by law, such as the European Commission’s standard contractual clauses.

• Enquiries that do not lead to an agreement — only for as long as needed to deal with your enquiry.
• Data relating to agreements — for the term of the agreement and afterwards for the period required by applicable law.

Under the General Data Protection Regulation you have the right to:

• obtain access to your personal data and a copy of it;
• have inaccurate data corrected;
• have your data erased or its processing restricted, where the law allows;
• object to processing based on our legitimate interests;
• receive the data you gave us in a portable format;
• withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, call us on +357 25 345 300 or write to our registered office. We will reply within one month.

If you believe your personal data has been handled unlawfully, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus (www.dataprotection.gov.cy), or with the data protection authority of the EU country where you live.

We may update this policy from time to time. The current version is always available on this page.