1. Why Do You Need this Privacy Notice?
We encourage you to carefully read this Privacy Notice as it provides you with information about your personal data being processed in connection with:
а) your access to and use of our website available at https://chisw.com, including any of its subdomains (the “Website”);
b) discussions for evaluating or pursuing certain business relationships and transactions with us (the “Business Relationship”) when either, we (including our representatives) contact you, or you reach us (including our representatives) for these purposes; and
c) your access to and use of our social media networks, such as LinkedIn profile, Twitter, Facebook and Instagram accounts (the “Social Media Channels”). Links to our Social Media Channels are provided on the Website.
This Privacy Notice does not govern processing of your personal data if you act as our team member or candidate. The latter case is governed by another document, which is provided to you by us if and where applicable.
In this Privacy Notice personal data and personal information are used as synonyms and mean any information that directly or indirectly identifies you as an individual. In this Privacy Notice we explain which types of personal data we hold on you, how we collect and process such data, how long we keep it, and so on.
2. Who Are We and How to Reach Us?
When we say “we”, “us”, or “our”, we mean CHISW Development LTD. “You” or “your” refers to you as (i) a visitor of the Website, (ii) a person who we contact or who reaches us regarding the Business Relationship, (iii) a person who accesses and uses our Social Media Channels, or (iv) any other person if we process your personal data in accordance with this Privacy Notice, as may be informed by us.
With respect to personal data collected as outlined in Section 1 above, we act as a data controller or joint data controller, depending on applicable circumstances as described below in this Privacy Notice.
We respect your privacy and are committed to protecting your personal data. Therefore, we process your personal data in accordance with this Privacy Notice and we endeavour to comply with the applicable data protection legislation, which includes the General Data Protection Regulation, also known as the GDPR (the “Applicable Legislation”).
If you have any questions regarding this Privacy Notice or the processing of your personal data, contact us via firstname.lastname@example.org.
3. What Are Our Principles?
Lawfulness. We endeavour to process personal data in accordance with the Applicable Legislation and only on the basis of the appropriate legal grounds.
Fairness. We do our best to handle personal data in ways that you would reasonably expect and we do not use any personal information in ways that have unjustified adverse effects on you.
Transparency. We endeavour to make the processing activities transparent and understandable for you, including by providing you with all reasonably necessary information regarding the processing.
Data Minimisation. We endeavour to process only necessary personal data, taking into consideration the requirements of the Applicable Legislation.
Purpose Limitation. We process your data only for the purposes it was collected. If we establish any other purpose, we will inform you reasonably in advance.
Accuracy. We endeavour to ensure the accuracy of your personal data, including by providing you with the opportunity to rectify or complete it.
Confidentiality, Integrity, and Availability. We try to comply with the best practices applicable to the development and maintenance of the security systems.
Storage Limitation. We keep the personal data as long as prescribed in this Privacy Notice, based on the purposes the data was collected.
Accountability. We endeavour to comply with the Applicable Legislation, and, furthermore, if we disclose personal data to any person, we will do our best to ensure that such person will comply with the terms of the Applicable Legislation and this Privacy Notice.
4. What Personal Data Do We Process?
The categories of personal data we collect depend on how you interact with us and the requirements of the Applicable Legislation. We collect and process the following types of personal data as outlined below. Please note that we may also collect certain other information, which may be required under the applicable laws.
|Business Relationship Data|
|full name||This includes your first name, last name and middle name, if any.||Please do not provide personal data unless it is reasonably necessary or requested by us.|
|contact details||This may include your email address, phone number, messenger contacts, such as Telegram, WhatsApp, etc.|
|other information requested by us, or data that you choose to provide us with||This may include information about the name of your project, address, ID document information, certain documents or data from which you can be identified, etc.|
|full name||This includes your first name, last name and middle name, if any.|
|position within the company you represent||This includes information about your position or title within the company you represent, such as a director, manager, etc.|
|contact details||This may include your email address, phone number, social media contacts, such as LinkedIn, Telegram, WhatsApp, etc.|
|other information requested by us, or data that you choose to provide us with||This may include information about your association with the company you represent.||Please do not provide personal data unless it is reasonably necessary or requested by us.|
|information collected from public or other third-party resources||This may include your full name, email address, phone number, information about your title or position within the respective company, information provided in your Social Media accounts, your messenger contacts, any other data you made publicly available, etc.||We may collect the Lead Data in a variety of ways as further described in Section “Where Do We Get the Lead Data From?” of this Privacy Notice.
If you become aware that we process your personal data and believe that we must stop processing such data, please contact us via email indicated in this Privacy Notice.
Once and if we enter into a Business Relationship, the Lead Data becomes Business Relationship Data and is processed accordingly.
|full name||This includes your first name, last name and middle name, if any.||Please do not provide your name unless it is reasonably necessary or requested by us.|
|contact details||This includes your email address and phone number.||This is necessary to contact you back.|
|country of residence||This includes information about the country where you reside.||This is an optional field.|
|other data requested by us or data that you choose to provide us with||Please do not provide personal data unless it is reasonably necessary or requested by us.|
|Social Media Data|
|nicknames, names, and/or photos||When you access or otherwise participate in our Social Media Channels, you will need to use certain social media, such as Instagram, Twitter, LinkedIn and Facebook (the “Social Media”).
In general, Social Media makes available the respective statistical information to us in an anonymised form.
It is impossible for us to make any conclusions about individual users and access to individual user profiles relying solely on such information.
|messages, comments, and other communications|
|any data that you choose to provide us with|
|information provided to us by the respective Social Media||This may include:
a) visits to the respective Social Media Channel;
|Instagram and Facebook Data|
We and Meta have entered into a so-called joint controller agreement, available here, to comply with the requirements of the Applicable Legislation.
We and LinkedIn have entered into a so-called joint controller agreement, available here, to comply with the requirements of the Applicable Legislation.
|Analytical and Marketing Data|
|Google Data||Google. Google Data is collected via Google Analytics solution, operated by Google Ireland Limited and its affiliates, including Google LLC (“Google”).
Cookies. Google gathers information by means of cookies. Cookies are, in effect, small data files that are placed on your device and by which it is possible to recognise this device when you interact with or return to the Website (the “Cookies”).Google Analytics. Google Analytics creates reports, which contain the aggregated information about the use of the Website, where we do not see any data pertaining to a particular person.In other words, we cannot identify you and your actions from the other visitors and their actions. More information regarding Google Analytics is available here.Opt-Out. You may object to the collection of personal data by Google Analytics on any website by downloading and installing the browser add-on from Google.
|internet protocol (IP) address||This means a unique address of a device, which may help to identify your approximate location (country, city, region, ZIP code). For better understanding, IP addresses are expressed as a set of numbers, for instance: 188.8.131.52.
According to the Google Analytics documentation, the IP address is anonymised (masked), so neither we nor Google can identify the IP address and precise location of a particular visitor.
|browser details||This includes information about the browser type and its version.|
|device details||This includes information about the type of device (e.g., computer, tablet, or smartphone).|
|operating system||This means the information about the type and version of the operating system on your device (e.g., Windows 10, macOS version 12.4, etc.).|
|other information regarding the use of the Website||For instance, when you clicked a certain button or made some input.|
|Meta Data||Meta. Meta Data is collected via Meta Pixel, provided by Meta, namely, Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA, USA, and its affiliates, including Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”). More information regarding Meta solutions is available here.
|information regarding the use of the Website and your reactions to and interaction with advertisements||This may include information that you used our Website or clicked on an advertisement from us. If you are registered with any of Meta products, Meta can assign the visit to your respective account.|
|information regarding the use of the Website and your preferences||This may include information about your behaviour and preferences, for instance, when you clicked on advertisements or made some input.|
5. How Do We Use Personal Data?
|Data Category||Purposes||Lawful Basis for Processing|
|Business Relationship Data||To establish a Business Relationship with you or, with respect to the Representative Data, 一 the company you represent.||To take steps at your request prior to entering into a contract (i.e., to establish the Business Relationship with you) 一 if you reach us for the Business Relationship.|
|To execute the relevant agreements, such as service agreement, non-disclosure agreement, etc., in connection with a Business Relationship.||To perform a contact with you 一 if we enter into the Business Relationship with you.|
|To verify your identity, and, with respect to the Representative Data, to make sure that you are duly authorised to act on behalf of the company we wish to establish a Business Relationship with.||Our legitimate interests to enter and perform the Business Relationship with the company you represent 一 with respect to the Representative Data.|
|To publish and publicly display testimonials made by you regarding our services and products to promote and market them.||Our legitimate interests to achieve this purpose 一 with respect to the Testimonial Data.|
|Lead Data||To contact you to enter into the Business Relationship with you or the company you represent.||Our legitimate interests to achieve these purposes.|
|To market and promote our services and products.||We will process such data only if we are of the opinion that our communications may be of your interest.|
|To create a lead database to further reach you out.|
|Contact Data||To contact you in matters of a Business Relationship.||Our legitimate interest to achieve these purposes.|
|To respond to your inquiry.|
|To provide you with marketing emails concerning services and products provided by us or our affiliates.||Our legitimate interest to notify you about our services and/or products that may be of your interest.
You may abandon marketing calls and/or unsubscribe from receiving marketing emails from us at any time by (i) contacting us; or (ii) clicking the unsubscribe button available at the bottom of each marketing email.
In such a case, we will delete your phone number and email address from the respective marketing database.
Please note that administrative or service-related communications (security alerts, email verifications, maintenance notifications, etc.) are not considered marketing and such communications may not offer an option to unsubscribe.
|Social Media Data||To communicate with the visitors, participants, or subscribers.||Our legitimate interest to achieve these purposes.|
|To handle requests from visitors via the Social Media Channels.||To take steps at your request prior to entering into a contract and further to perform such a contract, if and to the extent you wish to enter into a Business Relationship with us.|
|To obtain statistical information about the reach of the Social Media Channels.|
|To conduct customer surveys, marketing campaigns, market analyses, or other promotions and events.||Our legitimate interest to:
a) establish a Business Relationship with the company you represent;
b) execute the relevant agreements (such as service agreement, non-disclosure agreement, etc.) with the company you represent in connection with a Business Relationship.
|Analytical and Marketing Data||Your consent.|
|Google Data||To analyse the use of the Website.|
|To provide a better user experience by improving user flow and interface of the Website.|
|To enable Google to create reports about the use of the Website, which contain the aggregated information where we do not see any data pertaining to a particular person. In other words, we cannot identify you from the other Website visitors.|
|Meta Data||For the remarketing purposes to be able to contact you again within 180 days.|
|To display interest-based advertisements (Meta Ads) to the Website visitors when they visit Meta products or other third-party websites also using Meta Pixel.|
|To promote us and make the Website or its content more interesting for you by displaying advertisements that are of your interest.|
|To ensure that our Meta Ads match the potential interest of Website visitors and are not irritating.|
|To track the effectiveness of the Meta Ads for statistical and market research purposes by seeing whether Website visitors were redirected to the Website after clicking on the Meta Ads.|
|LinkedIn Cookie Data||To collect user behaviour data to optimise the Website and make advertisements thereon more relevant.|
|To identify details of a device accessing the Website for the diagnostic purposes.|
|To provide LinkedIn ads syncing, delivery or retargeting.|
|To store and track visits across the Website.|
6. How Long Do We Process Your Data?
As a general rule, we keep personal data as long as it is necessary for the purposes it was collected. We may process certain personal data longer than outlined below, if it is necessary:
a) to meet our legal obligations under the applicable law;
b) in relation to anticipated or pending legal proceedings; or
c) to protect our rights and legitimate interests or those of third parties.
|Data Category||Storage Period||Rationale|
|Business Relationship Data
|As long as we maintain our Business Relationship and for ten (10) years after any expiration or termination of the Business Relationship 一 if we or our affiliate entered into the Business Relationship with you or the company you represent.||We set these retention periods due to:
a) keep and retain the business records to comply with the applicable laws;
b) perform a contract with you;
c) maintain information about you as a representative of your company;
d) protect our or third-party rights in case of any violation of your confidentiality or other obligations in relation to the Business Relationship; and
e) resolve disputes, establish, exercise or defend legal claims or lawsuits arising out or in connection with the Business Relationship.
|Pending discussions of our Business Relationship and for ten (10) years after either, we or you, rejected the Business Relationship 一 if either we or you had access to certain confidential or other proprietary information in the course of negotiations regarding the Business Relationship.
Until you abandon marketing calls and/or unsubscribe from receiving marketing emails from us 一 with respect to your email address and/or phone number.
|For three (3) years after you last contacted us regarding the Business Relationship 一 if the Business Relationship was rejected by us or you, provided that neither we or you had access to any confidential or other proprietary information.||We need this data to create and maintain a lead database in order to be able to reach you, or a legal entity you represent, as a potential counterparty for the Business Relationship.|
|Lead Data||For three (3) years from the date when the respective data was collected, unless (i) such data becomes Business Relationship Data or (ii) you request us to delete your personal data.|
|During the same term as the Business Relationship Data 一 if we or our affiliate entered into the Business Relationship with you or the company you represent.||In this case, such data is processed as the Business Relationship Data.|
|Social Media Data||No retention period for statistical and analytical information.
The personal data you provided us with is stored as long as it is not deleted by you or respective Social Media. Other personal data is processed as long as it is necessary for the purposes it was collected, unless otherwise is expressly provided, e.g. in a specific consent form or privacy notice or statement.
|We do not establish any retention period for statistical and analytical information, because such information does not allow us to identify any particular individual.
We may not be able to erase the personal data you provided us within the Social Media Channels, therefore, such data is processed until either you or respective Social Media delete it.
|Analytical and Marketing Data||We need such data for the purposes outlined above.|
|Google Data||Up to 2 years. You may find specific timelines here.|
|Meta Data||Up to 180 days after last interaction with the Meta Pixel.|
|LinkedIn Cookie Data||Up to 1 year. You may find specific timelines here.|
7. Where Do We Get the Lead Data From?
General. We may collect the Lead Data in a variety of ways, including from:
a) public sources, such as, for instance, Social Media (e.g., LinkedIn). This includes any information and data you made publicly available through your Social Media profiles and accounts;
b) third persons or third-party service providers, who, to our knowledge, are authorised to share your personal data.
Particular Sources. In particular, we obtained the Lead Data from:
Name: Mr. Ákos Süle, LL.M. attorney at law Süle Law Firm
Postal address: Rungestr. 25, 10179 Berlin, Germany
b) Sales Navigator, operated by LinkedIn, which allows us to target the right leads, understand key insights, and engage with personalised outreach. More information regarding how your personal data is being collected and processed by LinkedIn is available here.
8. How Do We Share Your Data?
General. We do not sell or rent out your data. However, we may share your personal data in accordance with this Privacy Notice, Applicable Legislation, or with your consent, in each case for the purposes of and if it is reasonably necessary for the purposes outlined in this Privacy Notice or required under the applicable laws and regulations.
Please note that if we share any portion of your personal data with third persons, we will endeavour to secure such transfer using appropriate legal, organisational, and technical measures.
Recipients. Given the purposes outlined above, your personal information is shared with the following categories of recipients:
a) our affiliates, meaning any person controlling, controlled by, or under the same control as we;
b) our personnel, contractors and consultants, who are required to have such data in connection with the performance of the Business Relationship and on a “need-to-know” basis, such as our legal department for conducting the paperwork or financial department for administering payments, etc.;
c) CRM systems and other systems for the data management and storage;
d) support and technical teams;
e) sales and marketing teams;
f) email delivery service providers;
g) analytical solution providers, such as Google Analytics;
h) government authorities, upon their request or if necessary to comply with our legal obligations; and
i) another entity by virtue of succession, including as a result of merger, reorganisation, acquisition, or liquidation.
9. Do We Transfer Your Personal Data to Third Countries?
Sometimes we may transfer your personal data to countries that do not offer the same level of data protection as the laws of the European Union, EEA, Switzerland, the United Kingdom or your country. In case we transfer your personal data to a country that does not maintain the “adequate” level of data protection, as defined by the European Commission, we will put in place suitable safeguards, which give you more protection and control regarding your personal data, and take reasonable steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Notice and provided for in the Applicable Legislation. As a general rule, we will use the Standard Contractual Clauses (special documents developed by the European Commission) as an appropriate safeguard. You may reach us via the contact details indicated herein to ask whether your personal data is subject to transfer to a third country.
10. Who Controls Your Personal Data?
General. With respect to personal data processed in accordance with this Privacy Notice, we act as a data controller or joint data controller depending on applicable circumstances as described below.
Joint Controller. When we act as a joint controller with others, we mean that we and the respective person or entity process the substantially the same set of personal data and jointly determine the purposes and means of processing such personal information. If and to the extent we are considered to be a joint controller according to the Applicable Legislation, you may exercise your data protection rights with respect to the relevant personal data against both us or the respective person or entity. However, we will be able to assist you only with respect to the processing operations expressly outlined in this Privacy Notice. We have no influence on the processing of personal data in connection with your interaction with others, including, but not limited to, Social Media and other third-party service providers, as such. According to the Applicable Legislation, we may be regarded as joint controllers, for example, in the following cases:
a) with respect to your Social Media Data — when you access or otherwise participate in our Social Media Channels, we are deemed a data controller with respect to (i) the data you provide us with and (ii) the statistical data provided by the respective Social Media. However, with respect to any other processing of your data, the respective Social Media acts as an independent data controller;
b) with respect to the Meta Data — we are deemed a joint data controller with respect to the following data processing activities in connection with the Meta Pixel: (i) creation of individualised or suitable ads, as well as for their optimisation; (ii) delivery of commercial and transaction-related messages. The following data processing activities are not covered by the joint controllership: (i) the process that takes place after the collection and transmission is within the sole responsibility of Meta; (ii) the preparation of reports and analyses in aggregated and anonymised form is carried out by Meta as a data processor and we act as a data controller. We have concluded a corresponding agreement with Meta for joint controllership. This agreement defines the respective responsibilities for fulfilling the obligation under the data protection legislation with regard to joint controllership. In particular, we have agreed with Meta that Meta can be used as a contact point for the exercise of your data protection rights regarding the data collected by the Meta Pixel.
с) with respect to the Lead Data — we are deemed a data controller with respect to the following data processing activities: (i) collection, structuring, adaptation and storage of the Lead Data; and (ii) making marketing calls as well as delivery of marketing and other commercial messages regarding the Business Relationship. However, if the Lead Data was obtained from a public or other third-party resource, the respective provider of such public or other third-party resource acts as an independent data controller with respect to any other processing of your data, and we will not be responsible for such processing.
11. Are You Subject to Automated Decision-Making?
According to the Applicable Legislation, you have the right not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you. Automated decision-making is the process of making a decision by automated means without any human influence on the outcomes. A process might still be considered solely automated if a human inputs the data to be processed, and then the decision-making is carried out by an automated system.
We do not make any automated decisions based on your personal data, including profiling, which produce legal effects concerning you or similarly significantly affect you. If we intend to do so, we will do our best to inform you about the same in advance.
12. What About Securing Your Personal Data?
We strive to do our best to keep your personal data secure. We always review and update appropriate technical and organisational measures to:
a) keep your personal data secure in accordance with the Applicable Legislation, our internal policies and procedures regarding the storage of, access to, and disclosure of personal data;
b) protect you against unauthorised or unlawful processing of personal data and accidental loss or destruction of, or damage to them.
We endeavour to implement and maintain reasonably necessary technical and organisational measures to protect the confidentiality, integrity and availability of your personal data. Your personal information may undergo anonymisation, pseudonymisation, and/or encryption to ensure safe transfer and/or processing.
13. What About Interacting with Third-Party Links?
14. What Data Subject Rights Do You Have?
General. According to the Applicable Legislation, you may have the rights outlined below. In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.
Data Subject Rights. According to the Applicable Legislation, you may have the following rights:
|Right to access your personal data (commonly known as a “data subject access request”)||This enables you to (i) ask us whether we process your personal data, and (ii) request certain information about the processing activity and/or a copy of the personal data we hold about you as well as (iii) check that we are lawfully processing it.|
|Right to rectification of the personal data||This enables you to have any incomplete or inaccurate data we hold about you completed or rectified, though we may need to verify the accuracy of the new data you provide us with.|
|Right to erasure of your personal data (commonly known as a “right to be forgotten”)||This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal or technical reasons which will be notified to you, if applicable, at the time of your request
|Right to object to processing of your personal data||This enables you to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.|
|Right to restrict the processing of your personal data||This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy, (ii) where our use of the data is unlawful but you do not want us to erase it, (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.|
|Request the transfer of your personal data (commonly known as a “right to the data portability”)||We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.|
|Right to withdraw consent||You may withdraw your consent at any time where we are relying on consent to process your personal data.|
|Right not to be subject to automated decision-making||You reserve the right not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you. Please note that currently you are not subject to the automated decision-making, which produces legal effects concerning you or similarly significantly affecting you.|
|Right to file a complaint||You may file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the Applicable Legislation. The relevant supervisory authority may depend on the place where you are located.
The details of the Cyprus data protection supervisory authority:
15. Do We Process Children’s Personal Data?
The Website is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We also do not knowingly market to, solicit, process, collect, or use personal data of children.
If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our database. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.
16. Can We Modify and Update this Privacy Notice?
We keep our Privacy Notice under regular review and we may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. If we make substantial changes to the way we treat your personal information, we will notify you about the same prior to the change becoming effective.