Privacy Policy of Dial Marketing Services Ltd

1. Who we are:

Dial Marketing Services Ltd is compliant with the EU General Data Protection Regulation 2016/679 (GDPR) and is dedicated to protecting the confidentiality and privacy information entrusted to us.

Please read this Privacy Policy to learn about your rights, what information we collect, how we use and protect it.

This website is operated by Dial Marketing Services Ltd.

2. Why do we have a Privacy Policy?

To inform you of our policies regarding the collection, use and disclosure of Personal Data (as defined in GDPR) when you use our services and the choices you have associated with that data.

3. Who can you contact for privacy questions and concerns:

If you have questions or comments about this Privacy Policy or how we handle Personal Data, since we are the controllers of your Personal Data, please direct your correspondence to our Data Protection Officer by writing at Patsalos Plaza, Gorgonon 14, 6047, Larnaca, Cyprus or via email at:

We aim to respond within 30 days from the date we receive privacy-related communications.

4. What is GDPR?

General Data Protection Regulation – GDPR is a regulation by which the European Parliament, the Council of the European Union intend to strengthen and unify data protection for EU residents. The new EU data protection regime extends the scope of the EU data protection law to all companies even outside the EU when they process data of EU residents.

5. Changes to the Privacy Policy:

We reserve the right, at our complete discretion, to change, modify, add/or remove portions of this Privacy Policy at any time. You shall be informed by us of any changes made to this Privacy Policy by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

6. Personal Data:

Under the GDPR, Personal Data is defined as any information relating to an identified or identifiable natural person. It can include obvious identifiers like your name but also identification numbers, online identifiers and/or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

7. How and when we collect your Personal Data?

We obtain your Personal Data mainly through any information you provide directly to us or through information provided by third parties. Below is an indicative list of ways which we collect your Personal Data directly from you, including:

• when you make requests to receive our products or services
• when we perform services through a contract
• when you provide products or services on our behalf as an agent
• when you contact us for an enquiry, complaint or for any other reason (including submission of an employment application
• when you become our employee

8. Types of Personal Data collected:

We may collect the following Personal Data from you depending on the product or service we provide to you or which we receive from you:

• Contact details such as your name, address, telephone number, e-mail address and fax number.
• Identification details such as a copy of your ID, passport or driving license (e.g. when providing transportation services, becoming an employee or any procedure requires the collection of such documents).
• CV’s when you are interested in working with us or becoming an employee
• Financial information such as your bank account number and account details when we need to perform a bank transaction (e.g. to pay your rent in case we are in a leasing contract with you, pay your salary in case you are one of our employees or external agents, pay for your services in case you are one of our service providers).
• Closed Circuit Television (CCTV) recordings in case you enter areas of our office that CCTV is operated
• Details of contracts you enter into with us
• Your marketing preferences
• Other communication about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, email, online or otherwise.

9. Why we collect your Personal Data?

We shall process and use your information where we have your consent, or we have a lawful reason for using it subject to applicable law. Most commonly, we will use your Personal Data in the following circumstances:

A. Where we need to perform the contract or arrangement we have entered into or agreed with you or in order to take certain steps prior to entering into a contract with you such as:

i) Processing is necessary for us in order to provide you with our products or services or information, and more specifically in order to:

• • • Review any proposal made by you and provide you with a quotation;
    • Preparation of a contract;
    • Communicate with you in order to manage our business relationship with you and resolve any complaints and/or inquiries you may have;
    • Notify you about any changes to our products and/or services;
    • Recover any payment due to us in respect of the products and/or services we provide to you.

ii) Processing is necessary for us in order to enter in a contractual agreement with you in case you become an employee.

iii) Processing is necessary for us in order to enter in a contractual agreement in case you provide services or products.

B) Where we need to comply with a legal obligation:

Such obligations and requirements impose on us necessary personal data processing activities for compliance with governmental regulatory bodies, court orders, tax law and/or other reporting obligations for carrying out our business and be complaint with regulatory obligations imposed on us.

C) Where we have appropriate legitimate interests to use your Personal Data:

In some cases, we may process your Personal Data to pursue legitimate interests of our own or those of third parties provided your interest and fundamental rights are not overridden by our interests. More specifically, we may process your Personal Data in order to:

• • Maintain our records;
  • Enhance the security of our network and information systems;
  • Identify, prevent and investigate fraud and other unlawful activities, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality
  • Safeguard the security of our people, premises and assets and prevent trespassing through video surveillance;
  • Manage our infrastructure, business operations and comply with internal policies and procedures;
  • Defend, investigate or prosecute legal claims
  • Perform data analytics (such as market research, trend analysis, financial analysis)

D) Where you have given us your consent:

In some cases, you will have given us your consent to the processing of your Personal Data for one or more specific purposes (e.g communicate with you for any job openings if we hold your CV within the period mentioned on our data retention policy or for marketing purposes).

You may withdraw your consent to such processing at any time. Please note that any processing that was carried out prior to the withdrawal of your consent shall not be affected in any way.

10. With whom we may share your Personal Data:

We may share your Personal Data, with third parties as indicative listed below. When we do so, we request from such third parties to have appropriate technical and organizational measures in place to protect your Personal Data. We will not share any of your Personal Data for any purpose other than the purposes described in this privacy statement, nor will we sell your Personal Data to anyone.

• Service providers we have chosen to support us by offering technical expertise in order to perform/improve our activities or legal obligations;
• Training centers and governmental organizations that subside employee training (e.g. Human Resource Development Authority) in case you are one of our employees;
• Benefit providers (i.e. insurance providers), pension and payroll administrators in case you are one of our employees;
• Auditors and accountants;
• External consultants;

11. Data Retention Period:

Unless a longer retention period is required by applicable laws, we will retain your information for as long as we have a business relationship with you. More specifically:

A. Once our business relationship with you has ended (end or cancel of contractual agreement), we may keep your Personal Data for the longest of the following periods, according to the below (including but not limited to):

• The Limitation of Actionable Rights Law of 2012 as amended;
• The end of the period in which legal action or investigations might arise in respect of the products and services provided or received;
• Income tax law and respective regulations
• Any applicable law or regulation issued and enforced from time to time

This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as processing any disputes or claims pending for any services or products.

B. Personal Data Related to HR issues: Once you have sent us your CV, we shall keep your CV for a maximum of 6 months if you are unsuccessful to a job opening or If we do not have an appropriate position, for future consideration.

C. Supplier Personal Data and any other data arising for bookkeeping purposes will be kept for a period of 10 years or any other period as required by applicable laws including but not limited to tax law.

We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it to protect legitimate company interests (e.g. statute of limitations periods).

12. What are the Rights of the Data Subject?

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by the GDPR.

We, Dial Marketing Services Ltd (the Data Controller) aim to take reasonable steps to allow you (the Data Subject) to correct, amend, delete or limit the use of your Personal Data.

• Right to Information:

The Data Subject has the right to concise, transparent, intelligible and easily accessible information without undue delay and in any event within one month of receipt of a request for such information. The information is provided free of charge unless requests are manifestly unfounded or excessive, in particular because of their repetitive character, when Dial Marketing Services Ltd may either: a) Charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or b) Refuse to act on the request.

• Right to Information during the process of obtaining consent:

During the process of obtaining consent, Dial Marketing Services Ltd informs the Data Subject of the purpose of collecting his/her Personal Data, the period for which the Personal Data will be stored, his/her rights, the categories of data and the source of any data that has not been collected by Dial Marketing Services Ltd.

• Right of Access:

The Data Subject has the right to obtain a copy of his/her Personal Data and to be fully informed about the data, the purposes of the processing, the categories of Personal Data, the storage period and the criteria used to determine that period, the recipients to whom the data has been disclosed etc..

• Right to Rectification/Amendment:

The Data Subject has the right to demand the rectification/completion of inaccurate Personal Data and his/her demand must be satisfied without undue delay.

• Right to Erasure “Right to be Forgotten”:

The Data Subject has the right to demand the erasure of his/her Personal Data and his/her demand must be satisfied without undue delay, unless the Data Controller has an overriding legitimate interest.

• Right to Restriction of Processing:

The Data Subject has the right to demand the restriction of processing when he/she questions the accuracy of the Personal Data or the processing is unlawful or no longer essential.

• Right to Notification:

The Data Controller must communicate any rectification or erasure of Personal Data or restriction of processing to each recipient to whom the Persona Data has been disclosed and inform the Data Subject accordingly.

• Right to Data Portability:

The Data Subject has the right to receive his/her Personal Data in digital form and to transmit it to another organization or to demand its direct transmission to another organization.

• Right to Object:

Processing stops after such an objection, unless the Data Controller has an overriding legitimate interest.

• Right to Non-Automated Individual Decision-Making:

The Data Subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or significantly affects him/her.

The Data Subject has the right to submit a complaint to the Commissioner for Personal Data Protection at any time if he/she believes that any of his/her rights have been violated.

Furthermore, the Data Subject has the right to withdraw his/her consent at any time. If you wish to withdraw your consent you should notify our Data Protection Officer by writing at Patsalos Plaza, Gorgonon 14, 6047, Larnaca, Cyprus or via email at :

Please note that Dial Marketing Services Ltd may ask you to verify your identity before responding to such requests. Please note that we may not be able to accommodate your request without some necessary data.

13. Handling Leaks of Personal Data:

Dial Marketing Services Ltd informs the Commissioner for Personal Data Protection in detail of any leak and/or violations being made aware of such a leak/violation. Furthermore, Dial Marketing Services Ltd informs the Data Subject when there is a high risk of violation of his/her rights and freedoms.

14. Safeguarding your data:

We use a range of administrative, technical and technological measures to keep your information safe and secure both physically and electronically. We require our staff and any third parties who carry out any work on our behalf or at our premises or servers to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.