Privacy Notice
Purpose and Scope
Your privacy is very important to AbleTools Limited (AbleTools/ “we” / “us”) and we follow strict security for storing and disclosing the personal information you provide when accessing and using our website, making a purchase, requesting an offer, registering with us, booking educational classes, or when we collaborate with third parties to organize educational conferences.
“Personal Data” refers to any information relating to you that Abletools obtains from you or about you from other sources.
This Privacy Notice provides an overview of the policy regarding the protection of personal data that we follow and how we collect your Personal Data, how we use it, and what rights and choices you have in relation to the Personal Data we hold and process.
Who decides why and how we process your personal data?
AbleTools determines why and how your Personal Data is being processed and acts as a data controller in accordance with applicable data protection legislation.
1. CATEGORIES AND TYPES OF PERSONAL DATA WE COLLECT
AbleTools will only collect and process the necessary information required to perform the services described below. Typically, that includes the information below:
- Identity Data: First and last name, date of birth, gender.
- Contact Data: billing address, delivery address, email address and telephone numbers which are necessary for delivering, maintaining or collect equipments/products that we offer.
- Health Data: personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.
- Financial Data: bank details that are necessary for facilitating payments, including credit / debit card numbers, security code numbers and other such relevant billing details such as invoices and receipts.
- Profile Data: username (when registering as a member on our website), purchases or orders made by you or on behalf of your child, feedback and survey responses.
- Usage Data: information about how you use our website, products and services.
- Marketing Data: preferences in receiving marketing from us and your communication preferences.
- Recruitment Data: CVs, references by previous employers, previous or expected salaries, skills and qualifications obtained through education or experience.
- Security Data: data that is used for securing the use of our services and our premises, such as CCTV footage and other information obtained through electronic means.
Due to the nature of our services and the products that we offer, which can be tailored made to your needs or those of the intended users, we may collect Health Data and this information constitutes a Special Category of Personal Data. In accordance with data protection legislation, we will only process Special Category Data if we have obtained your explicit consent for the specific purposes outlined, or when the collection and processing of Health Data is necessary to protect the vital interests of the individual for whom our products are intended, especially if that individual is physically or legally unable to provide such consent..
We do not otherwise collect Special Category Data about you (for example, details about your race or ethnicity, religious or philosophical beliefs etc).
2. WHEN DO WE COLLECT YOUR DATA ?
The Personal Data we collect about you, is primarily collected through your interactions with us. You may share your Personal Data when you or your organization request a quote for our products or services, or when you express interest in attending conferences and seminars we organize. This includes, among other things:
- Personal Data you provide when applying for our products or services;
- Creating an account on our website and becoming a member of Abletools;
- requesting marketing to be sent to you;
- Giving us feedback or contacting us by phone, email or in person;
In some cases, your Personal Data may be collected from third parties, such as your physicians, government authorities (when you apply for financial aid), or your primary caregivers who provide your information on your behalf if you are physically unable to do so, in order to deliver our products and services to you.
Personal Data we receive from you about other people
When you provide us with the Personal Data of others, such as individuals for whom you are the primary caregiver, your employees, or other contacts, you must ensure that you have the right to share their Personal Data with us. Additionally, you must confirm that we are permitted to collect, use, and disclose the data as outlined in this Privacy Notice without needing to take any further actions
3. HOW WE USE YOUR PERSONAL DATA AND WHAT LEGAL BASES
| Purpose | Description of activities associated with purpose | Type of Data | Legal bases (where applicable) |
|---|---|---|---|
| Providing our Products and Services | There are a number of activities associated with this purpose, such as: (i) to provide our products and services which are tailored to you, the individuals to which you are the primary caregiver or your client’s specific needs; (ii) to deliver our products to the designated address that you or your organisation have provided; (iii) to provide you with an offer for our products or services (iv) to process payments and security deposits or governmental financial aids that are available to you; (v) to manage and maintain records in order to fulfill our obligations to register your information or share your Personal Data with government authorities, should you apply for governmental financial assistance, as agreed upon with you. |
|
|
| Registration as a Member | When you choose to become a registered member, we need to process your data to manage our relationship with you, which will include: (i) notifying you about changes to our terms or privacy notice, (ii) providing you with any marketing materials about our offers, new products, services or seminars that we might organise (iii) analysing and improving our services and communications to you |
|
|
| Perform a contract we are about to enter into or have entered into with you or your organisation | There are a number of activities associated with this purpose, such as when: (i) you or your organisation choose to purchase our products or services, or request a quotation for our products or services; (ii) you or your organisation choose to collaborate with us for organising an educational conference or seminar; (iii) you or your organisation choose to register for a conference or seminar that we organise |
|
|
| Communications/ Surveys | Provided that you have given as your consent we may send you relevant marketing communications or surveys and make personalised suggestions and recommendations to you about goods or services or upcoming conferences and seminars that we will organise, that may be of interest to you based on your Profile Data. |
|
|
| Improve our services | To use data analytics to enhance our website, offerings, customer relationships, and experiences, and to assess the effectiveness of our communications and marketing. |
|
|
| Employment | To review your application for an employment position with us |
|
|
| Liaise with governmental authorities | When you are eligible for governmental financial aids we will need to share your information with them. |
|
|
| Security | When we record footage from the CCTV cameras installed at our premises, for ensuring the safety of our employees and our business. The CCTV footage is processed in accordance with applicable laws and stored for the legally permitted time frames and shared with authorities as may be required by applicable laws. |
|
|
| Comply with our legal / tax/ statutory requirements or defend our legal claims | To comply with our legal, tax and statutory requirements or defend our legal claims we may need to process your Personal Data |
|
|
4. DISCLOSURES OF YOUR PERSONAL DATA
We may share your Personal Data where necessary with third parties for the purposes set out in the table in paragraph 3 of this Privacy Notice. This means, that your Personal Data may be shared with service providers and affiliates who will process your data on our behalf, following our instructions for the purposes set out above. This may involve transfers outside the EU or EEA, but we will ensure the security and integrity of your data.
There are instances where we may be instructed by you to share your data with governmental bodies, such as when you are eligible for governmental financial aid. We will disclose your data as required by law or with your consent.
Additionally, we may share your data with potential investors or buyers in the event of a business acquisition or merger, provided they agree to protect your data.
5. INTERNATIONAL TRANSFERS
Where permitted by applicable law, we may transfer your Personal Data outside of the European Union or the European Economic Area, which may not be considered to provide the same level of data protection as the European Union.
When we make such transfers, we will ensure that they are subject to appropriate safeguards in accordance with the EU General Data Protection Regulation 2016/679 (GDPR) or other relevant data protection legislation, or that we comply with the GDPR’s requirements and standards for transferring personal data abroad. For example, in some cases, we rely on transfer mechanisms based on an adequacy decision issued by the European Commission (e.g., for transfers to the United Kingdom) or on transfers subject to appropriate safeguards as indicated by GDPR.
6. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it for, including for the purposes of satisfying any legal, tax, accounting or reporting requirements. We will not keep your Personal Data for longer than five (5) years, unless requested by applicable law. In addition, we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In relation to Recruitment Data, which we may receive from you, for potential employment with us, unless we receive a specific request for erasure, we will delete such information from our records after the lapse of three (3) years.
7. DATA SECURIY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data based on our instructions and they are subject to a duty of confidentiality.
8. YOUR LEGAL RIGHTS
Subject to certain circumstances under applicable legislation, you have the right to:
- Request a copy of the Personal Data which we hold about you or in certain cases request that we transfer the data we hold about you to another provider;
- Have any inaccurate data we hold about you corrected;
- Object or restrict our use of your Personal Data, including but not limited to object to our use of automated decision making in certain cases;
- Submit a complaint if you have concerns about the way in which we are handling your data;
- Request that we delete the Personal Data we hold on you;
- Where we have relied on consent to process your Personal Data, to withdraw your consent; and
- Request that we transfer your data to another provider.
To do any of the above, please contact us at info@abletools.com.cy . To enable us to process your request, we may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification – this is to protect the Personal Data we hold from unauthorised access requests and comply with our security obligations.
We may charge a reasonable administrative fee for any excessive requests we receive.
9. CORRECTIONS, UPDATES AND COMPLAINTS
Where any Personal Data you have provided us with has changed, or where you believe the Personal Data we hold is inaccurate, or where you wish to make a complaint regarding our handling of your Personal Data, please let us know at info@abletools.com.cy or send us a letter addressed at:
Abletools’ Privacy Officer
Strovolos Avenue 149K,
Strovolos,
Nicosia,
2048, Cyprus
or
info@abletools.com.cy
In relation to complaints, we will promptly respond to your requests and complaints. In the event that you are unhappy with our response, you may submit a complaint to the Cyprus Data Protection Commissioner (DPC). We can provide details of the DPC upon request.
In addition, please note that if you have certain relationships with us or a third party entity to which we provide services, you and/or the third party entity may have a contractual or legal obligation to notify us of any change within a prescribed time period. We cannot be responsible for any loss that may arise due to us having any inaccurate, incomplete, inauthentic or otherwise deficient Personal Data which you or a third party entity have provided to us. Please also let us know if you wish to withdraw any request.
10. CHANGES TO OUR PRIVACY NOTICE
This Privacy Notice was last updated in October 2024. We have the right to update the contents of this Privacy Notice from time to time to reflect any changes in the way in which we process your Personal Data or to reflect legal requirements as these may change. In the case of updates, we will post the revised Privacy Notice on our website. Changes will take effect as soon as the revised version is made available on our website.
You can request a hard copy of the Privacy Notice (in Greek or English) by visiting our premises at Strovolos Avenue 149K, Strovolos, Nicosia, 2048, Cyprus.
11. GET IN TOUCH
We would be happy to hear your views about our website and this Privacy Notice – please let us know of any questions, comments or clarifications you may have at info@abletools.com.cy.
Phone +357 22 250 115
Fax +357 22 250 116