Privacy Policy

This Privacy Policy governs the processing of your personal data when you interact with our services, including accessing our website cpago.com (the “Website”), contacting us with inquiries, and engaging with our services through email or our Website’s contact form. It also applies to any other interactions or communications you have with us.

This Privacy Policy outlines how we handle your personal data and our commitment to safeguarding your privacy.

Contact Information

If you have any questions or need support regarding your data, please reach out to us:

• Company Name: Carambolico LTD (“CPAGO”)
• Email: support@CPAGO.com
• Address: 12 Demostheni Severi, 6 floor, office/flat 601, 1080 Nicosia, Cyprus

Definitions

• Personal Data: Any information relating to an identified or identifiable natural person.
• Data Subject: An individual whose personal data we collect, hold, and process.
• Processing: Any operation or set of operations performed on personal data, including collection, recording, storage, retrieval, and disclosure.
• Data Controller: The entity that determines the purposes and means of processing personal data.
• Data Processor: An entity that processes personal data on behalf of the controller.
• Privacy Regulations: Laws and regulations governing the collection, processing, and protection of personal data.

Information We Collect

We collect personal data through various channels to offer our services effectively and enhance your experience with us. The information we collect includes:

Information You Provide Directly:

• Contact Information: Name, email address, phone number, postal address provided when contacting us or filling out forms on our Website.
• Business Information: Company, job title, and business contact details when engaging with us in a business context.
• Communication Data: Content of your messages and attachments when you communicate with us via email, phone, or other channels.
• Feedback and Survey Responses: Information provided when participating in surveys or providing feedback.

Information Automatically Collected:

• Usage Information: Data collected when you visit our Website, such as IP address, browser type, device type, and browsing activity.
• Device Information: Data about your device, such as device identifiers and location data (if permitted by device settings).

Information Provided by Third Parties:

• Business Partners and Service Providers: Marketing agencies, analytics firms, and other service providers who may provide demographic data or business-related insights.
• Public Sources: Information from public websites, social media, search engines, and online forums, including when you post content related to us.

KYC Compliance

In certain circumstances, we may implement Know Your Customer (KYC) procedures to comply with regulatory requirements, such as anti-money laundering (AML) regulations. KYC involves verifying the identity and business legitimacy of individuals and entities, using documents and data obtained from both direct sources and publicly available information.

Purposes of Processing Personal Data

We process your personal data for the following purposes:

• Service Provision: To deliver and manage our services effectively, including monitoring service usage and ensuring smooth operation.
• Contractual Obligations: To fulfill our contractual commitments with you.
• Communication: To keep you informed about updates, security notifications, and other important information related to our services.
• Marketing: To send news, offers, and information related to our services (with your consent). You can opt out at any time.
• Business Operations: For purposes such as data analysis, marketing campaigns, and evaluating service effectiveness.
• Recruitment: To assess eligibility for employment if you apply for a position with us.
• Legal Compliance: To comply with applicable laws, including tax, accounting, and privacy regulations.

Legal Bases for Processing Personal Data

We process your personal data based on the following legal grounds:

• Contractual Necessity: To fulfill our contractual obligations or take steps at your request prior to entering into a contract.
• Legitimate Interests: To pursue our legitimate business interests, such as improving services, marketing, and ensuring the security of our systems.
• Compliance with Legal Obligations: To comply with applicable laws and regulations.
• Consent: In some cases, we rely on your consent to process your data for specific purposes, such as sending marketing communications. You can withdraw consent at any time.

Cookies

Our Website uses cookies to enhance your browsing experience and improve site functionality. Cookies are small text files stored on your device that help us remember your preferences and interactions with the site. We only use necessary cookies, which are essential for the operation of the Website, such as enabling navigation and access to secure areas.

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. Once the applicable retention period has passed, we will securely delete or anonymize your personal data.

Storage of Personal Data

Your personal data is processed and stored securely within the European Economic Area (EEA). We apply industry-standard encryption and access controls to protect your data from unauthorized access.

Sharing of Personal Data

We may share your personal data under the following circumstances:

• Affiliated Companies: We may share data with affiliated companies for recruitment purposes or other business activities.
• Service Providers: We share data with trusted service providers who assist us with operations such as hosting, analytics, and legal advice.
• Business Partners: Data may be shared with partners for joint business activities.
• Legal Compliance: We may disclose data to comply with legal obligations or protect our rights and safety.
• Business Transfers: In the event of a merger or acquisition, personal data may be transferred as part of the transaction.

International Data Transfers

While most personal data is processed and stored within the EEA, some data may be transferred to recipients outside the EEA for business operations. In such cases, we ensure appropriate safeguards, such as standard contractual clauses, are in place to protect your data.

Your Data Protection Rights

You have several rights regarding your personal data:

• Right to Access: Request a copy of your personal data.
• Right to Rectification: Request corrections to inaccurate or incomplete data.
• Right to Erasure: Request the deletion of your data under certain conditions.
• Right to Restriction of Processing: Request limitation on data processing in specific situations.
• Right to Data Portability: Request your data in a structured, machine-readable format.
• Right to Object: Object to the processing of your data in certain cases, including for marketing purposes.
• Right to Withdraw Consent: If we rely on consent, you can withdraw it at any time.

To exercise these rights, please contact us at support@CPAGO.com.

Children’s Privacy

Our services are not intended for children under the age of 16, and we do not knowingly collect data from children without parental consent. If you believe your child has provided personal data without consent, please contact us, and we will delete such data promptly.

Third-Party Links

Our Website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites and recommend reviewing their privacy policies before providing any personal data.

Updates to this Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the updated policy on our Website. Please review this policy periodically for the latest updates.