Privacy Policy

Thank you for visiting our Website https://napsodev.com/ (“Website”) and reading our documentation. We pay a special value to your privacy. This is why we have created this Privacy Policy (“Policy”).  When you use the Website, we process various data concerning you; in this Policy you can find the information about your data processing.

You can send to the e-mail address info@napsodev.com all the question relating to this Policy or processing your data by us.

Legal information.

Here you can find legal information about us. This Website is owned, operated, and provided by Napso Holding Limited, a company incorporated in Cyprus, with its registration number ΗΕ 316592, with its registered address at 13 Kypranoros, EVI building, 2nd floor, office 201, 1061, Nicosia, Cyprus. Napso Holding Limited shall hereinafter be referred to as the “Company”, “We”, “Us”, “Our”).

Application of this Policy.

This Policy applies to:

• • This Website;
  • Our e-mail address info@napsodev.com;
  • Our communications with you when you have provided your personal data via the Website or other means.

What data we collect.

Automatically-collected data. When you use the Website, the following data concerning you are collected automatically:

• • Your IP address, the data concerning your location, the data concerning your mobile carrier operator or internet provider;
  • The data concerning your device: its operating system, the type and version of the browser, screen resolution, installed time-zone, language setting, the type of the device: its model and manufacturer;
  • The data concerning your browsing session and any interaction(s) with the interface of the Website, for example Website pages you have visited, and Website pages` buttons you have clicked on;
  • The data concerning the source from which you have visited the Website.

The source of Automatically collected data: we receive automatically-collected data via technical facilities of the Website and via Google Analytics and Cloudflare Services. If you want to find out more about how Google processes your data, please, follow Google`s Privacy Policy https://policies.google.com/privacy. If you want to find out more about how Cloudflare processes your data, please, follow Cloudflare`s Privacy Policy https://www.cloudflare.com/privacypolicy/. To provide website visitors with the ability to prevent their data from being used by Google Analytics, Google developed the Google Analytics opt-out browser add-on for websites using the supported version of Google Analytics JavaScript (analytics.js, gtag.js). If you want to opt-out, download and install the add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Internet Explorer 11, Safari, Firefox and Opera. To install Google Analytics Opt-out Browser Add-on, follow this link https://tools.google.com/dlpage/gaoptout?hl=en.

Cookies data. Additionally, we collect Website visitors` personal data from Cookies. To find out more about the use of cookies by the Website, please, follow Cookies Policy.

Business data. When you contact us via our contact details or the interface of the Website, you hereby provide us with the following data:

• • Your name;
  • Your email address;
  • A subject of your message;
  • The subject of your message including all the data it may contain;
  • Your budget.

Additionally, you may voluntarily provide us with the following data:

• • The organisation you work for;
  • Your phone number.

Additionally, we record the history of your communications with the Company (either via the Website`s interface or via e-mail correspondence).

How we use your data.

a. Administration and protection of the Website.We use Automatically-collected data for the following purposes:

• • To administer the Website;
  • To protect the Website from DDoS attacks and other cyberattacks;
  • To protect the Website from any illegal, unlawful activity, fraud, and abuse;
  • To diagnose any problems with the Website and the Serverwhich makes the Website available;
  • To provide you with the Website tailored for your device, language, and opted preferences;
  • Toload balance to the Server which makes the Website available.

Legal basis for the processing: legitimate interests of the Company under Article 6(1)(f) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “GDPR”).

b. Research and analysis.We use your data for the purposes of research and analysis. It means that we take your data, anonymize them, combine with other data sets, and then use these data for the following purposes:

• • Conduct research and analysis in regard to the use of the Website its  audience;
  • Having known the information about the use of the Website, develop and enhance the Website.

Legal basis for the processing: legitimate interests under Article 6(1)(f) of the GDPR.

c. Test new features on the Website. We use your automatically collected data and cookies data in order to:

• • To conduct so-called “A/B tests” (to find out more A/B tests please follow https://en.wikipedia.org/wiki/A/B_testing);
  • To test new features on the Website.

Legal basis for the processing: legitimate interests under Article 6(1)(f) of the GDPR.

d. To contact you. We use your business datain order to contact you when required by the situation.

Legal bases for the processing:

• • If you make a request as the data subject or your request relates to another legal issue: the processing is necessary for compliance with a legal obligation to which the Company is subject in accordance with Article 6(1)(с) of the GDPR.
  • If your question relates to the Company in general or relates to the products and services of the Company: legitimate interests under Article 6(1)(f) of the

e. To communicate with you in the context of the establishment of business relationships.

Legal bases for the processing for this purpose:

• • If you contact the Company as an individual: the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract in accordance with Article 6(1)(b) of the GDPR.Without your business data, we would not be able to process your inquiry and discuss your issue.
  • If you contact the Company on behalf of your organisation: legitimate interests under Article 6(1)(f) of the GDPR. Establishment of business relationships with other organisations is the legitimate interest of the Company.

How long will we retain your data?

For automatically-collected data: for a period of twenty-six (26) months starting from the date of your last visit to the Website.

For business data: as long as required by a particular purpose of the communication or for implementation of pre-contractual measures.

Recipients of your data.

a. Our employees, affiliates, contractors, and sub-contractors. This category includes our employees, employees of our affiliated entities, contractors, and sub-contractors. Thus, your data will be shared with them.

b. The hosting provider that owns the server which makes the Website available. Our Website is placed on the third-party server; thus, your data will be shared with this services provider.Nevertheless, your data will be placed on this server only in encrypted form: from this follows that these services provider will not be able to decrypt your data without decryption keys which are in sole possession of the Company.

c. Google and Cloudflare.As mentioned above, the Company uses the services, provided Google LLC, Amphitheatre Parkway, Mountain View, CA 94043, USA and Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA. Google LLC. Please note that Google and Cloudflare transfer data from the EU to the United States. These transfers are secured by a proper legal mechanism called Standard Contractual Clauses. You can read the information about Standard Contractual Clauses via the link https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

Your rights.

As the data subject, you have several rights which you can implement either by contacting us via email info@napsodev.com or by sending a request to our legal address.

Please note, that your rights are applicable with some restrictions:

• If we are not sure about the identity of the requestor,we shall verify the identity of a user/visitor who requests for the implementation of any of the rights before the implementation of this right.
• We may restrict the rights specified above or deny in implementation of any of the rights if this restriction or denial is grounded on the legislation to which the Company is subject. In this case, we will specify you the reason for the denial in the reply to your request.

Your rights are the following

a. The right to withdraw consent.If you previously consented under Article 6(1)(a) of the GDPR to the processing of your data, you have the right to withdraw this consent at any time. It means that we will stop the processing of the personal data for the processing of which the consent was required starting from the date of the withdrawal.

b. The right of access.You have the right to obtain from us the confirmation as to whether or not the data concerning you are being processed, and, if we indeed process your personal data, to receive a copy of your personal data which we hold.

c. The right to correction.You have the right to obtain from us the correction of inaccurate personal data concerning you.

d. The right to erasure (or the right “to be forgotten”).You have the right to obtain from us the erasure (removal) of your personal data. Upon your request, your personal data shall be removed. This right shall be applied if:

• • your personal data are no longer needed for the purposes for which these data were collected;
  • you have withdrawn your consent (if you have provided this consent) and there are no other legal bases for further processing;
  • the data are processed unlawfully;
  • there are no any restrictions of this right by the applicable legislation;
  • in other cases when the erasure (removal) is required or permitted by the applicable law.

e. The right to object to processing. You have the right to object, on grounds relating to your particular situation, to processing of your personal data, if the grounds of this processing were necessary for the purposes of the legitimate interests pursued by the Company or by the third party (Article 6(1)(f) of the GDPR)or this processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company (Article 6(1)(e) of the GDPR).  Additionally, you have the right to object to the processing of your personal data for direct marketing purposes.

f. The right to restriction of the processing.You have the right to obtain from us restriction of processing, in case if one of the following applies:

• • • you contested to the accuracy of the personal data, for a period enabling the Сompanyto verify the accuracy of the personal data;
    • processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
    • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
    • you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of the Company.

g. The right to data portability.You have the right to receive from us the data which were collected from you, in a structured, machine-readable format and have the right to transmit those data to another controller (in a plain language, to another company). Nevertheless, this rule applies only to processing which:

• • • Was carried out by automated means;
    • Isbased on Articles 6(1)(a) and 9(2)(a) of the GDPR (consent) or is based on Article 6(1)(b) of the GDPR- processing which was carried out under the contract between you and us.

h. The right to lodge a complaint with the supervisory authority.You can always contact us for any issue with regard to the processing of your data, including complaints. Nevertheless, if you suppose that your rights under applicable data protection legislation have been violated, you can lodge a complaint either:

• • • Withthe Office of the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our incorporation). The Website of the Commissioner http://www.dataprotection.gov.cy/; or
    • With the data protection authority of the country of your habitual residence. You can find the list of all EU`s Data Protection Authorities on the Website of the European Data Protection Board https://edpb.europa.eu/about-edpb/board/members_en.

Cookie Policy.

The Website uses cookies. A cookie is a small file of letters and numbers that placed on your electronic device. We use these cookies for various purposes.

We use cookies in order to:

• • Protect this Website from the cyberattacks or any form of abuse (“security cookies”);
  • Some cookies are essential in order to provide you with the Website. If these cookies are disabled, the Website will not work (“essential cookies”);
  • Distinguish you from other visitors and users of the Website, which helps the Company to provide you with a good experience when you browse the Website and allows the Company to improve the Website (“analytics cookies” and other applicable).

Cookies used by the Website.

Essential and Security Cookies. These cookies are essential and enable you to use the Website and provide access to the features of the Website. Some cookies (see below) are used in order to protect this Website. These cookies cannot be disabled.

Analytics. We use Analytics cookies to collect information about how visitors use our website. You can always disable these cookies through our cookie consent tool.