PRIVACY & COOKIE POLICY

Last updated: 07/09/2024

Lumenwriter Platform described herein and represented by PANIMPEX LTD, a company incorporated under the laws of Cyprus, registered number HE 435789, having its registered address and address for correspondence at 25 Martiou, 27, D. Michael Tower, office 105A, ‘Egkomi, 2408, Nicosia, Cyprus (hereinafter referred to as “Platform”, “we”, “our” and “us”) is always committed to maintaining the accuracy, confidentiality, and security of the Personal Data of each user and is a privacy conscious organization.

All capitalized terms used herein and not otherwise defined in these Terms will have the meaning set forth in Terms of Service.

1. For what purposes we may use your Personal Data?

We may collect and use your Personal Data with your consent to provide you with access to the Platform and our Services, contact you about your account and our Services, and to detect, prevent, mitigate and investigate fraudulent or illegal activities. Personal information you submit to us may be used to manage our relationship with you, including any of your requests, or to customize or improve the Platform and related Services offered to you. 

When we believe it is necessary to comply with applicable laws or to exercise or defend our legal rights or protect your legal interests or those of any third party, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory authorities and other organizations, courts, pre-trial investigation institutions, or as otherwise required or permitted by applicable laws.

2. Definitions and Rights

For the purposes of this Provision the following definitions will be used:

«Controller» means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Your Personal Data Controller is PANIMPEX LTD, a company incorporated under the laws of Cyprus, registered number HE 435789, having its registered address and address for correspondence at 25 Martiou, 27, D. Michael Tower, office 105A, ‘Egkomi, 2408, Nicosia, Cyprus. If you have any requests, questions or concerns about our use of your Personal Data and this Privacy Notice, please contact us at [email protected]. The person submitting the request must clearly indicate his/her full name and add a copy of his/her personal identification document or sign the request electronically.

The Controller is responsible for the collection, use, disclosure, retention and protection of your personal information.

«Processor» means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

Being a Data Subject, each user has the following rights:

2.1 THE RIGHT OF ACCESS TO DATA: You have the right to be informed about the Personal Data we collect from you, and how we process it.

2.2 THE RIGHT OF RECTIFICATION: the right to obtain from the Controller the rectification of inaccurate Personal Data concerning the User or to have the incomplete Personal Data completed by providing a relevant request.

2.3 THE RIGHT TO BE FORGOTTEN / TO ERASURE: the right to obtain from the Controller the erasure of Personal Data concerning the User.

2.4 THE RIGHT TO RESTRICTION OF PROCESSING: the right to obtain from the Controller restriction of processing Personal Data concerning the User.

2.5 THE RIGHT TO OBJECT: the right to object to the processing of the Personal Data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.

2.6 THE RIGHT TO LODGE A COMPLAINT: the right to lodge a complaint with a supervisory authority in Cyprus – The Commissioner for personal data protection.

2.7. THE RIGHT TO DATA PORTABILITY: the right to receive the Personal Data concerning the User, which was provided by the User for the Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Controller to which the Personal Data have been provided.

3. Children’s privacy protection

We understand the importance of protecting children’s online privacy. Our Platform is considered to be general audience and is targeted at adults of the legal age of majority in his/her country and state of residence.
4. Legal basis

We collect and process Personal Data in accordance with Data Protection Act 2018, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation) and other legal acts. All employees, agents and employees of the agents of PANIMPEX LTD who know the secret of the Personal Data must keep it safe even after termination of the employment or contractual relationship.

5. What measures do we apply for the information security?

We have in place reasonable commercial standards of technology and operational security and appropriate legal measures to protect all personal information provided by Users from unauthorized access, disclosure, alteration, risks of loss, misuse or unlawful erasure, as well as from any other unauthorized form of processing.

6. Changes to this Privacy Notice and future developments

We continually improve and update our Platform to enhance your experience and the Services we provide for you. As a result, our Privacy Notice continues to evolve. As soon as we implement new technology or provide new services, we will update our Privacy Notice accordingly. We encourage you to refer to this page on an ongoing basis for our most current Privacy Notice and practices.

If our information practices change at any time in the future, we will post the notice changes on this page including the effective date of the amended version of the Privacy Notice and such modified or amended Privacy Notice shall be effective as to you and your information as of that effective date. If we make any material changes, we will announce it and notify you by means of a notice on this Platfrom’s website.

7. Final provisions

7.1 These Privacy Notice provisions are subject to the law of the Republic of Cyprus. All the disputes regarding the provisions of this Privacy Notice shall be settled by negotiation and, in case of failure to resolve an issue by negotiation, the dispute shall be taken to courts of the Republic of Cyprus.

7.2 By visiting our Platform and/or using the Services of the Platform, you acknowledge and confirm that you have read the Privacy Notice, understand it and agree with it. We kindly ask you to note that when visiting this website, you have a responsibility to make sure that you are familiar with the latest version of the Privacy Notice that applies to you at the time you are visiting the website.

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