Privacy Policy
This privacy policy (“Privacy Policy”) describes how information and data is collected from you when you use this online website, mobile website, or any related products, services, sites, features or functionality (each a “Service”, collectively the “Services”) that link to this Privacy Policy, and how ZOELINE MANAGEMENT LTD (“Zoeline Management” or “we” or “us” or “our”), uses, shares and manages your information and data. By using any of the Services, you consent to the collection, use, processing, and sharing of your information as described in this Privacy Policy.
Who we are
ZOELINE MANAGEMENT LTD is a company duly incorporated and existing under the laws of The Republic of Cyprus, with head office located at 53, Ptolemaion street, office 102, Neroupos Business Centre 3041 Limassol, Cyprus.

You can always contact us via the following methods:
Address: 53, Ptolemaion street, office 102, Neroupos Business Centre 3041 Limassol, Cyprus
Phone: +357 25350307
Email address: office@zoelinem.com

While visiting our website, you agree to this Privacy Policy.
As data controller, we determine how we process your personal data, for what purposes and by what means. While we are required by law to provide you with all of the following information, we do so primarily out of the belief that our relationship should always be honest and transparent.

As data controller we are responsible that all our processing activities are in accordance with legal requirements but also you may reasonably expect these processing of your personal data (legitimate interest).

If you have any questions about data protection at Zoeline Management, you can also contact us by emailing office@zoelinem.com

Definitions and Interpretation
In this Privacy Policy, unless the context otherwise requires:
“Data Protection Laws” shall mean all laws governing the handling of Personal Data, including without limitation the following as amended, extended, re-enacted or replaced from time to time.

  1. EC Regulation 2016/679 (the “GDPR”) on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (when in force);
  2. all local laws or regulations implementing or supplementing the EU legislation mentioned above;
  3. all codes of practice and guidance issued by national regulators relating to the laws, regulations and EU legislation mentioned above.

“Data Controller” means Zoeline Management;

“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

“Process, Processing and Processed” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Supervisory Authority” means the Office of the Commissioner for Personal Data Protection in Cyprus; and ‘Third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

1. Our Privacy Principles
We are committed to recognising and respecting your privacy rights by keeping you informed and processing and protecting your personal data in compliance with applicable Data Protection Laws.

If you are located outside of the European Union and you choose to use the Website, your data may be transferred to, processed and maintained on servers, databases or cloud storage facilities. Your use of the Website represents your consent and agreement to these practices. If you do not want your data transferred to or processed or maintained, you should not use the Website.
2. Information that We Collect from You
Usage Data We Automatically Collect from You:

  • Device Registration Data (for example, the type of mobile device you use, your mobile device’s unique device or advertising ID, IP address, operating system and browser type)
  • Device Settings (for example, your language preference)
  • Information about how you use the Services (for example, how many times you use the Services each day)
  • Requested and Referring URLs
  • Location Data collected through your Device (including, for example, precise location data such as GPS and WiFi information)
  • Information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access
3. How We Use Your Personal Data & Legal Bases
If you access the Website through a browser, your browser may allow you to adjust your browser settings so that “Do Not Track” requests are sent to the websites that you visit. However, we will not disable tracking technology that may be active on the Website in response to any Do Not Track requests that we receive from your browser. You can change your privacy preferences regarding the use of cookies and other similar technologies through your browser. You may set your browser to accept all cookies, block certain cookies, require our consent before a cookie is placed in your browser, or block all cookies. Blocking all cookies will affect your online experience and may prevent you from enjoying the full features offered through the Services.

You may opt out of the collection, use, and transfer of precise location data for location-based advertising purposes, by using the location services controls in your mobile device’s settings.

Legal Bases: consent, legitimate interest where consent is not required (to enable us to provide you with an experience related to your interests)

Analytics Services. We may also work with third party analytics companies to help us understand how the Website is being used, such as data collection, reporting, website and mobile application analytics etc.

We may use Google Analytics, an analytics service provided by Google or other third party analytics services providers (“Analytics Services”) to collect information about your use of the Services. These Analytics Services may collect information about the content you view and your system information and geographic information. The information generated by the Analytics Services about your use of the Services will be transmitted to and stored by the Analytics Services. The information collected by the Analytics Services allows us to analyze your use of the Services.

We encourage you to review your device and Services settings to ensure they are consistent with your preferences, including with respect to the collection and use of information. You may be able to stop further collection of certain data by the Services by updating your applicable device settings, or you may uninstall the Services. In addition, you may choose not to share your location details by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider/carrier or device manufacturer.

Legal Bases: consent, legitimate interests (to enable us to perform our obligations); contract performance

Our business purposes include:

  • Auditing related to our interactions with you;
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Performing services (for us or our service provider) such as account servicing, processing orders and payments, marketing and analytics;
  • Internal research for technological improvement;
  • Internal operations;
  • Activities to maintain and improve our services; and
  • Other one-time uses.
4. Cookies
Zoeline Management may use cookies as part of the facilitation and the operation of the Services through our Website. Cookies are small text files that are sent and stored on the user’s computer, allowing websites such as www.artvesta-consulting.com to function seamlessly and without technical abnormalities, collect multiple user options, identify frequent users, facilitate their access to it and collect data to improve the content of the site.

Cookies do not harm users’ computers, or the files stored on them.

Cookies don’t store personal details such as your credit card details, your name or your date of birth.

You should keep in mind that certain cookies are absolutely necessary for our website to function properly and seamlessly.

Cookies are divided to the following categories:

– Necessary Cookies
– Functionality Cookies
– Performance Cookies
– Advertisement Cookies
– Analytics Cookies

You can adjust your browser (chrome, firefox, edge etc.) to inform you every time a cookie is to be received so you can decide whether to accept it or not. Bear in mind that in this case you might not be able to fully utilize all of the website’s potentials.

Zoeline Management can use Google Analytics functions for promoting advertisements (e.g. repeated marketing, Google Display Network reports etc.). Using the Advertisement settings, users can opt out from Google Analytics regarding display advertisements but also Google’s Display Network advertisements.

We reserve the right to alter this policy for cookies at any time. All changes made in this Cookies policy will take effect as soon as the revised Cookies policy is available in our website.

Third party advertisers and other companies we collaborate with may use their own Cookies to collect information regarding your activities on our website. We have no control over those Cookies.

5. How Your Information is Shared with Third Parties
We may share the information you provide or that we collect in some circumstances as follows:

With Advertisers. We may share your information with advertisers, third-party advertising networks and analytics companies who may use it to deliver targeted advertisements to you on the Services or third-party websites or advertisers. Similarly, these advertisers may share information with us about you that they have independently gathered or acquired. We may also share encrypted versions of information we have collected in order to enable our advertising partners to perform data analysis or for advertising-related use.

With Our Service Providers. We may share your information with our service providers who work on our behalf. These service providers will only have access to the information needed to perform these limited functions on our behalf.

Social Media and Sharing. The Services may use social networking or “share functionality” or may contain links to third-party social media sites or applications that are not owned or controlled by us. We also may allow you to use social media sites or applications to leverage your existing social media site or application accounts to access features of the Services. Your use of these features may result in the collection or sharing of information about you by these sites or applications, depending on the feature.

We have no control over, and assume no responsibility for, any share functionality or the content, privacy policies, or practices of any third-party site or application. We encourage you to review the privacy policies and settings on the social media sites or applications with which you interact to make sure you understand the information that may be collected, used, and shared by those sites. You are subject to the policies of those third parties when and where applicable.

As required by law or to protect rights and to comply with our policies. To the extent permitted by law, we will disclose your information to government authorities or third parties, including national security or law enforcement agencies, if required to do so by law, or if requested in response to a subpoena or court order, we believe in our sole and absolute discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large, or we believe that you have abused the Services by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws or in violation of our Terms of Use. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

Business Transfers or Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets or any business, any user information owned or controlled by us may be one of the assets transferred to third parties in such transaction or event. We reserve the right, as part of this type of transaction or event, to transfer or assign your information and other information we have collected from users of the Services to third parties. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity or acquirer, as applicable.
6. The Privacy of Children
The Website is not intended for children under age 16. We do not knowingly collect or distribute personal information from or about children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@artvesta-consulting.com.
7. Your rights
You can also make use of the following rights at any time:

  • Withdraw consent
Where you have consented to us using your personal data, you can withdraw that consent at any time.

  • Right to access
You have the right to be informed which data we store about you and how we process this data.

  • Right to rectification
If you notice that stored data is incorrect, you can always ask us to correct it.

  • Right to erasure
You can ask us at any time to delete the data we have stored about you.

  • Right to restriction of processing
If you do not wish to delete your data, but do not want us to process it further, you can ask us to restrict the processing of your personal data. In this case, we will archive your data and only reintegrate it into our operative systems if you so wish. However, during this time you will not be able to use our Services, otherwise we will process your data again.

  • Right to data portability
You can ask us to transmit the data stored about you in a machine-readable format to you or to another responsible person. If you choose to exercise this right, then in certain circumstances any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

  • Right to object to the processing of your data
You can revoke your consent at any time or object to the further processing of your data. This also includes objecting to our processing, which we process without your consent but based on our legitimate interest. This applies, for example, to direct marketing. You can object to receiving further newsletters at any time. If you do not agree with one of our processing purposes based on our legitimate interest or wish to object to it, you may object to the processing at any time on grounds relating to your particular situation. Please write an email to info@artvesta-consulting.com In this case we will review the processing activity again and either stop processing your data for this purpose or explain to you our reasons worth protecting and why we will continue with the processing.

  • Right of complaint
If you believe that we have done something wrong with your personal data or your rights, you can complain to the appropriate supervisory authority at any time.

The supervisory authority responsible for us is:
Name of the supervisory authority: Office of the Commissioner for Personal Data Protection
Address: Iasonos 1, 1082 Nicosia, Cyprus
Telephone: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
You may Lodge a complaint with our data protection authority at http://www.dataprotection.gov.cy

To exercise these rights, we need to be suitably satisfied of your identity and so may request you provide identification documents or confirm other details we may hold about you (such as a recent delivery reference or address).

8. Security Measures and Storage Limits
We provide industry-standard physical, electronic, and procedural safeguards to protect personal data we process and maintain. For example, we take reasonable measures to limit access to this data to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. Please be aware that, although we endeavour to provide reasonable security for data we process and maintain, no security system can prevent all potential security breaches. As a result, we cannot guarantee or warrant the security of any information you transmit on or through the Services and you do so at your own risk.

Our retention periods for personal data are based on our business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose.
9. Updates to this Privacy Policy
We will notify you of material changes to this Privacy Policy by at least thirty (30) days before the effective date of the changes. If you do not agree to such changes following such notice, you should discontinue your use of the Services prior to the time the modified privacy policy takes effect. If you continue using the Services after the modified privacy policy takes effect, you will be bound by the modified privacy policy.
Zoeline Management 2023