1. Web Site - Data Privacy Policy
By entering into DW Dynamic Works Ltd websites your personal data are been protected according to the GDPR requirements. Any process of your personal data is based on the C.I.A. (confidentiality, Integrity and Availability). Any processing of your personal data is in accordance with the legal data protection regulations as well as this Data Privacy Policy.
This policy discloses the way DW Dynamic Works Ltd handles personal data on the internet, information concerning users that is being recorded and analysed, and how this information is used, shared or otherwise processed. It is furthermore described how cookies and other technologies can be used in our applications.
When calling up our website, you will be informed about the use of cookies for analysis purposes. In this process, it will also be referred to this Data Privacy Policy.
By using our website, you declare your consent to the gathering and use of your personal data in the way described in this Data Privacy Policy. This is recognition that DW Dynamic Works Ltd can change and update this Data Privacy Policy regularly at our own discretion. In that case, we will publish updated versions of this Data Privacy Policy on this webpage.
It is recommended that you check this page carefully and regularly for updated information about our data privacy policy.
The DW Dynamic Works Ltd Privacy Policy will be updated accordingly at any point in time, if needed.
Name and address of the data controller and Data Protection Officer
Any Data Subject and or physical person has the right to communication with DW Dynamic Works Ltd for any related questions or exercise his or hers rights concerning his or hers personal data.
It is recommended that you check this page carefully and regularly for updated information about our data privacy policy.
The DW Dynamic Works Ltd Privacy Policy will be updated accordingly at any point in time, if needed.
Name and address of the data controller and Data Protection Officer
Any Data Subject and or physical person has the right to communication with DW Dynamic Works Ltd for any related questions or exercise his or hers rights concerning his or hers personal data.
Data Controller: DW Dynamic Works Ltd
Data Prodection Officer: Stelios Sakkas - T.I.M.S. LTD
Data Controller Address: 1, Diogenous Street, Block A, 5th floor 2404 Engomi, Nicosia - CYPRUS
Data Controller Telephone and email: 22 427900 [email protected]
2. General remarks on data processing
2.1 Processing Personal Data by DW Dynamic Works Ltd.
The policy of our company, DW Dynamic Works Ltd, assures that in its cooperation measures with any party, it will be in full compliance with General Data Protection Regulation 2016/679. We achieve this through the full implementation of an effective system of safeguarding and protecting personal data that we collect from any natural person and with full respect for the rights of individuals.
Our goal is to collect Personal Data that is absolutely necessary and consistent with serving the legal basis for which these Data have been collected.
Our goal is to collect and process Personal Data that are:
- Consistent with the purpose for which they were originally collected
- Only necessary
- Correct and up-to-date
- Only maintained for as long as they are absolutely necessary
- protected by appropriate and organizational security measures
- Reviewed regularly to take account of new technological developments
- Encrypted or used by pseudonymization where it is possible instead of using actual data
In addition to DW Dynamic Works ltd always takes into consideration the rights of natural persons by whom it has received its Personal Data in such a way that it contributes to the strengthening of the existing rights granted to them as follows:
- Right to be provided with information
- Right of access
- Right to rectification
- Right to be forgotten (right to erase)
- Right to restriction
- Right to data portability
- Right to object
- Right to object to automated decision-making, including profiling (automated decision-making, including profiling)
With this policy DW Dynamic Works Ltd commits in preventing any possible violation of the rights of individuals and protecting them in such a way that the natural persons will fully trust DW Dynamic Works Ltd when their Personal Data are being processed.
Any process of physical person’s personal data is based on the C.I.A. (confidentiality, Integrity and Availability). Any processing of physical person’s personal data is in accordance with the legal data protection regulations as well as this Data Privacy Policy.
All of the above will be implemented through an organized system designed to record and monitor the GDPR system from the beginning of the collection to the final recipient. The system is controlled at frequent intervals through documented internal audits, providing feedback to DW Dynamic Works ltd's management for improvement.
2.2 Scope of the processing of personal data
DW Dynamic Works Ltd uses your personal data as described in this Data Privacy Policy, in order to make our services available, to respond to your enquiries, and to the extent it is legally permissible or required or to assist in legal or criminal investigations. DW Dynamic Works Ltd can further anonymise and aggregate data gathered via this website for statistical purposes to expand our product portfolio and improve our services.
2.3 With whom does DW Dynamic Works Ltd share your personal data?
DW Dynamic Works Ltd can store your personal data or otherwise pass it on to our affiliates or further trustworthy business partners, who perform services in our name, for example, for technical support to evaluate the usefulness of this website for marketing purposes or other types of service provision. DW Dynamic Works Ltd has conducted contracts with these parties especially for Personal Data Control so as to ensure that personal data is processed on the basis of our instructions and in compliance with this Data Privacy Policy, and other suitable measures regarding confidentiality and security and Availability. DW Dynamic Works Ltd passes on your personal data to these parties and other third parties exclusively to the required extent in order to perform services that you have requested or authorised and to protect yours and our rights, property or security or, if DW Dynamic Works Ltd is obligated to do so based on applicable laws, orders by courts or other authorities. In any cased of data breach or any disclosure DW Dynamic Works Ltd will assist by any means in order to assist in legal or criminal investigations or court proceedings.
DW Dynamic Works Ltd as well as related parties as authorities, customers and suppliers to whom DW Dynamic Works Ltd may pass on your personal data, might possibly be hosted outside of your home country, and potentially also in countries with data protection laws that can differ from those applicable in the country where you are. In such cases, DW Dynamic Works Ltd will ensure that suitable measures for the protection of your personal data are taken by introducing suitable legal mechanisms, e.g. EU standard contract clauses. You can find a copy of the EU standard contract clauses at: ec.europa.eu/justice/data-protection/international-transfers/transfer
2.4 Legal basis for the processing of personal data
When DW Dynamic Works Ltd obtains consent from any data subject for the processing of personal data, Art. 6 (1) lit. a) EU General Data Protection Regulation (GDPR) applies as the legal basis for the processing of personal data.
In the processing of personal data that is required for the fulfilment of a contract to which the data subject is a party, Art. 6 (1) lit. b) GDPR serves as the legal basis. This also applies to processing that is required to conduct pre-contractual measures.
Where processing of personal data is required for the fulfilment of a legal obligation imposed on our company, Art. 6 (1) lit. c) GDPR serves as the legal basis.
In the case that vital interests of the data subjects or another natural person necessitate the processing of personal data, Art. 6 (1) lit. d) GDPR serves as the legal basis.
If the processing serves to protect a justified interest of our company or of a third party and if the interests, civil rights and fundamental freedoms of the data subject do not outweigh the interest mentioned first, Art. 6 (1) lit. f) GDPR serves as the legal basis for the processing.
2.5 Data deletion and period of storage
The personal data of the data subjects will be deleted or blocked as soon as the purpose for storing it ceases to apply. The Personal Data will be deleted when a storage period expires that is prescribed by and as it is defined within the Register of Activities for Personal Data, unless there is a necessity for the continued storage of the data for a contract conclusion or contract fulfilment.
· Provision of the website and creation of logfiles
1. Description and scope of the data processing
On each retrieval of our website, our system automatically gathers data and information from the computer system of the accessing computer. The following data is gathered in this process:
(1) Information on the browser type and the version used
(2) The user’s operating system
(3) The user’s IP address
(4) Data and time of the access
(5) Websites from which the user’s system reaches our website
(6) Websites that are called up by the user’s system via our website
The data will likewise be stored in the logfiles of our system. This data will not be stored together with other personal data of the user.
2. Legal basis for the data processing
The legal basis for the temporary storing of the data and logfiles is Art. 6 (1) lit. f) GDPR.
3. Purpose of the data processing
The temporary storing of the IP address by the system is necessary to enable a delivery of the website to the computer of the user. For this purpose, the user’s IP address must remain stored for the duration of the session. The logfiles are stored in order to ensure the functionality of the website. In addition, the data helps DW Dynamic Works Ltd optimise the website and ensure the security of our IT systems. The data is not analysed for marketing purposes in this context. These purposes are also justified interests of ours in the data processing pursuant to Art. 6 (1) lit. f) GDPR.
4. Duration of the storing
The data will be deleted, as soon as it is no longer needed to achieve the purpose for gathering it. This will be the case when the respective session is ended in the case that data is gathered for the purpose of providing this website. In the event that the data is stored in logfiles, deletion will take place at the latest after seven days. Storing beyond this point is possible. In that case, the users’ IP addresses will be deleted or anonymised, so that it will not be possible anymore to attribute them to the retrieving client.
5. Possibility for objection and removal
The gathering of the data for the purpose of providing the website and the storing of the data in logfiles is necessarily required for the operation of the website. Consequently, there is no possibility to object for the user.
· Use of cookies
a) Description and scope of the data processing
Our website uses cookies. Cookies are text files that are stored in the internet browser or that are stored by the internet browser on the user’s computer system. If a user retrieves a website, a cookie can be stored in the user’s operating system. This cookie contains a sequence of characters that enable a definitive identification of the browser upon repeated retrieval of the website.
DW Dynamic Works Ltd uses cookies to make our website more user friendly. Some elements of our website require that the retrieving browser can also be identified after a different page is called up. DW Dynamic Works Ltd differentiates between the following cookies for the use of DW Dynamic Works Ltd website:
Necessary cookies
These cookies are necessary to operate the website and temporarily store session data so that the page is displayed correctly.
Performance cookies
DW Dynamic Works Ltd uses performance cookies so that DW Dynamic Works Ltd can improve the technical performance such as loading speed and image build up.
Functional cookies
These cookies are used by our applications to cache the entered data and thereby assure functionality and customer friendliness.
Advertising cookies
DW Dynamic Works Ltd uses advertising cookies to check the success of our marketing activities.
Third-party cookies
Third-party cookies are cookies, which are set by a person who is in fact responsible for the processing but who is a different person than the operator of the website that is visited by the user.
DW Dynamic Works Ltd uses third-party cookies, e.g. to link our page with LinkedIn, Twitter and/or Facebook and to provide the DW Dynamic Works Ltd users the opportunity to share something directly via LinkedIn, Twitter or Facebook.
Furthermore, DW Dynamic Works Ltd uses Google Analytics, an advertising analysis service of Google Inc. (“Google“). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is generally transmitted to and saved on a server of Google in the USA.
Google will use this information on our behalf to analyse the use of our online offer by the users, to compile reports about the activities within this online offer, and to perform further services for us that are related to this online offer and the internet use. In the process, pseudonymised user profiles of the users can be created from the processed data.
DW Dynamic Works Ltd uses Google Analytics only with activated IP anonymisation. This means, the users’ IP addresses will be truncated by Google within the Member States of the European Union or in other signatory states of the Treaty on the European Economic Zone. The complete IP address will only be transmitted in exceptional cases to a server of Google in the USA and it will be truncated there. The IP address transmitted from the user’s browser will not be combined with other data of Google.
b) Legal basis for the data processing
The legal basis for the processing of personal data by means of technically necessary cookies is Art. 6 (1) lit. f) GDPR. The legal basis for the processing of personal data by means of cookies for analysis purposes, if a consent in this regard has been granted by the user, is Art. 6 (1) lit. a) GDPR.
c) Purpose of the data processing
The purpose of using technically necessary cookies is to enable the users to use the websites. Some features of our websites cannot be offered without the use of cookies. For these, it is required that the browser is recognised even after changing to other webpages.
The user data gathered by the technically necessary cookies is not used to create user profiles.
Analysis cookies (advertising cookies and third-party cookies) are used for the purpose of improving the quality of our website and its contents. DW Dynamic Works Ltd finds out from the analysis cookies how the website is used and we can thereby continuously optimise our offer. They can also be used for the purpose of creating a profile of your interests and displaying relevant advertising on other websites.
The legal basis for the processing of personal data by means of technically necessary cookies is Art. 6 (1) lit. f) GDPR. The legal basis for the processing of personal data by means of cookies for analysis purposes, if a consent in this regard has been granted by the user, is Art. 6 (1) lit. a) GDPR.
d) Duration of the storing, possibility for objection and removal
Cookies are stored on the user’s computer and transmitted from it to our website. Therefore, as a user, you also have full control over the use of cookies. By changing the settings of your internet browser, you can deactivate or limit the transmission of cookies. Cookies already stored can be deleted at any time. This can also be done in an automated process.
· Registration
1. Description and scope of the data processing
DW Dynamic Works Ltd offers users the possibility on our website to register by entering personal data. The data is entered in an input mask in the process and it is transmitted to DW Dynamic Works Ltd and stored by DW Dynamic Works Ltd. The following data is gathered in the course of the registration process:
First name
Last name
Phone
Company details
At the time of the registration, furthermore the following data is stored:
(1) Information on the browser type and the version used
(2) The user’s operating system
(3) The user’s IP address
(4) Data and time of the access
(5) Websites from which the user’s system reaches our website
(6) Websites that are called up by the user’s system via our website
2. Legal basis for the data processing
The legal basis for the processing of the data, if the user has granted a consent, is Art. 6 (1) lit. a) GDPR.
If the registration serves for the fulfilment of a contract to which the user is a party or for the execution of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 (1) lit. b) GDPR.
3. Purpose of the data processing
A registration of the user is required for the fulfilment of a contract to which the user is a party or for the execution of pre-contractual measures.
Subject to your consent, which DW Dynamic Works Ltd asks for specifically for said registration purposes and your option to deregister at any time again, DW Dynamic Works Ltd also uses your data to offer you such of our products and services that can be of interest to you. You can deactivate these services by clicking on “Deregister”. If you request further correspondence from DW Dynamic Works Ltd after this time, DW Dynamic Works Ltd will recreate your subscription and you can then again click on “Deregister” if you would like to unsubscribe again.
4. Duration of the storing
The data will be deleted, as soon as it is no longer needed to achieve the purpose for gathering it.
This will be the case [sic for the data gathered] during the registration process for the fulfilment of a contract or the execution of pre-contractual measures whenever the data is no longer needed for the execution of the contract. A necessity to store personal data of the contractual partner can also apply after conclusion of the contract, in order to fulfil contractual or legal obligations.
The personal data from your account will be stored for as long as required for the purposes for which the data has been gathered or otherwise processed. This does not apply insofar as DW Dynamic Works Ltd are subject to statutory retention periods. Otherwise, the following applies: If you have not used your account for more than 365 days, DW Dynamic Works Ltd will use your email address to inform you that your account will be deleted..
5. Possibility for objection and removal
As a user, you have the option at any time to cancel the registration. You can have the data stored about you be changed at any time. If the data is required for the fulfilment of a contract or execution of pre-contractual measures, a premature deletion of the data is possible only if no contractual or legal obligations are opposed to a deletion.
· Contact form and email contact
1. Description and scope of the data processing
A contact form is available on our website, which can be used to contact DW Dynamic Works Ltd electronically. If a user uses this option, the data entered in the input mask will be transmitted to DW Dynamic Works Ltd and stored by DW Dynamic Works Ltd. This data is:
(1) First name
(2) Last name
(3) Email
(4) City
(5) Country
(6) Postal code
(7) Company
Your consent to the use of the data will be requested in the course of the transmission process and a reference to this Data Privacy Policy will be made.
If contact is offered via a provided email address, the user’s personal data transmitted along with the email will be stored in that case. The data will not be passed on to third parties in this context. The data will be used exclusively for the processing of the communication.
2. Legal basis for the data processing
The legal basis for the processing of the data, if the user has granted a consent, is Art. 6 (1) lit. a) GDPR.
The legal basis for the processing of the data that is transmitted in the course of sending an email is Art. 6 (1) lit. f) GDPR. If the contact by email aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b) GDPR.
3. Purpose of the data processing
The processing of the personal data from the input mask serves solely for our processing of the communication. In the event of contact by email, this is also the required justified interest in the processing of the data. Your data will only be processed only with your explicit consent for purposes other than the ones mentioned. The other personal data processed in the course of the transmission process serves to prevent misuse of the contact form and to ensure the security of our IT systems.
4. Duration of the storing
The data will be deleted, as soon as it is no longer needed to achieve the purpose for gathering it. This is the case, regarding the personal data originating from the input mask of the contact form and the data that has been transmitted with the email, when the respective communication with the user is terminated. The communication is terminated when it can be seen based on the circumstances that the relevant facts have been clarified conclusively.
5. Possibility for objection and removal
The user has the possibility at all times to revoke his/her consent to the processing of personal data. If the user contacts DW Dynamic Works Ltd by email, he/she can object at any time to the storing of his/her personal data. In such a case, the communication cannot be continued.
Please address the revocation of the consent and the objection to the storing to DW Dynamic Works Ltd via the link provided under Sec. VIII.
All personal data that has been stored in the course of the contacting will be deleted in that case.
· Rights of data subjects
If your personal data is processed, you are a data subject in the definition of the GDPR and you have the rights listed below in relation to the data controller.
You can claim your rights at any time at [email protected]
As the Data Subject Rights Map show below there are 8 basic rights that the physical persons can have while they “deliver” their personal data to controllers or the controllers collects those data from them.
These Personal Data Rights of the Data Subjects are discussing in more details below:
1. Right to information
You can demand a confirmation from the data controller of whether personal data relating to you is being processed by DW Dynamic Works Ltd.
If such processing applies, you can demand information from the data controller regarding the following aspects:
- the purposes for which the personal data is processed;
- the categories of personal data that is processed;
- the recipients or categories of recipients to whom personal data relating to you has been disclosed or will be disclosed in the future;
- the planned duration of the storing of the personal data relating to you or, if this cannot be specified concretely, the criteria for determining the storage duration;
- applicability of a right to correction or deletion of the personal data relating to you, a right to restrict the processing by the data controller or a right to object to this processing;
- applicability of a right to complain with a supervisory authority;
- all available information on the origin of the data if the personal data has not been gathered from the data subject;
- applicability of an automated decision-making process including profiling according to Art. 22 (1) and (4) GDPR and – at least in these cases – explanatory information about the involved logic and scope, as well as the intended effects for the data subject from such processing.
You have the right to demand information of whether the personal data relating to you is being transmitted to a third country or an international organisation. In this connection, you can request being informed about the suitable guarantees according to Art. 46 GDPR relating to the transmission.
2. Right to correction
You have a right to the correction and/or completion in relation to the data controller, insofar as the processed personal data relating to you is incorrect or incomplete. The data controller has to make the correction without delay.
