Privacy policy

The Introduction

Here, at (“Website”), we strongly value your privacy and strive to make every feasible effort to execute the processing of your data protected and secure. In this Policy, you are to discover the information about how we process your data: the objectives of the processing, examples of the data we receive from you, the storage duration of the data we obtain from you, the objects of your data, your rights and additional information you have to learn in regard to the processing of your data.

1. Who are we?

The Website is owned and operated by NITAYA INVESTMENTS LIMITED (“The Company,” “We,” “Our”), consolidated following the legislation of Cyprus, having its registered number ΗΕ 384793, with its registered address at Veroias, 3 Monovolikos 4, Kato Polemidia, 4150, Limassol, Cyprus. The Company is the Data Controller under the Regulation 2016/679 of the EU and the Council (“GDPR”).

1.1 How can you get in touch with us?

In case you have any possible issues concerning your privacy or your personal data processing, or you got any difficulties, or you are in need of making a complaint, please, get in touch with our Support team through e-mail and express your issues. Your request will be delivered to the appropriate department that will help you with your case.

2. What personal data concerning you do we collect and when?

2.1 When you surf or utilize the Website, the following data regarding you is automatically collected (“Automatically collected data”):

  • Information about your device. When you surf the Website, we track the data concerning your device (mobile device or PC), unique device ID (if relevant), operating system, type of browser and its version, time-zone, established language.
  • Your IP location, your data location, information regarding your mobile carrier operator, or Internet provider.
  • Information concerning the source which you used to get into the Website.
  • Information collected and managed by cookies (to figure out how the Website employs cookies, please, see the cookies section or go to our Cookies Policy).
  • We also keep the data on your presence on the Website with the number of times you log into the Website, the subpages you went through, access time, and extra information concerning your browsing time.
  • Information on whether you have agreed to get personalized content or materials or whether or not you have accepted our Privacy Policy, Cookies Policy, and other relevant documents.

2.2 When conveying a message to us by the interface of the Website or if you send an email to us directly, or when you subscribe to our weekly mailing list, you are to lodge to us the next data (“Message Data”):

  • Information concerning your e-mail.
  • Information regarding the status of your subscription to our weekly mailing list.
  • The point of your request.

3. How do we utilize your data, and on what legal grounds?

The Company shall use the data obtained from you for the subsequent needs and on the next lawful grounds:

Objectives of the processing Legal Ground of the processing
To manage the Website and guard our Company. We utilize your data to stop fraud, unlawful or criminal activity, protect the Website, and the Company's technical infrastructure.  The processing is needed in order to have the lawful interests pursued by the Company.

To provide you with the Website designed for your interests, geography, and likings. Examples cover, but are not limited to the following:

a) we might give you an access to the Website in your language;  

b) we may provide you with the Website designed for your geography and likings.

The processing is needed in order to have the lawful interests pursued by the Company.
To give you the content, articles, and materials made for your interest and favorites (upon your apparent approval). Your Consent.
To establish new peculiarities of the Website. We may anonymize your data (by excluding individually identifiable data from data sets) and make an examination and analysis. This will assist us in finding out how users of specific audiences use the Website. Using this data, we are to develop the Website in a way that fits our audiences' concerns.   After the anonymization, your information shall no longer be classified as personal data. This processing is not banned by the law and does not need any particular agreement.
To be in accordance with the law, requests of the government agencies, court or police (if relevant).  The processing is needed to act in accordance with a legal obligation to which the Company is subject.
To reply to your request or message. Your Consent.
To keep a history of processing activities. The processing is needed to act in accordance with a legal obligation to which the Company is subject.
To mail you our weekly mailing list. Your Consent.

4. Children Protection

The Website is not designed for users below the age of 18 years or below the age asked to engage in gambling in the field of the particular user ("legal age").

The Website does not receive and process the information of users under the legal age. If it is ascertained that any Website user is below the legal age, we are to instantly exclude all the data that was received from the kid. If you are parents or a guardian and figure out that your child or your custody uses the Website in any way, feel free to immediately get in touch with us in order to resolve this issue.

The Company carries no responsibility for any usage of the Website by children or persons under 18. By using the Website, each user or guest certifies and warrants that they have reached the legal age of their jurisdiction.

5. To whom can we reveal your data?

Your data, obtained by this Policy, can be exposed to the next Parties:

5.1 The representatives, affiliates, and sub-contractors of the Company. We can do this to equip you with the Website with it being fully functional. These disclosures shall be based on individual data transfer protocols. It suggests that those parties shall process your information only under this Privacy Policy.

5.2 Service providers, host providers, software providers.

Some functions of the Website or the foundation of the Company may not apply to the Company. That is why, when you surf the Website, your data may be given to those third parties.

5.3 Analytics

We use Analytics to understand our guests' requirements better and optimize users' experience on the Website.

Google Analytics

Google Analytics is a web analytics assistance granted by Google that follows and records website traffic. Google utilizes the data gathered to track and observe the performance of our Website. This data is distributed with other Google settings. Google Analytics Opt-out Browser Add-on accommodates guests and users with the capability to stop their data from being accumulated and handled by Google Analytics. To install Google Analytics Opt-out Browser Add-on, please, use this link:


Hotjar is a technology service that aims to help us fully understand our guests' activity (e.g., how much time they surf and which pages, which links they prefer to click, etc.), and this allows us to manage and develop our Website. Hotjar uses cookies and additional technologies to accumulate data on our users' behavior and their devices (it means a device's IP location (obtained and kept only in anonymized form), device screen size, information concerning browser, type of device (individual device identifiers), chosen language used to display our Website), geographic area (country only). Hotjar keeps this data in a pseudonymized user form. Neither Hotjar nor we will ever use this information to recognize different users or to coordinate it with further data on an individual user. For extra details, please go to Hotjar's privacy policy (

5.4 To the regulatory authorities, such as governing bodies, police, courts in case of their legal inquiry.

6. How long do we keep your data?

We shall save your Automatically collected data and Message data as long as we require them to accommodate you with the Website or resolve your issues. In some particular cases, we might keep your information for an extra period, if needed by the law.

As was defined before, we are to use your data after the anonymization procedure. We want to assure you that the data a) shall include no information that can be described as "personal data"; and b) shall bear no information by usage of which you can be recognized.

7. Your rights

As the data subject, you bear the number of rights that you can recognize by getting in touch with our Support Team through email:

These rights include:

The right to access. You bear the right to receive from the Company proof as to whether or not individual information regarding you is processed. If the Company admittedly processes your data, to obtain a copy of the personal data supporting processing.

The right to correct. You can always request the Company for the correction of incorrect private data concerning you.

The right to erase. You can always request the Company to exclude all the private data we receive from you. We will eliminate every beforehand received individual data if we do not need these for the purposes the information was collected.

The right to object to processing. You bear the right to object, on grounds relating to your precise situation, to processing of your data, if the bases of this processing were essential for the needs of the legal matters pursued by the Company. Besides, you own the right to object to the processing of your data for direct marketing goals (if appropriate).

The right to restrict the processing. You hold the right to receive from the Company restraint of the processing when one of the subsequent applies:

a) you opposed to the correctness of the personal data;

b) the processing is illegal, and you face the cancellation of the private data and inquire the limitation of their use alternatively;

c) the Company no longer require the private data for the processing, but they are asked by you for the establishment, exercise or defense of legal requests;

d) you have opposed to processing based on your right to object pending to confirmation whether your legal grounds annul those of the Company.

The right to withdraw consent. If you previously agreed to your data processing, you bear the right to revoke this approval at any time. It also means that we shall end the processing of the private information for the processing of which the approval was required, beginning from the date of the removal. The exclusion of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

The right to have data portability. You possess the right to obtain from the Company the records, which were received from you, in a structured, machine-readable form and retain the right to transfer those data to another controller (in other words, to another company).

Please keep in mind that these rights are relevant only with some limitations:

  • Suppose we are not certain about the identification of the requestor. In that situation, The Company shall confirm a guest/visitor's personality who asks for realizing any of the rights before executing this right.
  • We may limit the rights defined before or reject the realization of any of the rights if this constraint or rejection is based on the Company's legislation. The Company shall also blueprint to you the reason for the refusal in response to your request.

8. Information concerning complaints

Feel free to always get in touch with our Support Team for any matter regarding your privacy, including complaints. Although, if you believe that your rights following the data protection legislation have been violated, you can make a complaint with The Office of The Commissioner for private data guard of the Republic of Cyprus. The Commissioner website:

9. How do we protect your data?

We guard your information by utilizing the legal methodology and technical methodology:

  •  Legal methodology. We implement this methodology by employing individual data transfer arrangements with the Company's representatives, subcontractors, and affiliates. It suggests that they will be required to follow this Privacy Policy.
  • Technical methodology. Proper encryption standards ensure all your data safety. It suggests that it is almost impossible to obtain your information having no decryption keys in a matter of any possible data breach.

10. Cookies.

Our Website applies cookies. A cookie is a tiny record of letters and numbers that we place on your electronic device. These cookies enable us to identify you among other users of our Website, which assists us in providing you with a great experience when you surf our Website and also permits us to develop our site. In case you need more information about Cookies, please, follow Cookie Policy.

11. Transfer of the data outside the European Union (For EEA residents).

Please bear in mind that some parts of our company group are settled outside the European Economic Area. It suggests that legislation on data security may not be so severe as the legislation, which is in force in the European Union. Some of your information will be assigned to these jurisdictions. Furthermore, we want to inform you that we employ all means to force all parts of all our business groups, including our non-EU business associates, to treat your data under The General Data Protection Regulation (EU) 2016/679 (in other words, "GDPR"). In case you agree to this Policy, you as a result of this consent to these transfers. You can revoke this agreement at any time, but in this instance, the functions of the Website will not be accessible for you.

12. Third-party Websites.

Please bear in mind that our Website may include links to the Websites run by third parties — for instance, banners of third-party trademarks or hyperlinks to third-party websites, etc. Please also remember that you use those banners or links at your peril. The Company has no responsibility for the content on those Websites. The Company also carries no responsivity on anything, which can happen due to your stay at those third-party Websites. We strongly advise you to attend "Privacy Policy" or "Privacy Notice" or another privacy document on the third-party Website prior to submitting any data to the latter.

13. Updates to this Policy Policy.

We may amend this Privacy Policy occasionally. If we do so, we will contact you to let you know by changing the date of this Policy Policy. We urge you to examine the Privacy Policy each time you access our Website. By keeping using our Website after Privacy Policy updates go live, you accept to be treated by the amended Privacy Policy.