Privacy Notice

The data controller, as defined by the GDPR, is:

Seventh Signal (CY) Ltd.
Arsakeiou 19, 2045 Strovolos, Cyprus

Phone: +357 24 020210

Email: info@seventhsignal.eu

Data controller’s representatives: Christos Christou, Michael Bielicki

You can reach the data protection officer as follows:

Email: dpo@seventhsignal.eu

You may contact our data protection officer directly at any time if you have any questions or suggestions regarding data protection.

This Privacy Notice is based on the terminology used by the European legislature and legislature in the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand, both for the public and for our customers and business partners. To ensure this, we would like to explain in advance the terminology used. Among other things, we use the following terms in this privacy policy.

We use the following terms in this Privacy Notice, among others:

1. Personal data
   Personal data means any information relating to an identified or identifiable natural person. 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.
2. Data subject
   A data subject is any identified or identifiable natural person whose personal data is processed by the data controller (our company).
3. Processing
   Processing 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.
4. Restriction to processing
   Restriction to processing means marking stored personal data with the aim of limiting its processing in future.
5. Profiling
   Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
6. Pseudonymisation
   Pseudonymisation is the processing of personal data in such a way that the data can no longer be assigned to a specific data subject without additional information being provided, given that such additional information is kept separate and subject to appropriate technical and organisational measures that ensure that personal data cannot be attributed to an identified or identifiable natural person.
7. Data processor
   The processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
8. Recipient
   Recipient means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
9. Third parties
   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.
10. Consent
    Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Article 6 Paragraph 1(a) GDPR serves as our company’s legal basis for processing operations in which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Article 6 Paragraph 1(b) GDPR. The same applies to those processing operations required to carry out pre-contractual measures, such as in cases of queries regarding our products or services.

If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Article 6 Paragraph 1(c) GDPR.

In rare cases, processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if someone visiting our business were to be injured and their name, age, health insurance data or other vital information needed to be disclosed to a doctor, hospital or other third party. Processing would then be based on Article 6 Paragraph 1(d) GDPR.

Finally, processing operations could be based on Article 6 Paragraph 1(f) GDPR. Processing operations not based on any of the above-mentioned legal bases may be carried out on the basis of Article 6 Paragraph 1(f) GDPR if the processing is necessary to safeguard the legitimate interests of our company or those of a third party, provided the interests and fundamental rights and freedoms of the data subject do not take precedence. We are permitted to engage in such processing operations in particular because they have been specifically mentioned in European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47 Sentence 2 GDPR).

6.1 SSL/TLS encryption

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login details or contact requests that you send to us as the website operator. You can recognise an encrypted connection by your browser’s address bar reading “https://” instead of “http://” and the lock symbol in the browser bar.

We use this technology to protect your transmitted data.

6.2 Data collection when visiting the website

If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (in what is known as “server log files”). Our website collects a range of general data and information each time you access a website or an automated system. This general data and information is stored in the server’s log files. It may be colltected

1. the types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system accesses our website (called a referrer),
4. the sub-pages accessed via an accessing system on our website,
5. the date and time the website is accessed,
6. a truncated internet protocol address (anonymised IP address) and
7. the accessing system’s internet service provider.

No conclusions are drawn about you when using this general data and information. Instead, this information is needed

1. to properly deliver our website content,
2. to optimise the content of our website as well as to advertise it,
3. to ensure the continued functioning of our IT systems and our website’s technology
4. as well as to provide the information necessary for law enforcement authorities to prosecute in the event of a cyber attack.

This collected data and information is therefore statistically analysed and further analysed by us with the aim of increasing data protection and data security within our company to ultimately ensure an optimum level of protection for the personal data being processed by us. The anonymous data from the server log files is stored separately from all personal data provided by a data subject.

The legal basis for data processing is Article 6 Paragraph 1 Sentence 1(f) GDPR. Our legitimate interest is based on the purposes listed above for the collection of data.

7.1 General information about cookies

We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our website.

Information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity.

The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are erased automatically when you leave our website.

We also use temporary cookies to optimise user-friendliness. These cookies are stored on your device for a specific period of time. If you return to our website to use our services, cookies allow us to automatically recognise that you have visited our website previously and remember the inputs and settings you have made so that you do not have to enter them again.

We also use cookies to statistically record the use of our website and analyse it for the purpose of optimising our services. These cookies allow us to automatically recognise that you have already visited our website when you visit our website again. These cookies are automatically erased after a defined period of time.

7.2 Legal basis for the use of cookies

The data processed by cookies, which are required for the proper functioning of the website, are to safeguard our legitimate interests pursuant to Article 6 Paragraph 1 Sentence 1(f) GDPR.

For all other cookies you have given your consent to this through our opt-in cookie banner in accordance with Article 6 Paragraph 1(a) GDPR.

8.1 Data processing when opening a customer account and for contract execution

Pursuant to Article 6 Paragraph 1(b) GDPR, personal data is collected and processed if you provide it to us for the execution of a contract or when opening a customer account. The data collected is shown in each input form. You may erase your customer account at any time by sending a message to the data controller’s address as stated above. We store and use the data you provide to execute contracts. After complete execution of the contract or erasure of your customer account, your data will be blocked, taking into account tax and commercial retention periods, and erased once these periods have expired unless you have expressly consented to the further use of your data or we are legally permitted to further use your data, about which we will inform you below.

8.2 Data processing for order processing

The personal data we collect is disclosed to the transport company hired to deliver goods under the scope of contract execution, provided this is necessary for the delivery of the goods. We disclose your payment details to the bank commissioned as part of payment processing, provided this is necessary for payment processing. If payment service providers are used, we will explicitly inform you about this below. The legal basis for this transfer of data is Article 6 Paragraph 1(b) GDPR.

8.3 Contact/contact form

Personal data is collected when you contact us (e.g. using our contact form or by email). If you use a contact form to get in touch with us, the contact form you use will indicate the data being collected. This data is stored and used exclusively for the purpose of responding to your query or establishing contact and the associated technical administration. The legal basis for data processing is our legitimate interest in responding to your request pursuant to Article 6 Paragraph 1(f)f GDPR. If the aim of you contacting us is to conclude a contract, processing is also legally based on Article 6 Paragraph 1(b) GDPR. Your data will be erased once we have finished processing your query. This is the case when it can be inferred from the circumstances that the relevant facts have been clarified in a conclusive manner and there are no statutory retention obligations in place that prevent its erasure.

8.4 Comment function on the blog

We offer users the opportunity to leave individual comments on individual blog posts on a blog located on our website. A blog is a portal maintained on a website, usually open to the public, in which one or more people called bloggers or web bloggers can post articles or write thoughts in what are termed blog posts. Blog posts can usually be commented on by third parties.

If you leave a comment on the blog published on this website, your comments will be stored and published, as will information about the date and time of posting the comment and your chosen user name (pseudonym). The IP address assigned by your Internet Service Provider (ISP) is also logged. IP addresses are stored for security reasons and in the event that you have violated the rights of third parties or posted illegal content through a comment. The storage of this personal data is therefore in our own interest so that we can exculpate ourselves in the event of a violation of the law. This represents a legitimate interest within the meaning of Article 6 Paragraph 1(f) GDPR. Personal data collected will not be disclosed to third parties unless such disclosure is required by law or serves our legal defence.

8.5 Application management/job exchange

We collect and process the personal data of applicants for the purpose of carrying out the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents to us electronically, for example by email or via a web form on the website. If we conclude an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If we do not conclude an employment contract with the applicant, the application documents will be automatically erased two (2) months after notification of the rejection decision, provided that no other legitimate interests of ours prevent their erasure.

9.1 Newsletter for regular customers

If you have provided us with your email address when purchasing goods or services, we reserve the right to send you regular emails with offers on products or services from our collection similar to those you have already purchased. We do not require your specific consent for such purposes as per article 7, paragraph 3 of the UWG (Unfair Competition Act). The sole basis for the data processing is our legitimate interest in personalised direct marketing in line with article 6, paragraph 1 lit. f GDPR. We will not send you any emails should you expressly object to the use of your email address for that purpose. You are entitled to object to the use of your email address for the aforementioned purpose at any time with immediate effect by notifying the data controllers listed in the opening of this statement. By taking this action, you will incur submission fees only in line with basic rates. After receipt of your objection, your email address will immediately be removed for marketing purposes.

To allow us to communicate with you on social networks and inform you about our services, we run our own pages on these social networks. If you visit one of our social media pages, we and the provider of the social media network are joint controllers (Art. 26 GDPR) regarding to the processing operations triggered thereby, which concern personal data.

We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers
We would therefore like to point out as a precautionary measure that your data may also be processed outside of the European Union or the European Economic Area. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your rights to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behaviour by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behaviour may be assigned directly to your own member profile on the respective social network (if you are logged in).

The processing operations of personal data described are carried out in accordance with Article 6 Paragraph 1(f) GDPR on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you have to grant your consent to the respective providers to process your data as a user, the legal basis for this processing is Article 6 Paragraph 1(a) GDPR in conjunction with Article 7 GDPR.

Since we have no access to these providers’ databases, we would like to point out that you would be best placed to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider. More information on the processing of your data on social networks and your options for exercising your right to object or your right of revocation (opt out) is listed below for each of the social network providers we use:

10.1 Facebook

(Jointly) Data controller responsible for data processing in Europe:
Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Privacy Notice (Data Policy):
https://www.facebook.com/about/privacy

Opt-out and advertising settings:
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen

https://facebook.com/about/privacy/

10.2 Instagram

(Jointly) Data controller responsible for data processing in Europe:
Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Privacy Notice (Data Policy):
http://instagram.com/legal/privacy/

Opt-out and advertising settings:
https://www.instagram.com/accounts/privacy_and_security/

10.3 LinkedIn

(Jointly) Data controller responsible for data processing in Europe:
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland

Privacy Notice:
https://www.linkedin.com/legal/privacy-policy

Opt-out and advertising settings:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

10.4 Twitter

(Jointly) Data controller responsible for data processing in Europe:
Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland

Privacy Notice:
https://twitter.com/en/privacy

Information:
https://twitter.com/settings/your_twitter_data

Opt-out and advertising settings:
https://twitter.com/personalization

11.1 WP Statistics

On our website we use the analysis plugin WP Statistics. This plugin has been developed by the American software company Veronalabs (5460 W Main St, Verona, NY 13478, United States). The plugin allows us to receive simple statistics on how you as a user interact with our website. In this privacy policy we will go into more detail about the analysis tool and show you where and for how long your data is stored.

What is WP Statistics?

This plugin is an analysis software which was specially developed for websites that use the WordPress content management system. WordPress helps us to easily edit our website even without any programming knowledge. WP Statistics may for example collect data about how long you stay on our website, what subpages you visit, how many visitors are on our website or which website led you to us. Furthermore, WP Statistics does not set any cookies and you cannot be personally identified by the collected data.

Why do we use WP Statistics?

With the help of WP Statistics, we obtain simple statistics that help us to continuously improve and make our website even more interesting for you. Our website and the content, products and/or services offered on it should meet your needs and demands as closely as possible. In order to achieve this goal, we of course have to find out where there is room for improvements and changes. The statistics obtained help us to get one step closer to this goal.

Which data is stored by WP Statistics?

WP Statistics does not set any cookies and the collected data are only used to generate anonymised statistics on the use of our website. WP Statistics also anonymises your IP address. You cannot be identified as a person.

WP Statistics collects visitor data when your web browser connects to our web server. These data are then stored in our server’s database. The retained data may for example be:

• the address (URL) of the accessed website
• browser and browser version
• the operating system used
• the address (URL) of the previously visited page (referrer URL)
• the hostname and IP address of the device from which our website was accessed
• date and time
• information on the country/city
• number of visitors that come from a search engine
• duration of the website stay
• clicks on the website

Your data will not be passed on or sold.

How long and where are the data stored?

All data is retained locally on our web server. Your data will be stored on our web server until it is no longer needed for the purposes listed above.

How can I delete my data or prevent data retention?

You have the right to information, rectification, deletion or restriction of the processing of your personal data at any time. Moreover, you can revoke your consent to the data processing anytime.

We have now given you the most important information about data processing by WP Statistics. Your data is handled very carefully, as the plugin does not use cookies and the data for statistical analyses are stored locally on our web server. If you want to learn more about WP Analytics, you can view the company’s privacy policy at https://wp-statistics.com/privacy-and-policy/.

12.1 Right to confirmation

You have the right to request confirmation from us as to whether personal data relating to you will be processed.

12.2 Right to information (Article 15 GDPR)

You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us, in accordance with the statutory provisions.

12.3 Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

12.4 Erasure (Article 17 GDPR)

You have the right to demand that we erase the personal data relating to you be deleted without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required.

12.5 Restriction to processing (Article 18 GDPR)

You have the right to request that we restrict the processing of your data if one of the legal requirements is met.

12.6 Data transferability (Article 20 GDPR)

You have the right obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 Paragraph 1(a) GDPR or Article 9 Paragraph 2(a) GDPR or on a contract pursuant to Article 6 Paragraph 1(b) GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us.

Furthermore, when exercising your right to data transferability pursuant to Article 20 Paragraph 1 GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.

12.7 Objection (Article 21 GDPR)

You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1(e) (data processing in the public interest) or (f) (data processing on the basis of the weighing of legitimate interests) GDPR.

This also applies to profiling based on these provisions pursuant to Article 4 Number 4 GDPR.

Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims.

In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose.

In addition, you have the right to object to our processing of your personal data for scientific or historical research purposes or for statistical purposes pursuant to Article 89 Paragraph 1 GDPR for reasons arising from your particular situation, unless such processing is necessary for the performance of a task in the public interest.

You are free to exercise your right to lodge an objection in relation to the use of information society services, Directive 2002/58/EC notwithstanding, by means of automated procedures using technical specifications.

12.8 Revocation of consent regarding data protection

You have the right to revoke any consent to the processing of personal data at any time with future effect.

12.9 Lodging a complaint with a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

We process and store your personal data only for the period of time necessary to meet the storage purpose or as required by the legal provisions to which our company is subject.

If the storage purpose no longer applies or if a required retention period expires, personal data will be routinely blocked or erased in accordance with the statutory provisions.

The criterion for the duration of the retention of personal data is the respective legal retention period. Once this period expires, the data in question will be routinely erased, provided it is no longer required for the fulfilment or initiation of the contract.

This Privacy Notice is currently valid and was last updated on April 27th, 2023.

It may be necessary for us to amend this Privacy Notice in the process of further developing our website and the services we offer through our website or due to changes in legal or regulatory requirements. You can view and print our current Privacy Notice on the website at any time by visiting “https://www.truenas.cy/privacy“.

This privacy statement has been prepared with the assistance of the privacy software: audatis MANAGER.