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Our privacy statement

1 Data processing – type of data and the ways of processing

1.1 Cookies

We apply cookie on our websites which is a small piece of data sent from our webserver and temporary stored on your computer by the used web browser while you are browsing.
Generally, cookies have been designed to be a reliable mechanism for websites to remember stateful information or to record the user's browsing activity (including clicking particular buttons, logging in, or recording which pages were visited in the past). They can also be used to remember arbitrary pieces of information that the user previously entered into form fields such as names, addresses, passwords, and credit card numbers.
But we do not apply cookies for this purpose, we use them as stated in the followings.

1.1.1 Type of applied cookies
Our web server creates only PHPSESSION session cookies temporarily, which are necessary for serving clients’ requests. We do not apply cookies to collect and analyze personal data. And even, temporary cookies are automatically deleted as browser is closed.
Without temporary cookies, our webpage may not able to perform users’ requests properly because of technology capabilities.

1.1.2 User consent
Browsing our website is based on your consent complying with GDPR Article 6 1. (a), which is expanded to using the aforementioned usage of temporary cookies.

1.1.3 How it may be disabled, deleted, purged, destroyed, etc.?
Temporary cookies are deleted as web browser is closed.
Each web browser is able to list all the cookies applied by webservers. Cookies may be generally blocked by web browsers. It is depending on used web browser where this capability may be found. Please, inform in help menu of your browser.

1.2 Contact
You may be able to contact us via the proposed function of our website. In this case, you may send an email for us. Sending a message is based on your decision and, hence, it is based on your consent complying with GDPR Article 6 1. (a). Processed data includes name and email address, and those which you write for us in message. We keep messages while there is a communication session alive. After closing (responding every questions or notes, fulfilling requests), we delete your message or anonymize it – or as you request. But please note, there may be circumstances when we shall keep messages based on another lawful as stated in GDPR Article 6 1. (b)-(f). In this case, we notify you ASAP, but at least, with our first response to your last message.

2 Compliance
Our eyes are constantly to comply with international and local regulation, definitely, mainly with General Data Protection Regulation of the European Union and other local laws of Member States and states outside the European Union.

3 About data controller
We are an international startup located in Tallinn:
Contact: hello (at) cyex.io
Name: cyex OÜ
Address: Pikk tn 7, Tallinn 10123, Estonia

4 Who may meet with your personal data?
We keep your personal data in secret inside and outside organization. Only the necessary personal may meet with your message to answer your question or fulfill your request. Without your consent or request, we do not forward it to any other data controller or data processor, aka. third party.
For email service, we use Protonmail as third party’s cloud solution. They do not have any permission or entitlement to meet your personal data.

5 Information security
We do our best to keep your personal data in secret. We apply least privilege, authentication, authorization and accounting, etc., and data encryption as necessary.

6 Your rights and advocacy
You may be initiate to
• request information about your processed personal data,
• make us to correct your personal data,
• delete or restrict processing your personal data,
• initiate data portability,
• withdraw your consent,
• object against data processing.
In case of a request, please contact us via the beforementioned email address. After processing your request, but within 3 day, we make our response.
You may contact Estonian supervisory authority
Nõuandetelefon 5620 2341
(vaata vastamisaegu SIIT),
üldtelefon 627 4135,
info[a]aki.ee
https://www.aki.ee/en/inspectorate/staff-and-contacts

7 Definitions
‘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;

‘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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

‘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 analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;

‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

‘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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

‘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 authorized to process personal data;

‘consent’ of the data subject means 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;

‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

‘main establishment’ means:
(a) as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment;
(b) as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;

‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;

‘cross-border processing’ means either:
(a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or
(b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.

‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;

‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council (19);

‘international organisation’ means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.