#AEICineFest2019

Privacy Policy

– Introduction

The audiovisual company with the name TETRAKTYS FILMS, sole organiser of the Cyprus Archaeological, Ethnographic and Historical Film Festival hereinafter AEI-CineFest Film Festival, with registered offices in the 95, Kerynia Avenue, apt. 201, Aglanjia, Nicosia, Cyprus, taking into serious consideration the fundamental right of natural persons – users regarding the processing of their personal data and the necessary protection thereof, undertakes to protect your personal data as specified in the European Union Regulation 2016/679 – hereinafter “the GDPR”.

In this Privacy Policy, TETRAKTYS FILMS, describes, in accordance with article 13 of the GDPR, which personal data collects from you (“data subject”), how it collects it (directly and through the AEI-CineFest Film Festival, website), how it processes it, the purposes, the lawful basis for processing, as well as the rights you have pursuant to the GDPR regarding the processing of your personal data.

– Data Controller

The data controller of your data is TETRAKTYS FILMS, with registered offices in the 95, Kerynia Avenue, apt. 201, Aglanjia, Nicosia, Cyprus.

We encourage you to read the Privacy Policy carefully in order to be informed about the processing procedure of your data by TETRAKTYS FILMS, and, if you wish, to exercise any of your rights, or if you have any questions you may contact us at the following email address:aei.filmfestival@cytanet.com.cy    

1. What is processing of personal data of a natural person?

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.

The procession of personal data is performed in the context of the TETRAKTYS FILMS’ activities, provided that the processing activities are related to the provision of goods or services to said data subjects, whether payment by the data subjects is required or not. The right to the protection of personal data is not an absolute right; it must be considered in relation to its function in society and be balanced against other fundamental rights, in accordance with the principle of proportionality.

TETRAKTYS FILMS processes and stores files with the personal information of the data subjects, for financial, fiscal, accounting, archiving and communication purposes, pursuant to the provisions of article 5 of the GDPR. In the context of continuous improvement of its services and information, it may process for statistical purposes, applying strict confidentiality terms, part or all the data that the data subjects have submitted. TETRAKTYS FILMS keeps a physical or electronic record of its processing. The same record is kept by the data processor performing the processing on behalf of TETRAKTYS FILMS.

Minors may access the website and the services of TETRAKTYS FILMS with the consent of their parents or legal guardians, otherwise all relevant information provided by minors without said consent will be deleted.

2. How is your personal data collected?

TETRAKTYS FILMS collects information directly from you when you access its services, either in person or electronically by means of its databases. Furthermore, it collects data from publicly available sources, when required (websites, public telephone directories etc.).

The specific personal data requested in our various forms, is determined by your relationship with us, the purpose you are accessing our website and required for the fulfilment of the purposes for which TETRAKTYS FILMS requests said information. This means that if you do not provide your personal data or submit it incorrectly, we are not able to fulfill said purposes.

TETRAKTYS FILMS depending on its relationship with you, the request you have submitted in the form/forms you fill and your capacity, creates lists/files where it records you and will request exclusively the personal data necessary for each list. Optionally, the data subjects may provide additional information, if they wish. For certain functions and if required by law, it will be necessary to disclose your age to us. 

Said data is not published, is accessible only to the data processors on behalf of TETRAKTYS FILMS and is disclosed only for lawful purposes, always in accordance with the provisions of the GDPR. The data subjects are responsible for the accuracy and authenticity of the data they submit.

If you have declared that you wish to receive our newsletter, you are automatically included in the newsletter recipient mailing list with the e-mail address you provided and you will receive it periodically. For information purposes we could use data such as: your e-mail address, full name and the city of residence. The lawful basis for the processing of said data is your explicit and unequivocal consent. The newsletter mailing lists are subject to change, however the same Privacy Policy applies to all of them.

3. Which personal data do we process?

The personal data processed by TETRAKTYS FILMS is determined by the request and form/forms filled by the data subjects, providing their consent and simultaneously determining their relationship with use.

The following data may be submitted to processing, as appropriate: full name, date of birth, country, address, e-mail, telephone number, education information, etc, which is provided directly by you when you use the functions of AEI-CineFest Film Festival, website, including the data of the browser or the requests to use the services provided in the Website (e.g. by filling the various forms of TETRAKTYS FILMS for the submission of forms and applications, by filling contact forms, by submitting questions, etc.). 

4. Why do we process your personal data?

Below you will find a brief review of the purposes for which TETRAKTYS FILMS, with your consent, process your personal data, depending on the form you filled and your request. In particular:

– For the communication, via newsletter, of the purposes, the activities and the services of TETRAKTYS FILMS, the schedules of the events and film screenings in the cinemas it operates.

– In order to be able to process your registration, the requests and reports received through its website, allowing the processing to fulfil your request and the purposes for which your data has been collected.

– For the fulfilment of obligations deriving from laws, regulations and European Union law. The lawful basis for processing is provided by article 6 paragraph 1 of the GDPR.

Your usual personal data, only with your consent, may also be used in the official publications of TETRAKTYS FILMS for your information with various means of communication (e.g. by mail, telephone, fax, e-mail, etc.). The lawful basis for this purpose is article 6 paragraph 1 point a) of the GDPR.

During the processing of your personal data we ensure their full protection and confidentiality and we use all the required technical and organizational means and policies. TETRAKTYS FILMS may process your usual and sensitive personal data should it need to defend its rights before any court and in any legal procedure in general.

Furthermore, by registering in AEI-CineFest Film Festival, website you may participate:

– In electronic commerce activities, with your explicit and informed consent, providing payment services for the goods and/or services you purchased, using payment gateways established for this purpose.

– In the purchase of Electronic Tickets, through third party platforms.

In particular, for the purchase of tickets for cinema screenings using third party electronic platforms, your will be requested to provide basic personal data necessary for the electronic reservation of tickets. The lawful basis for the processing of said data is the informal but free contract concluded between TETRAKTYS FILMS and the customer for the provision of cinema services.

Furthermore, it may collect data in other cases for your information needs, about which you will be promptly informed at the moment of collection thereof, ensuring the lawfulness of the processing by complying with the principles of lawfulness, fairness, transparency, accuracy, integrity, confidentiality, data minimisation and purpose limitation.

5. Lawful basis for data processing

TETRAKTYS FILMS will process your personal data with your explicit consent, always in accordance with the GDPR requirements and regarding the purpose specified in the form you have filled. However, if you subsequently wish to withdraw your consent to any data processing, this will not affect the lawfulness of the processing already performed by TETRAKTYS FILMS, or of any subsequent processing required for other lawful procedures in accordance with the GDPR.

6. What are your rights?

The visitors/users of AEI-CineFest Film Festival’s website have specific rights regarding their personal data and the processing thereof. In fact, they may contact the website administrators at the e-mail address:aei.filmfestival@cytanet.com.cy in order to be informed about the existence of a file with their data, alter it, request their deletion from the lists, etc., as described below.

In particular:

  • Right to Information
    You may always examine your personal data and, if required, to adjust your preferences. If you wish to know what personal data you have provided to TETRAKTYS FILMS or are stored by TETRAKTYS FILMS you may send an information request at the administrators of the website at the e-mail address:aei.filmfestival@cytanet.com.cy  accompanied by a copy of an identification document.
  • Right of Access
    You may receive confirmation about if your personal data is subject to processing, and to what extent and for which specific purposes. If you wish to adjust your personal data and you are not able to do so on your own, you may send an adjustment request to TETRAKTYS FILMS at the e-mail address: aei.filmfestival@cytanet.com.cy You may request from TETRAKTYS FILMS to adjust, improve, rectify (right to rectification), erase (right to erase) or to conceal (partially) your data. In case of submission of a written request for the determination, rectification or erasure of data, TETRAKTYS FILMS undertakes to examine it within a reasonable time. Your erasure request will be accepted, except in the cases where TETRAKTYS FILMS is obligated to conserve the data (indicatively: for archiving, information of the authorities, fiscal, insurance, accounting purposes).
  • Right to Restriction of Personal Data Processing
    You have the right, subject to the aforementioned conditions, to request from TETRAKTYS FILMS, at the e-mail address:aei.filmfestival@cytanet.com.cy, to restrict the processing of your personal data. Your request will be accepted, except in the cases where TETRAKTYS FILMS is obligated to conserve the data (indicatively: for archiving, information of the authorities, fiscal, insurance, accounting purposes).
  • Right to Object
    If the processing of certain data is performed on grounds of a “legitimate interest” of TETRAKTYS FILMS or a third party, you have the right to object to the processing of said data, subject to the same above mentioned conditions. Your request will be accepted, except in the cases where TETRAKTYS FILMS is obligated to conserve the data (indicatively: for archiving, information of the authorities, fiscal, insurance, accounting purposes).
  • Withdrawal of Consent
    In all the cases where the lawful basis for the processing of your data is your unequivocal, explicit and free consent, you have the right to withdraw your consent. The withdrawal is effective only for further processing and not retroactively. This means that we will be no longer able to process the relative data and TETRAKTYS FILMS will not be able to provide certain services. You may revoke your withdrawal on a case by case basis, as follows:
    1. If you are registered in the automated information list, in every newsletter you receive you have the option to unsubscribe following the relevant link at the bottom of the e-mail (“unsubscribe”). Withdrawing your consent has as a consequence that you will not be able to follow our events and activities.
    2. If you receive any other correspondence from us, we will inform you at the bottom of any other notice you receive from us.
  • Response from TETRAKTYS FILMS  Your requests may be sent to the e-mail address:aei.filmfestival@cytanet.com.cy. TETRAKTYS FILMS will examine your request as soon as possible after the receipt of your request. If TETRAKTYS FILMS rejects your request, we will provide you a relevant reasoned response about the reasons.

7. How and for how long do we store your data?

TETRAKTYS FILMS stores your personal data exclusively in accordance with the definitions of article 5 par. 1 c’ and e’ of the GDPR, i.e. their storage is limited to what is necessary in relation to the purposes for which they are processed and for no longer than is necessary for the specific purposes declared with the relevant request/form filled by the data subject. After the fulfilment of the relevant purpose, TETRAKTYS FILMS will erase your personal data. Furthermore, exceptionally your personal data may be stored for longer periods, provided that you did not request their erasure, for archiving purposes in the public interest, for statistical purposes as well as for the period required for the fulfillments of our relevant legal and fiscal obligations. In any case, the criterion used for the determination of the storage period is based on the compliance with the deadlines allowed and/or imposed in some cases by the law or the Authorities. The personal data that you made available to us must be accurate and in case of changes you, as the data subject, must ensure that we are promptly informed in order to erase or rectify it.

It is noted that you have the right to request the erasure of information, as mentioned above, except in certain cases where TETRAKTYS FILMS is obligated to preserve the information (indicatively for archiving, fiscal, insurance or accounting purposes).

8. Data recipients

TETRAKTYS FILMS does not transfer or transmit your personal data to third parties within or outside the European Union or the European Economic Area, in any manner whatsoever, except in the following cases:

  1. To Public Authorities, following relevant order or when provided/required by applicable legislation (lawful purposes).
  2. If we believe that the disclosure is necessary to prevent personal injury or financial loss or for the investigation of suspicious or unlawful conduct.
  3. To third parties, when required for the purposes for which it was collected, e.g. to credit card companies, banks, natural and legal persons, which will be transmitted your personal data and payment method details, if required for the processing of transactions related to registrations or to third parties that have agreements with TETRAKTYS FILMS for the provision of services to its visitors (e.g. arranging accommodation / transportation on behalf of the data subjects, etc.) and other purchases made by the data subject.
  4. To the personnel and trusted third parties that provide assistance for the operation of the entity, provided that said parties agree to maintain said information strictly confidential.

9. Security

TETRAKTYS FILMS implements and applies appropriate technical and organizational measures and policies in order to protect your personal data from risk of loss or erroneous processing, in full compliance with the provisions of the European General Data Protection Regulation (GDPR). Furthermore, we request from our service providers to comply with the strict requirements for the security of your personal data. In case of breach of your personal data, TETRAKTYS FILMS will promptly inform you in accordance with the definitions of the Regulation.

10. Amendments of the Privacy Policy

TETRAKTYS FILMS reserves the right to amend its Privacy Policy. All amendments will be announced at its website. TETRAKTYS FILMS recommends to all interested parties to periodically visit this page to determine if any adjustments were made. TETRAKTYS FILMS may send a relative informative e-mail.

11. Hyperlinks

Appropriate links in  the AEI-CineFest Film Festival website provide access to other websites. Said links are placed in the website exclusively in order to facilitate the browsing of visitors. They do not constitute, in any manner whatsoever, endorsement or approval of the content of the linked websites. Each link leads to a different website and the browsing thereof is subject to the terms of use of said website. TETRAKTYS FILMS assumes no liability whatsoever for the content and the personal data management policy of the linked website. Access to any website using the provided links is made under the exclusive responsibility of the user.

This Privacy Policy applies exclusively to the Website specified above. Despite the fact that the Website may contain links to other third party websites, we inform you that TETRAKTYS FILMS does not use and does not have access to cookie tracking systems, web beacons or other user tracking technologies that may be active on third party websites, or to the content and the material posted to said websites or to the processing procedures of your personal data. For this reason, TETRAKTYS FILMS explicitly disclaims any liability associated with said matters. Therefore, you must examine the privacy policies of said third party websites and collect information regarding the terms and conditions and the methods of processing of your personal data.

12. Browsing data

If you simply browse the website, without sending a message, the processing of your data is limited to the browsing data, i.e. the data that must be sent to the website for the operation of the computers on which the website runs and the Interned protocols.

TETRAKTYS FILMS collects this and other data, such as the number of visits and the time spent on the website, exclusively for statistical reasons and anonymously, in order to monitor its operation and improve its performance. Said data is not collected in order to be associated with other user related information and in no case whatsoever to identify users. Browsing data is usually deleted after being anonymously processed, but may be stored and used by TETRAKTYS FILMS for the detection and identification of the perpetrators of computer crimes committed against or using the website.

13. Persons that have access to the data

Persons belonging to the following categories are authorized to process user data, i.e. technical and management personnel, product managers, as well as other staff members that must process the data for the performance of their duties. Persons that provide technical services for the data controller and the Data Protection Officer (DPO) also have access, exclusively for the purposes of their duties.

Regarding the transfer of data outside the EU, any transfers will be made in accordance with the GDPR and the data may be disclosed to authorities, public entities for institutional reasons, as well as to third parties and service providers that provide to TETRAKTYS FILMS the technologies required for the above mentioned purposes and for supporting TETRAKTYS FILMS to provide the services you requested. The aforementioned recipients receive only the data required for the respective operations and duly undertake to process it only for the aforementioned purposes and in accordance with personal data protection laws.

14. Where can you submit your questions or complaints?

If you have any questions regarding our Privacy Policy and the methods utilized by TETRAKTYS FILMS for the processing of your personal data, a request for information, or any complaint regarding the processing of your personal data by TETRAKTYS FILMS, you may send a message at the e-mail address aei.filmfestival@cytanet.com.cy. The contact information is also provided in all communications you receive.

Furthermore, you can always contact the competent Data Protection Authority.

This Privacy Policy was updated on 1st of April 2019.

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