SummerCliff understands that your privacy is important to you and that you care about how your personal data is
used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways
that are described here, and in a way that is consistent with our obligations and your rights under the law.
Information About Us
SummerCliff is a trading name owned and operated by Golden Telemedia Ltd registered in Cyprus under company
number HE 55178.
Registered address: 131 Kyrenias Avenue, Victor Plaza, Office 201, 2113 Aglantzia, Nicosia, Cyprus
Main trading address: same as registered address.
VAT number: 10055178T
Data Protection Officer: Antonis Iniatis.
Email address: firstname.lastname@example.org
Telephone number: +357 22444411.
Postal Address: P.O.Box 24688, CY-1302 Nicosia, Cyprus
What Does This Notice Cover?
This Privacy Information explains how [we] OR [I] use your personal data: how it is collected, how it is held, and how
it is processed. It also explains your rights under the law relating to your personal data.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any
information relating to an identifiable person who can be directly or indirectly identified in particular by reference to
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers
obvious information such as your name and contact details, but it also covers less obvious information such as
identification numbers, electronic location data, and other online identifiers.
The personal data that [we] OR [I] use is set out in Part 5, below.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell
you everything you need to know, but you can always contact us to find out more or to ask any questions
using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or
incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data
that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using
it with your consent or for the performance of a contract, and that data is processed using automated
means, you can ask us for a copy of that personal data to re-use with another service or business in many
For more information about our use of your personal data or exercising your rights as outlined above, please contact
us using the details provided in Part 11.
Further information about your rights can also be obtained from the Office of the Commissioner of Data Protection
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with
the Office of the Commissioner of Data Protection http://www.dataprotection.gov.cy.
What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Email address
- Telephone number
- Business name
- Job title
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is
necessary for our performance of a contract with you, because you have consented to our use of your personal data,
or because it is in our legitimate business interests to use it. Your personal data will be used for one of the following
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes,
which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with
information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or
spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the
Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to
- Providing and managing your account.
Supplying our products AND/OR services to you. Your personal details are required in order for us to enter
into a contract with you.
- Personalising and tailoring our products AND/OR services for you
- Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or
opt-out at any time by clicking on the opt-out or unsubscribe links or call-to-action button provided in such
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first
collected. Your personal data will therefore be kept for as long as you shall be using our products and services.
How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of
all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully
protected under the GDPR or to equivalent standards by law.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important
In some limited circumstances, we may be legally required to share certain personal data, which might include yours,
if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details and a copy of it. This is known
as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’
(for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 15 days and, in any case, not more than one month of
receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that
time. In some cases, however, particularly if your request is more complex, more time may be required up to a
maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access
request, please use the following details (for the attention of Data Protection Officer):
Email address: email@example.com
Telephone number: +357 22444411.
Postal Address: P.O.Box 24688, CY-1302 Nicosia, Cyprus.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if
we change our business in a way that affects personal data protection.
Any changes will be made available on our website.