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Privacy Policy

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Privacy Policy

Answeropia takes your privacy very seriously. Answeropia is committed to safeguarding your privacy, and this privacy policy explains our data collection, use, and disclosure practices.

This policy covers:

  • important information and who we are
  • the personal data we collect and store
  • legal basis and purpose of processing
  • how and why we collect and use your personal data
  • why we process your personal data
  • when and why we will disclose your personal data
  • international transfers
  • the use of cookies
  • the steps we take to ensure your information is kept secure and confidential
  • how long we will hold your information for
  • your legal rights
  1. IMPORTANT INFORMATION AND WHO WE ARE

“Answeropia Ltd, which is company duly incorporate under the laws of the Republic of Cyprus with Registration no. HE412320 and with registered address at 5A Samouil Haou str. K. Polemidia, 4151, Limassol, Cyprus (herein referred to as “Answeropia”, “we”, “us” or “our” in this Privacy Policy) is the controller for personal data which we received through https://answeropia.com/privacy/ or otherwise or which is in our possession,Answeropia is committed to protect your personal data within the provisions of the European Union General Data Protection Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data (the ‘GDPR’), the  Cyprus Consumer Protection Law of 2021 (Law.112(I)/2021) and the Protection of Natural Persons Against Processing of Personal Data and the Freedom of Movement of Data Law (the ‘Law’) The GDPR and the Law regulate how personal information is handled by Answeropia and www.answeropia.com.

Answeropia provides its service (the “Service”) to you subject to the Terms of Service, and the following Privacy Policy.

This website is not intended for children and we do not knowingly collect data relating to children.

Words beginning with capital letters in this Privacy Policy which are not defined in this Privacy Policy are defined in the Terms of Service.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or the processing of personal data carried out by them. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. INFORMATION WE COLLECT AND RECEIVE

When you register for an Answeropia professional account, Answeropia collects personal data that you submit such as your name, username, email address, telephone number, home address, qualifications, exam reports and teaching experience. Answeropia also collects and generates a number of other areas of usage information automatically which includes; services metadata, log data, device information, IP addresses, third-party data and cookie information.

When you register for an Answeropia student account, Answeropia collects personal data that you submit such as your name, username and email address. Answeropia also collects and generates a number of other areas of usage information automatically which includes; services metadata, log data, device information, IP addresses, third-party data and cookie information.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data Nor do we collect any information about criminal convictions and offences.

We may contact you to ask you to participate in research. By participating in research with us, you confirm that you have read and agreed to the research conditions. Some of our research will use information from your Answeropia account in order to give us accurate results. Results will be aggregated and may be used for marketing purposes. No personal details will be shared with third parties. All your personal information will be stored securely for the duration of the research and deleted after the publication of the results. We store your personal information only on secure servers that are held in secure facilities in the European Economic Area (“EEA”) and have up-to-date firewall protection.

If you decide to participate in any research, your participation is voluntary and you can withdraw at any time. If you’d like to withdraw, please send an email to info@answeropia.com and your request will be processed on the following working day in the Republic of Cyprus. All your data will then be deleted from our database and excluded from the research.

When you use the Service, you may set up your personal profile, send and receive messages, perform searches and queries, and transmit information through various channels.

Where the above data is not provided, we may be unable to provide the Service.

 

3. LEGAL BASIS AND PURPOSE OF PROCESSING

The legal basis for the processing of personal data is:

  • that processing is necessary for the performance of a contract to which you are a party, including but not limited to the performance of the contract between you and us and/or between you and another person utilising the services provided by us, or in order to take steps at your request prior to entering into a contract;
  • that processing is necessary for compliance with our legal obligations;
  • that you have given us your specific consent for processing; and/or
  • that the processing is necessary for the compliance with legal obligations or legitimate interests.

Answeropia will use your personal data for the following purposes:

  • to provide, update, improve, maintain and protect our services, websites, apps and business
  • as required by applicable law, legal process or regulation
  • to comply with a legal obligation to which we are subject to
  • for research and to ask you to participate in research, the results of which may be used for marketing purposes
  • to establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure, and to enforce any agreement and/or judgment deriving from the above.
  • to respond to your questions and comments
  • to send marketing and transactional communications, including but not limited to email, push notifications, SMS and in-app messages, about the Service
  • statistical purposes
  • for billing, account management and other administrative matters
  • to investigate and help prevent security issues and abuse
  • other purposes as described to you at the point of collection
  • To verify your identity; and/or
  • For any other purpose to which you have consented

 

4.INFORMATION USE

Answeropia uses such information to customise the marketing and Content you see, fulfil your requests for products and services, improve our Service to you, contact you, conduct research, and provide anonymised reporting for internal purposes and for external clients such as advertisers.

Please note that if you enter payment details into the Service when purchasing a Paid Service, Answeropia itself does not receive or store such payment information, and as such information is received, it is stored and used by our payment service providers for the purpose of completing the purchase.

You can opt out of promotional communication initiated by Answeropia when registering for the Service. You can also opt out of all communications, email, push notifications and SMS, from the communication itself or from your preference settings.

  1. STORAGE AND TRANSFER OF YOUR PERSONAL DATA

We store your personal information only on secure servers that are held in secure facilities in the European Economic Area (“EEA”) and have up-to-date firewall protection. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

6. RETENTION

Answeropia will retain your personal data for as long as you maintain your account with Answeropia. In the event that you request your deregistration the personal data will be kept only for as long as is necessary in order to fulfil legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements. This means that, unless we are required by any governmental authorities or any other applicable local law or by the occurrence of any dispute or by any other legitimate reason on the basis of which we are required or allowed to maintain them for a longer period, we will maintain personal data for 6 years due to our obligation to maintain appropriate bookkeeping records and because the general limitation period for civil cases is equal such a period.

 

7. COOKIES

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computers and stored on your computer’s hard drive. You can configure your browser to accept all cookies, reject all cookies or notify you when a cookie is set. If you want to delete any cookies that are already on your computer, please refer to the instructions for your browser to locate the file or directory that stores cookies. If you reject all cookies, you may not be able to use some features of the Service. You can find out more about how we use cookies on Answeropia here: www.answeropia.com/cookies

  1. DISCLOSURE OF PERSONAL INFORMATION

Answeropia may disclose personal data to the following third parties:

  • Employees of Answeropia;
  • Service providers offering services to Anweropia;
  • Individuals seeking professional advice and/or guidance and/or answers through our website;
  • IT professionals and/or experts responsible for the maintenance and/or updating of our website;
  • Our accountants and auditors;
  • Banks in the intervals of our transactions;
  • To lawyers, legal consultants, advocates in the intervals of receipt of legal advice and/or opinion;
  • To lawyers, legal consultants, advocates and/or the court, where Answeropia is responding to a subpoena, court order, or legal process, or to establish or exercise our legal rights or to defend ourselves against legal claims;
  • To lawyers, legal consultants, advocates, the court, the police and/or any other governmental authorities where Answeropia believes it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Answeropia’s Terms of Service, or as otherwise required by law;
  • where you are using a Paid Service in your capacity as a client or a professional or other third party using the Paid Service, we may in such circumstances share your personal information with your educational establishment, your employer or any third party paying for the Service on your behalf (as the case may be) to allow them to monitor your use of the Paid Service;
  • where Answeropia is acquired by or merged with another company, personal data may be transfered to the merged or acquiring company. If this happens, Answeropia will notify you before information about you is transferred and becomes subject to a different privacy policy.

In some of the above cases the data may be transferred out of the EEA.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Please remember that whenever you disclose personal information online, that information can be collected and used by others. By posting personal data online so that such personal data is publicly accessible, you may receive unsolicited messages from other parties as a result.

  1. CONFIDENTIALITY AND SECURITY

We shall take measures to protect personal data using reasonable and industry standard security safeguards against loss or theft, as well as unauthorised access, disclosure, copying, improper use or modification.

Your personal data is password protected can only be seen by you and us. You agree to keep your password(s) confidential and not to disclose them to anyone else, or allow them to be disclosed.

Answeropia limits access to personal information about you to employees who Answeropia reasonably believes need to come into contact with that information, to provide products or the Service to you, or in order to do their jobs.

Answeropia has physical, electronic, and procedural safeguards that comply with regulations to protect personal information about you. However, data transmissions over the internet cannot be guaranteed to be 100% secure. Consequently, Answeropia cannot ensure or warrant the security of information you transmit to Answeropia. In particular, by accessing and using the Service, you do so at your sole risk and you are responsible for restricting access to your computer and ensuring that your computer is free from all types of malicious code, spyware, viruses, Trojans, etc. that may track any data you enter into the Service, including email address and payment related information. We are not responsible for any loss or damage arising from the user’s failure to comply with this paragraph.

However, when you pay for a Paid Service, Answeropia uses secure payment service providers to make sure that your payments are secure.

  1. 10. THIRD-PARTY WEBSITES

Where the Site, or any other part of the Service, links to other websites, such other websites do not operate under this Privacy Policy. Answeropia recommends that you examine the privacy statements posted on such other websites to understand their procedures for collecting, using, and disclosing personal data.

  1. YOUR LEGAL RIGHTS

You have the right to exercise the following rights, as appropriate by sending an email to info@answeropia.com:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request rectification (correction) of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please also note that any financial information will be kept and maintained in accordance with local laws.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need time to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to form a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to lodge of complaint. If you are concerned about how we use your personal data, please contact our Data Protection officer by email at info@answeropia.com., You also have the right to complain to the Office of the Commissioner for Personal Data Protection the Cyprus supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner, so please contact us in the first instance. You can find more information on how to submit a complaint from their website at https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_en/home_en?opendocument

If you wish to exercise any of the rights set out above, please contact us as detailed below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive then we may either charge a reasonable fee. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. CONTACTING ANSWEROPIA

You may obtain a copy of the personal data held about you that you provide through the Site or otherwise request that Answeropia updates, makes changes or deletes personal information or to exercise any of your rights over your personal data by sending an email to info@answeropia.com. If you have any questions or suggestions regarding our Privacy Policy, you can contact Answeropia by email at info@answeropia.com.

  1. UPDATE OF THE PRIVACY POLICY

We may update this Privacy Policy from time to time. All changes will be posted on our website (the “Site”). You can review the most current version of the Privacy Policy at any time here https://answeropia.com/privacy/ . Your continued use of the Service or the Site after any such changes have been made constitutes your acceptance of the new Privacy Policy.

 

Last updated: 11/05/2022