PORTOFOLAKIS

Privacy Policy

1.INTRODUCTION

This Privacy Policy aims to give you information on how JOBCHA LTD collects, uses, discloses and processes your personal data through your use of the website Portofolakis.com (hereinafter referred to as “the Website”) and the means by which this is done. The Privacy Policy acts as a means of notifying the website visitors of their rights in accordance with local law and the EU General Data Protection Regulation (EU) 2016/679.

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

JOBCHA LTD is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience.

By accessing, browsing and/or using this Website, you consent to the data practices described in this Privacy Policy and acknowledge that you have read, understood, and agree, to be bound by these terms conditions, and notices contained herein and to comply with all applicable laws and regulations.

For the purposes of this Privacy Policy “Personal Data” refers to all data which relates to a living individual who can be identified from such data such as for instance, name, address and/or identification number. It does not include data where the identity has been removed (anonymous data).

2. WHO WE ARE

The Website is owned and operated by JOBCHA LTD, a limited liability company registered in the Republic of Cyprus with registration number ΗΕ 305965 and registered address at 8 Michalaki Karaoli Street, Anemolmylos Building, 3rd floor, 1095 Nicosia, Cyprus.

Portofolakis is an online platform where Users can get all offers, discounts and deals from grocery shops to electronics or hotels. Portofolakis focuses on publishing all available special offers (either product or service) in the market. Portofolakis provides the ability to advertise a product or service on offer. Portofolakis also offers exclusivities, claims and redeems, email services, Social Media services and Web Push Notifications. Furthermore, through data analytics, Portofolakis offers companies a report of valuable user data, which can be used for marketing If you have any questions about this Privacy Policy , including any requests to exercise your legal rights, please contact us at the details set out below.

Contact Details: Portofolakis.com Team

Address: Spyrou Kyprianou 37, ΤΚ 4154, Λεμεσός, Limassol 4154

Email address: [email protected]

Telephone number: (+357) 25 55 87 44

You have the right to make a complaint at any time to the Office of the Commissioner for Data Protection, the supervisory authority for data protection issues in the Republic of Cyprus (Click here to see more details). We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner for Data Protection therefore please contact us in the first instance.

3. TYPE AND METHOD OF COLLECTION

The data we collect consists of what the User voluntarily makes available to us when accessing and/or registering on the Website

Overall we collect personally identifiable information, such as your e-mail address, name and surname and telephone number.

We may also collect anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites. There is also information about your computer hardware and software that is automatically collected by the Website. This information can include: your IP address, browser type, domain names, access times and referring Website addresses.

We strongly encourage you to review the privacy statements of Websites you choose to link to from Portofolakis.com so that you can understand how those Websites collect, use and share your information. JOBCHA LTD is not responsible for the privacy statements or other content on websites outside portofolakis.com.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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.

The Website consists of "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with the

Webiste or services, a cookie helps us recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the Website, the information you previously provided can be retrieved, so you can easily use the Webiste features that you customized. You have the ability to accept or decline cookies.

Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Website.

4. USE OF THE DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). (Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

We use the personal information we collect to provide and improve our services, to provide you with a personalized experience on our site (especially, by offering you services and items that you may like), to contact you about your account and our services, to provide you customer service, to provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.

JOBCHA LTD also uses your personally identifiable information to inform you of other products or services available from JOBCHA LTD and its affiliates.

In the instance, that you will be communicated by an affiliate for the purposes of direct marketing, prior to such communication being effected you will be requested to give your free, explicit and specific consent to be expressed in a clear and conscious manner. Such consent will be requested to be given by you when you will be visiting

the Website of the said related companies and ticking the relevant box referring to the provision of direct marketing services.

5. ACCESS TO THE DATA/YOUR RIGHTS AS USER ON THE WEBISTE

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Such rights are as follows:

  • 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 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.
  • 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 as you feel it impacts on your fundamental rights and freedoms. 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 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 perform 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.

It is noted that upon the registration of the User on the Website and after providing his e-mail address, the User automatically becomes a recipient of the Website’s newsletter. The User can Opt-Out from receiving such newsletter by clicking on the link therein.

6. DISPOSAL TO THIRD PARTIES

Except as specifically set forth in this Privacy Policy , we do not share your personal information with any non-affiliated third party without your free, explicit and specific consent and in any event when your personal information is collected we will notify you of the recipient or the categories of recipients of such information. Furthermore, we will promptly notify you when the said data are to be first announced to a third party. We may disclose aggregate information, such as demographic information, and our statistical analyses to third parties, including advertisers or other business partners. This aggregate information does not include your personal information.

7. SECURITY

The security of your personal information is important to us and this is why we maintain physical, electronic, and procedural safeguards to secure your personal information. JOBCHA LTD secures your personal information from unauthorized access, use or disclosure.

This Website has security measures in place to protect the loss, misuse and alteration of the information under our control. Such measures include regular security reviews, upgrades, and backups. We use our best efforts to maintain the security and reliability of our infrastructure; however, they are provided "as is" without any express or implied warranty of any kind including warranties of merchantability, reliability, or fitness for a particular purpose. We offer no assurance of uninterrupted or error free service, nor does JOBCHA LTD warrant the accuracy or completeness of any service. In no event shall JOBCHA LTD be held liable for any damages whatsoever (including, without limitation, damages for loss of profits, business interruption, loss of information) arising out of the use or inability to use the Website.

8. INTERNATIONAL TRANSFERS

In the instance that your Personal Data will be transferred 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 in accordance with Article 46 of the GDPR.
  • 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.


9. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. CHANGES TO THIS STATEMENT

JOBCHA LTD will occasionally update this Privacy Policy to reflect company and customer feedback. You will be notified of any changes to this Privacy Policy but we encourage you to periodically review this Privacy Policy so as to be informed of how your information is protected.

11. TIME LIMIT TO RESPOND

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.

12. THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside JOBCHA LTD for marketing purposes.

Contact Us

If you have any questions about this Privacy Policy, please contact us.