1. INTRODUCTION

1.1. Uniplant Ltd (“we”, “us” or “our Company”), is a company that specialises in the import and sale of various types of machinery and/or equipment and/or parts in Cyprus, which includes road construction equipment, agriculture, earth moving construction and recycling equipment, as well as training of equipment handlers. This Policy describes the ways in which we collect and use personal data, the purposes of processing, when we may disclose your personal data to third parties, as well as your rights and control in relation to it.

1.2. Personal data or personal information means any information related to an identified natural person (i.e. a person whose identity has been established), or an identifiable natural person (i.e. a person whose identity may be established directly or indirectly by using other information such as name, identity card number etc).

1.3. For the purposes of data protection legislation, our Company acts as Controller of your personal data since it is responsible for collecting and using your personal data in accordance with the General Data Protection Regulation 2016/679 (the “GDPR”) and the national law (L. 125(I)/2018) (together the “data protection legislation”). As Controller of your personal data, our Company is committed to ensuring that all personal data are held and processed securely in compliance with the applicable data protection legislation and in accordance with this Privacy Policy (unless otherwise required by law).

2. INFORMATION COLLECTION

2.1. We collect personal information in the course of conducting our business, for example, when you engage our Company for the provision and/or promotion of our products and/or services to you, including but not limited to:

• i. The fulfilment and adherence to contractual and legal obligations regarding the pricing offers for machinery purchases, procurement of spare parts and related products and services, machinery maintenance and repair services, machinery purchase orders and contracts, pricing, provision of warranties for your vehicle, and vehicle registration (if needed) with the Road Transport Department.
• ii. The provision of information and informative materials related to your machinery, maintenance, spare parts, vehicle inspection reminders, maintenance campaigns, or vehicle recalls as per manufacturer's directives or other competent authorities to meet legal obligations and safeguard Uniplant' legal interests concerning service provision, ensuring timely and accurate information regarding safety concerns, and monitoring proper vehicle usage and maintenance.
• iii.Conducting surveys and statistical analyses, including Customer Satisfaction Surveys concerning machinery acquisition and maintenance services, driven by legal and contractual obligations to uphold and enhance quality and service standards, aimed at protecting your personal data.
• iv. Conducting marketing endeavours for our products and services, such as event invitations, offers, advertisements, and market research, contingent upon your explicit consent.

2.2. We use your personal data in ways that are compatible with the purposes for which it was collected or authorized by you, as described in this Privacy Policy.

2.3. Communication with you may be facilitated through mail, email, telephone, text message, and instant message, as deemed appropriate and subject to your preference.

2.4. The types of personal data that are voluntarily provided by you or at your request upon direct contact with us, which our Company collects and retains, include the following:

• i. Your name, ID or passport number, and contact details like address, telephone, and email address.
• ii. In case of service and/or machinery purchase, machinery registration certificate, machinery data and technical details, machinery insurance coverage, and relevant loan or rental purchase documentation.
• iii. Information pertaining to your previous transactions with us.
• iv. Card information.

2.5. Our records will be periodically updated through the same channels as data collection.

3. DATA STORAGE & SECURITY

3.1. Your personal data is stored both in printed and electronic formats, maintained either on-site or at external storage facilities. Stringent security measures, policies and rules are in place, that are regularly reviewed and upgraded, to ensure data confidentiality, and protect the personal data from unauthorised access, improper use or disclosure, unlawful destruction, accidental loss or unauthorised modification. Access to your personal data is restricted only to our personnel (who are bound by confidentiality rules).

3.2. We have put in place procedures to handle any suspected security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal data. In such case, we have in place appropriate plans and policies for handling such data breach incidents.

4. DATA SHARING

4.1. Uniplant may transmit your personal data to entities affiliated or controlled by Uniplant for the purpose of promoting its products and services, subject to the previously mentioned principles. These entities are bound by data processing agreements and/or data sharing agreements (as applicable), incorporating strict confidentiality and usage restriction clauses.

5. DATA RETENTION

Uniplant will retain your personal data for the duration necessary to fulfil the aforementioned purposes and obligations, including compliance with contractual and legal requirements.

Indicatively:

• (a) for personal data collected as part of a contractual relationship, such personal data will be maintained for the duration of our contract and upon termination and/or expiration of such contract, for an additional period of six (6) years.
• (b) For personal data collected subject to your consent, such personal data will be processed until you withdrawal of such consent or upon completion of the purposes for which your personal data was collected originally.
• (c) The above-mentioned retention periods are subject to the Company’s obligation to comply with legal or regulatory requirements to which we are subject to, or to be able to exercise our legal rights under such contract.

6. YOUR RIGHTS

At any point during which we are processing your personal data, and subject to applicable legislation, you have the right to:

• (a) Access such information and request a copy of the information that we hold about you.
• (b) Correct such data that you believe is inaccurate or incomplete.
• (c) Ask for such data to be deleted from our records.
• (d) Restrict the processing in certain situations.
• (e) Receive personal data provided to us in a structured, commonly used and machine-readable format and to request that we transmit this data directly to another controller.
• (f) Object to certain types of processing in certain situations.
• (g) Lodge a complaint with the Office of the Commissioner for Personal Data Protection (Postal address: Kypranoros 15, Nicosia 1061, Cyprus / Email address: commissioner@dataprotection.gov.cy / Tel.: +22818456).
• (h) Withdraw your consent at any point in time without affecting the lawfulness of processing based on consent before its withdrawal by emailing our Data Protection Officer at: Iacovos Panayiotou by post at 182 Giannou Kranidioti Av., Nicosia, CY – 2235.

7. TECHNICAL DATA

7.1. We may collect technical data, such as your web browser or operating system, which does not identify you personally but aids in website traffic monitoring.

8. UPDATES TO OUR POLICY

We may periodically update this Privacy Policy to reflect any changes regarding the use of your personal information required by the data protection legislation.