Privacy Policy

This Privacy Policy describes management by SpecTec Group Holdings Ltd. (as hereinafter identified "Controller") of any personal data (as hereinafter specified "Personal Data") relating to a natural person (“Data Subject”) identified or can be identified, directly or indirectly by reference to the use, for whatever purpose, of the following web site address owned of the Controller: (“Controller’s Web Site”).

The purpose of this Privacy Policy is to outline the steps Controller takes to keep Personal Data confidential, to inform Data Subject about how and why Controller collects Personal Data and to provide Data Subject with its rights and Controller’s contact information to exercise these rights and for any questions or concerns arising out of this Privacy Policy.

Protecting Data Subject privacy and maintaining the integrity of Personal Data means that: Controller will keep Personal Data and the business between Data Subject and Controller in confidence; Controller will not sell, rent or loan Data Subject’s information to third parties; Controller will respect Data Subject’s privacy when Controller may contact Data Subject concerning various products and services which Controller make available to Data Subject from time to time; Controller will have control over how obtains, uses and under circumstances gives out information about Data Subject; and Data Subject will have access to the information that Controller have about Data Subject.

This Policy Privacy only applies to Controller’s Web Site and does not concern any web sites that Data Subject may visit by external links.

Controller and Processor of Personal Data

Controller who determines the purposes and means of Personal Data collecting and processing is SpecTec Group Holdings Ltd with registered office in Limassol, Cyprus.

The processing operations of Personal Data, whether or not by automated means, are performed on behalf of the Controller by SpecTec Group Holdings Ltd with registered office in Limassol, Cyprus (“Processor”) and carried out at this place.

Why Controller May Collect Personal Data

Controller collects Personal Data and uses it in order to:

  • Establish identity
  • Perform necessary identity and security verifications
  • Process transactions and conduct business
  • Deliver products and services
  • Provide customer support and services
  • Provide ongoing service delivery
  • Provide Data Subject with information
  • Improve products, services and service delivery
  • Better understand Data Subject’s needs, interests and suitability for various products and services
  • Recommend specific products and services that may meet  Data Subject’s needs
  • Respond to issues, questions, and queries
  • Protect Data Subject and himself against errors or fraud; and
  • Co-operate with law enforcement and legal authorities, where required, to comply with applicable laws and with courli>orders.

Controller will collect, use and may disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances; and endeavors to collect as little information as possible as may be necessary under the circumstances.

Data Subject takes note that aggregated statistics and information, where the identity of a specific individual cannot be identified, is not Personal Data. Controller reserves the right to use aggregated information in any manner it determines, in its discretion, to be appropriate. Use of such aggregated information may include, but not be limited to, the preparation of aggregated user statistics and information summaries to improve efficiencies, more effectively describe Controller’s product and service offerings, and assist in the marketing of Controller’s products and services.

Aggregated statistics and information will not contain Personal Data.

What Type of Personal Data Controller May Collect

Controller collects various types of Personal Data. During the course of using Controller’s Web Site or doing business or interacting with Controller, or receiving products and services from or through Controller, Data Subject may depending on the nature of the circumstances be asked to provide Controller with:

  • Geographic (physical) addresses
  • Demographic information
  • E-mail addresses
  • Phone numbers or other contact information
  • Names (first, and last or whatever the family identifying name is)
  • Shipping information
  • Billing information
  • Transaction history
  • Web site usage preferences
  • Feedback regarding business, services, web site and public relations
  • Source IP addresses
  • Times and dates of access to Web site servers
  • Language
  • Personal preferences
  • Product and service preferences
  • Browsers types and configurations and Miscellaneous administrative and computer traffic information

Certain forms of information, such as government issued or private sector issued licenses, permits, certificates, cards, in the nature of driver's licenses, social insurance/security number, passports, insurance cards, voucher numbers, and the like, although convenient for identification, is voluntary. It is up to Data Subject whether wants to provide this, or other suitable identification, subject to any legal requirements.

How Does Controller Collect Personal Information

Controller will only collect Personal Data that Data Subject has voluntarily provided to Controller or have agreed to have provided to Controller. Controller will not collect any Personal Data about Data Subject without advising Data Subject accordingly (either by way of this Privacy Policy or by way of providing Data Subject with some other form of notice at the time Controller is requesting or collecting Personal Data), why and how that Personal Data is being collected and how such Personal Data will be used or disclosed. Controller may collect Personal Data through a variety of means:

  • using Controller’s  Web Site
  • using Controller’s services
  • in the course of communications with Controller (face-to-face, by e-mail, by phone, mail or otherwise) in the course of feedback to Controller regarding Controller’s business, services, website and publications
  • when registering with Controller for services or, where relevant, accounts, or, where relevant, for the download of Controller’s software
  • customer, membership, recipient, or service lists that have been lawfully acquired from third parties
  • through the completion of manual or electronic forms
  • website cookies – Cookies are identifiers that can be sent from a website via Data Subject’s browser to be placed on computer's hard drive of Data Subject. Data Subject may elect not to accept cookies by changing the designated settings on Data Subject’s web browser; however, not utilizing cookies may prevent Data Subject from using certain functions and features of Controller’s Web Site. Information collected from the use of cookies is used to improve Controller’s services
  • web beacons – Web beacons are small, graphic images that allows a website operator to collect certain information and monitor user activity on its website. A web beacon is a very small pixel which is invisible to the user. Controller uses web beacons to collect information that is not of a personal nature
  • clickstreaming - Clickstreaming is a technology that allows a website operator to track the paths that surfers take as they access a website and look at the site's pages, and as they use links to other sites. Controller collects such information from visitors to Controller’s Web Site; and
  • website traffic information, which is monitored and analyzed in order to determine which products, services or features may be of interest to visitors, so Controller may improve website, products, services, features or other offerings of the Controller.

In addition, Controller may review and analyze Data Subject’s use of products and services, to help him serve Data Subject better, and to bring other products and services to Data Subject’s attention, which Controller feel, will be of benefit to Data Subject. Controller also collect and analyze information from other sources for the same purposes.

How Controller May Disclose Personal Information

Controller does not sell any Personal Data it collects to third parties. Controller may share Personal Data with its affiliates, subsidiaries, employees, contractors and agents in the course of providing Data Subject with Controller’s business services, support, or the fulfillment or delivery of products or services of the Controller.

Controller may disclose Personal Data if is required to do so a court of competent jurisdiction, other legal or regulatory authority, or, if there is a good faith belief, and reliance on said belief that disclosure is necessary to: comply with any legal process served on Controller; maintain, uphold or protect Controller' rights or property; protect and ensure the personal safety of the public or other Controller’s clients; or protect against criminal or quasi-criminal activities, or to detect, prevent, investigate allegations of, or address, misrepresentation or fraud.

Controller reserves the right that in the event of a bankruptcy filing, mergers with third parties, acquisition by third parties, sale of assets (all or partial), or any other transfer of all or substantially all of Controller’s relevant assets to a third party, that Controller shall be entitled share (or sell as an ancillary aspect of the overarching business transaction) the Personal Data provided by Data Subject to the third party.

Retention and Disposal

Controller keeps information only for so long as it is needed for the efficient and effective delivery or fulfillment of the software, products, or services using or contemplating using by Data Subject and for a reasonable time thereafter, or to meet any legal requirements. Controller will either destroy or remove information when it is no longer needed.

Security and Storage

Controller endeavors to maintain appropriate physical, procedural and technical security with respect to its and Processor’s offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Data. This also applies to Controller’s disposal or destruction of Personal Data.

Controller  keeps the Personal Data collected from about Data Subject strictly confidential. Only authorized personnel have access to this Personal Data. Personnel of the Controller and Processor who have access to Personal Data receive training regarding privacy protection.

If any employee, contractor or agent of Controller or Processor misuses Personal Data, this will be

considered as a serious offense for which disciplinary action may be taken, up to and including termination of employment or contract for service. If any individual or organization misuses Personal Data - provided for the purpose of providing services to or for Controller, this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between Controller and that individual or organization and possible legal action against such individual or organization.

Controller’s computer security specialists build security into all our computer systems. This protects Personal Data at all times, when it is stored in data files or handled by employees of Controller or Processor. Controller’s systems also protect Personal Data when it is transmitted, for example, between data processing centers of Processor, Controller’s stores and corporate offices.

Controller is and shall continue to use industry-standard technology to maintain the security of  Personal Data, and for Controller’s connections to the internet; however, Controller cannot and does not guarantee the privacy, security, authenticity or non-corruption of any information transmitted through the internet or any for information stored in any third-party system connected to the internet.

While Controller takes steps to verify that any service providers, suppliers or the like with whom Controller share Personal Data are committed to maintaining the privacy of Personal Data at standards that are at least as stringent as Controller’s Privacy Policy and has communicated to them to refrain from making any independent or unauthorized use of any Personal Data, Controller does not and cannot guarantee the actions, conduct or standards of any such parties.

Controller shall not be responsible for any claims, damages, costs or losses whatsoever arising out of or in any way related to third-party connections to or use of the Internet. Controller cannot and does not ensure the protection of any Personal Data that Data Subject provide to a third-party web site that may reference, be referenced or link to Controller’s Web Site. Personal Data collected by these third parties is not subject to, or governed by, this Privacy Policy.

Controller shall not be responsible for events beyond our direct control. Controller will not be liable for any direct, indirect, incidental, consequential or punitive damages relating to the uses or releases of Personal Data.

Data Subjects' Rights

Data Subjects is entitled at any time to obtain confirmation of the existence of Personal Data and to be informed of their contents and origin, to verify their accuracy, or else request that such data be supplemented, updated or rectified (Section 3 articles 16 to 22 of EU Regulation 2016/679 Link to

The above Section also provides for the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data.


Controller is committed to upholding this Privacy Policy. Controller have policies and procedures in place to educate and assist his employees and contractors in fulfilling their obligations under this Privacy Policy. Controller’s policies and procedures will be reviewed on a regular basis and their results of such review will be presented to Controller’s personnel responsible for overseeing privacy matters.

Controller is committed to treating Data Subject with the greatest respect and consideration. Data Subject please let know Controller if he has any questions or concerns and will take steps to address them. If Data Subject has any questions regarding this Privacy Policy, would like to confirm the accuracy of its Personal Data, believes that the privacy of Personal Data has not been respected, or would like to update or delete incorrect Personal Data, please contact Controller by emailing at or write to the attention of Privacy Policy Manager, SpecTec, 1 Agias Fylaxeos St, KPMG Centre 2nd Floor Office 1, 3025 Limassol, Cyprus.

The Privacy Policy Manager will acknowledge the query and will respond within thirty business days. If Controller needs to extend timing for response, or have to refuse Data Subject’s request, Controller will advise Data Subject accordingly, subject to any legal restrictions.


Controller is committed to protecting the safety of children. Controller will not knowingly request or use Personal Data from children under the age of eighteen without parental consent. If Controller receives actual knowledge does not knowingly or intentionally collect any Personal Data from children under the age of eighteen, Controller will take steps to have such Personal Data eliminated. The Controller’s Web Site is not to be used by anyone under the age of eighteen. Persons under the age of eighteen are not authorized to use Controller Web Site and are directed to immediately discontinue use of Controller  Web Site.


Controller may from time to time update this Privacy Policy, with the updated policy to be posted on the Controller’s Web Site. The use of Personal Data provided to Controller prior to the update will continue to be governed by the policy in effect at the time the information was provided. Controller recommend that Data Subject revisit this Privacy Policy from time to time on a regular basis.


In most cases Data Subject will be asked to specifically express its consent to collecting and processing Personal Data by Controller in accordance with this Policy Privacy. Data Subject will nor obliged to provide such consent, The absence will be excluded Data Subject from participating in specific services or activities.

In the all others cases Controller may deduct the manifestation of Data Subject by using Controller’s Web Site: in these cases Data Subject if continues the Controller’s Web Site use agrees, and hereby consents, to collection and use of Personal Data for purposes for which the Personal Data was collected and in accordance with this Privacy Policy. If Data Subject does not consent, Data Subject must to immediately discontinue use Controller’s Web Site and to refrain from further using.

Governing Law and Venue

The processing of Personal Data is performed in the context of the activities of the Controller and Processor established in European Union and is subject to “EU Regulation 2016/679 on the protection of natural person with regard the processing of personal data and the free movement of such data” and to the relevant EU member country national law before the competent local court.

Controller will disclose Personal Data without Data Subject permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to Controller’s company, associates, or property (including this website), or to others.