Privacy Policy

Introduction

This Privacy Policy explains how sarnovitel.top Ltd ("we," "us," or "our") collects, uses, and protects your personal information when you visit our website sarnovitel.top or use our fitness client engagement automation services. We are committed to protecting your privacy and ensuring transparency about our data practices.

Data Controller Information

sarnovitel.top Ltd is the data controller for the personal information we collect. Our contact details are:

• Company: sarnovitel.top Ltd
• Registration Number: HE497625
• Address: Evagoras Avenue 5, 1004 Nicosia, Cyprus
• Email: [email protected]
• Phone: +357 22 712 025

Data Collection

We collect personal data in various ways to provide and improve our services. The data we collect includes information you provide directly to us, information collected automatically through your use of our website and services, and information from third-party sources where applicable.

Information You Provide

When you use our website or services, you may provide us with personal information including:

• Contact information (name, email address, phone number)
• Business information (company name, business type, number of members)
• Account credentials and profile information
• Communication preferences and settings
• Messages and correspondence you send to us
• Payment information (processed securely through third-party providers)

Information Collected Automatically

When you visit our website, we automatically collect certain technical information including:

• IP address and location data
• Browser type and version
• Device information and operating system
• Website usage data and navigation patterns
• Referral sources and exit pages
• Time and date of visits

How We Use Your Information

We use your personal data for legitimate business purposes and to provide you with our services. How we use your information depends on the services you use and your relationship with us.

Service Provision

We use your data to:

• Provide and maintain our fitness automation services
• Process your account registration and manage your subscription
• Respond to your enquiries and provide customer support
• Process payments and manage billing
• Deliver automated messaging and engagement tools

Communication and Marketing

We may use your contact information to:

• Send important service updates and notifications
• Provide technical support and customer service
• Send marketing communications about our services (with your consent)
• Conduct customer satisfaction surveys

Business Operations

We use data to:

• Improve our website and services
• Conduct analytics and research
• Ensure security and prevent fraud
• Comply with legal obligations

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Contract: To fulfil our contractual obligations to provide services
• Legitimate Interest: To operate our business, improve services, and communicate with customers
• Consent: For marketing communications and certain cookies
• Legal Obligation: To comply with applicable laws and regulations

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use, please see our Cookie Policy.

Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your information in the following circumstances:

Service Providers

We work with trusted third-party service providers who assist us in operating our business and providing services to you, including:

• Cloud hosting and infrastructure providers
• Payment processing companies
• Email marketing and communication platforms
• Analytics and advertising services
• Customer support tools

Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes or government requests
• Protect our rights, property, or safety
• Investigate potential violations of our terms
• Prevent fraud or security threats

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the European Commission
• Standard contractual clauses approved by the European Commission
• Binding corporate rules or certification schemes

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, and resolve disputes. Our retention periods vary depending on the type of data and our relationship with you.

General Retention Periods

• Account Data: Retained for the duration of your account plus 7 years for legal compliance
• Communication Records: Retained for 3 years after the last interaction
• Marketing Data: Retained until you withdraw consent or 2 years of inactivity
• Website Analytics: Anonymised after 26 months
• Financial Records: Retained for 7 years as required by law

Your Rights

Under data protection law, you have several rights regarding your personal data:

Access and Portability

• Right of Access: Request a copy of the personal data we hold about you
• Data Portability: Receive your data in a structured, machine-readable format

Correction and Deletion

• Rectification: Correct inaccurate or incomplete personal data
• Erasure: Request deletion of your personal data in certain circumstances

Processing Controls

• Restriction: Limit how we process your data in certain situations
• Objection: Object to processing based on legitimate interests or for marketing
• Withdraw Consent: Withdraw consent for processing where consent is the legal basis

To exercise any of these rights, please contact us at [email protected] or +357 22 712 025. We will respond to your request within one month.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication systems
• Employee training on data protection
• Incident response procedures

Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after any changes indicates your acceptance of the updated policy.

Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Email: [email protected]
• Phone: +357 22 712 025
• Post: sarnovitel.top Ltd, Evagoras Avenue 5, 1004 Nicosia, Cyprus

Supervisory Authority

If you believe we have not handled your personal data in accordance with data protection law, you have the right to lodge a complaint with the relevant supervisory authority. In Cyprus, this is the Office of the Commissioner for Personal Data Protection.