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Privacy Policy

Omorodion Holdings Limited ("Omorodion", "we", "us", or "our") respects your privacy and is committed to protecting it through compliance with this Privacy Policy (this "Policy"). This Policy describes the types of information we may collect from you or that you may provide when you visit our websites (each, a "Website"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Our Websites do not require you to register or create an account, and we do not knowingly collect account credentials from visitors. The information we collect through the Website consists mainly of usage data generated automatically as you browse, together with any information you choose to submit to us directly, for example through a contact or inquiry form.

This Policy applies to information collected through our Websites. It does not apply to information collected offline or through other means, including through a separate Service Agreement you may enter into with us for our website and mobile application development and support services, which may be subject to a separate data processing agreement.

Please read this Policy carefully. By using a Website, you acknowledge that you have read and understood this Policy.

1. Data Controller

For the purposes of the EU General Data Protection Regulation (GDPR) and the Cyprus Law on the Protection of Natural Persons with regard to the Processing of Personal Data and the Free Movement of such Data (Law 125(I)/2018), the data controller responsible for the Website is:

Omorodion Holdings Limited
Spyrou Kyprianou, 79, PROTOPAPAS BLDG, 2nd floor, Flat/Office 201, 3076, Limassol, Cyprus
Company Registration No.: HE 497938
Email: info@omorodion.org

2. No Account Registration

Our Websites do not offer, and do not require, user account registration. We therefore do not collect passwords, account profiles, or similar registration data through the Website. Where we refer to "you" providing information in this Policy, this means information submitted voluntarily (such as through a contact form or email) or collected automatically through your use of the Website, as described below.

3. Information We Collect

3.1 Usage Data (Collected Automatically)

When you visit the Website, we and our service providers automatically collect certain information about your device and how you interact with the Website ("Usage Data"), which may include:

  • IP address and approximate location derived from it (e.g., country or city level);

  • browser type and version, device type, and operating system;

  • pages viewed, time spent on pages, click patterns, scroll behavior, and navigation paths through the Website;

  • referring and exit pages, and the search terms that led you to the Website (where available);

  • date and time stamps of your visit;

  • language preferences and general technical settings of your device;

  • aggregated or de-identified analytics identifiers used to distinguish unique visitors and returning sessions.

Usage Data is collected primarily through cookies, pixels, and similar tracking technologies, as described in Section 4 below.

3.2 Information You Choose to Provide

If you contact us through a form on the Website, by email, or otherwise to make an inquiry about our Services, we will collect the information you provide, which may include your name, email address, company name, phone number, and the content of your message. Providing this information is voluntary, but necessary if you want us to respond to your inquiry.

3.3 Information We Do Not Collect

We do not collect special categories of personal data (such as health, biometric, or genetic data) through the Website, and we do not knowingly collect personal data from children (see Section 11). We do not require or collect payment card details through the Website itself; any billing information for our Services is handled separately under your Service Agreement.

4. Cookies and Similar Technologies

The Website uses cookies and similar technologies (such as pixels and local storage) to operate reliably and to understand how visitors use the Website. We categorize these as follows:

  • Strictly Necessary Cookies - required for the Website's core functionality (e.g., security, load balancing, remembering cookie preferences). These do not require consent.

  • Analytics Cookies - help us understand aggregate visitor behavior (e.g., pages visited, time on site) so we can improve the Website. These are used based on your consent where required by law.

  • Marketing/Advertising Cookies - used to measure the effectiveness of our own marketing of our Services. These are used based on your consent where required by law.

Where required under applicable law, a cookie banner or preference tool is presented on your first visit so you can accept or reject non-essential cookies and change your preferences at any time. You can also control cookies through your browser settings, though disabling certain cookies may affect Website functionality.

5. Legal Basis for Processing

Where the GDPR applies, we rely on the following legal bases to process your personal data:

  • Legitimate interests - to operate, secure, and improve the Website, and to understand aggregate usage trends, provided these interests are not overridden by your rights and interests;

  • Consent - for non-essential cookies and similar tracking technologies, and for any marketing communications you opt into, which you may withdraw at any time;

  • Pre-contractual and contractual necessity - to respond to inquiries you submit and to take steps toward entering into a Service Agreement with you;

  • Legal obligation - where we are required to process or retain data to comply with applicable law.

6. How We Use Your Information

We use the information we collect to:

  • operate, maintain, and improve the Website and monitor its performance and security;

  • understand aggregate visitor trends and preferences to improve content and user experience;

  • respond to inquiries and communicate with you about our Services;

  • measure and improve the effectiveness of our own marketing and advertising activities;

  • comply with applicable legal, regulatory, and contractual obligations;

  • detect, investigate, and prevent fraudulent, unauthorized, or illegal activity.

We do not sell your personal data, and we do not use Usage Data to build individually identified profiles for sale or rental to third parties.

7. Disclosure of Your Information

We may share information we collect through the Website with:

  • service providers who perform functions on our behalf, such as website and application hosting, analytics providers (e.g., web analytics tools), email delivery services, and IT support, under contractual obligations to protect your information;

  • advertising and social media platforms, where you interact with our own ads or content and where cookie-based measurement tools are enabled, subject to your cookie preferences;

  • professional advisors, such as lawyers, auditors, and accountants, in connection with our business operations;

  • regulators, law enforcement, or other third parties where required by law, regulation, or legal process, or to protect our rights, property, or safety, or that of others;

  • a successor entity in connection with a merger, acquisition, financing, or sale of assets.

8. International Data Transfers

As a Cyprus-based company, we are established in the European Union. Some of our service providers (for example, certain analytics or hosting providers) may process data outside the European Economic Area (EEA). Where this occurs, we take steps to ensure an adequate level of protection, such as relying on the European Commission's Standard Contractual Clauses, an adequacy decision, or other lawful transfer mechanisms recognized under the GDPR.

9. Data Retention

We retain Usage Data for as long as reasonably necessary for the analytics and security purposes described in this Policy, typically in line with the default retention settings of our analytics tools, after which it is deleted or aggregated/anonymized. Information you submit through a contact form is retained for as long as needed to respond to your inquiry and, if it leads to a business relationship, in accordance with our records-retention practices and any applicable Service Agreement. We retain information only for as long as necessary for the purposes set out in this Policy, unless a longer retention period is required by law.

10. Data Security

We implement reasonable technical and organizational measures designed to protect information collected through the Website from accidental loss and unauthorized access, use, alteration, or disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee the absolute security of information transmitted to or stored on the Website.

11. Children's Privacy

The Website is not directed at children under the age of 16, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can take appropriate action.

12. Your Data Protection Rights

If you are located in the EEA, the UK, or another jurisdiction with similar data protection laws, you have the following rights in relation to your personal data, subject to applicable legal conditions and exceptions:

  • Access - to request confirmation of whether we process your personal data and to obtain a copy of it;

  • Rectification - to request correction of inaccurate or incomplete data;

  • Erasure - to request deletion of your personal data in certain circumstances;

  • Restriction - to request that we limit the processing of your personal data in certain circumstances;

  • Data portability - to receive certain personal data you provided to us in a structured, commonly used, machine-readable format;

  • Objection - to object to processing based on our legitimate interests or for direct marketing purposes;

  • Withdraw consent - where processing is based on consent (e.g., non-essential cookies), to withdraw it at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us using the details in Section 15. You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection, or with the supervisory authority in your own country of residence within the EEA, if you believe our processing of your personal data infringes applicable law.

13. Do Not Track Signals

Some browsers offer a "Do Not Track" (DNT) signal. There is currently no uniform industry standard for recognizing or responding to DNT signals, so the Website does not currently respond to them. We will reassess this position if a common standard is adopted.

14. Third-Party Links

The Website may contain links to third-party websites or services that are not owned or controlled by Omorodion. This Policy does not apply to, and we are not responsible for, the privacy practices of any third-party sites. We encourage you to review the privacy policies of any third-party site you visit.

15. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Effective Date" at the top of this Policy indicates when it was last revised. We encourage you to review this Policy periodically. Material changes will be indicated by updating the Effective Date or, where appropriate, through a notice on the Website.

16. Contact Us

If you have questions, comments, or requests regarding this Policy or our data practices, please contact us at:

Omorodion Holdings Limited
Spyrou Kyprianou, 79, PROTOPAPAS BLDG, 2nd floor, Flat/Office 201, 3076, Limassol, Cyprus
Company Registration No.: HE 497938
Email: info@omorodion.org

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